Sustainable Management of Beech Forests:
Consequences for Biodiversity and New Zealand Conservation Management

Submission of Evidence


Dr Henrik Moller

Ecosystems Consultants Ltd.,
P.O. Box 6161,

03 – 4776885
03 – 4776895 (Fax)
Email:          ecosyst@es.co.nz
Web site: www:nzecosystems.com

Presented in Support of Resource Consent Application

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Go to index.

Executive Summary

This TWC proposal is innovative and ecologically sensitive. It embodies a complete paradigm shift from earlier exploitative and ecologically unsustainable forestry practices. Economic return has been moderated so that a very small fraction of the annual production of the forest is taken. Tree removals are on small spatial scales, the size of natural forest gaps. Species and size classes of small groups of trees are selected for removal in direct proportion to their availability in the forest. This means that the size structure and species composition of the forest are not greatly altered, and forester's will "track" where the forest system goes rather than "pushing" it into an altered state that might yield increased timber production but also might increase risks to biodiversity. The proposal is in line with international contemporary shifts to 'Natural Forestry' and 'Ecosystem Management' approaches.

The Proposal has correctly identified the old large beech trees as an important habitat feature for birds and bats and taken several steps to ensure that this critical resource is not reduced to any great degree. Old trees and dead standing trees are sites of abundant food and hollows for nesting and roosting. They will be left and sufficient intermediate sized trees will be retained to grow through to replace natural losses in these old large trees. Rigorous monitoring of forest structure and the population abundance trends of 'focal species' will be used to guide an adaptive management approach to optimal tree removal regimes for protection of biodiversity.

Historically habitat degradation through unsustainable forestry, agriculture and urbanisation undoubtedly caused the demise and reduction of many of New Zealand's endemic species. But today it is the effect of introduced competitors, predators and browsers that are the main cause for concern in limiting native species. There is ample evidence that most of the endemic fauna and threatened species existing in TWC forests are depressed far below the 'carrying capacity' set by habitat availability because of predation by introduced mammals and wasps.

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This has two main ecological consequences: (i) declines in New Zealand's biodiversity values are inevitable unless we act with force and soon to control introduced pests; and (ii) even reasonably major reduction in habitat quality would not exacerbate current pressures on biodiversity. So even if ecologists have somehow got their predictions very wrong, which I do not believe is the case, there is little prospect of irreversible consequences for threatened biota from this proposal. Nevertheless the proposal takes a precautionary approach to ensure that nothing is done that might significantly reduce habitat quality for valued indigenous biota. It is important to retain near natural habitats not only to minimise immediate risks, but also so as not to impair ultimate levels of restored biodiversity if effective predator and browser control is put in place in the long term.

The plan for active intervention to add conservation value to forests through browser and predator control mirrors the recent efforts of DoC to create 'mainland islands'. This is part of a general shift to a more active interventionist role for conservation managers – they are assuming a type of natural gardener's role of constantly weeding out introduced pest species. Wasps, rats, stoats and possums are the most important pests to control in beech forests to trigger restoration of ecologically representative communities on New Zealand's mainland. The proposer will divert 5 – 10% of the net revenue from sustainable timber extraction into this restoration effort. The result is a net conservation gain – a true win:win between biodiversity and economic interests. Only six such mainland island restoration sites are currently mounted by DoC throughout New Zealand and TWC proposes to trial 2 to 3 intermediate sized ones on their estate alone. I consider the scale of proposed restoration effort to be impressive despite uncertainty about actual methods to be used.

As well as adding conservation values to its own forests, TWC have funded extensive wildlife surveys in their preparation of these plans. New Zealand conservation management is critically short of survey information and ongoing monitoring of biodiversity in the way now proposed in the plan. This added information is a welcome adjunct to DoC's own challenge of managing "blind" due to lack of monitoring and a shortage of research capacity. TWC-funded predator control research is already providing benefits to other conservation endeavours. Secondary poisoning techniques developed from this plan are now being widely adopted by DoC and

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Conservation NGOs to manage reserves. More research is planned on predator controls, ecology and populations of threatened species, forest community structure and processes. All the understanding and experience gained in pursuit of their research for ecological sustainability can be exported to give a lasting benefit to conservation throughout New Zealand. Research or other benefits obtained from sustainable forestry will help other under-funded conservation institutions such as DoC to best direct their scant resources elsewhere. This is one of the ways that New Zealand conservation will benefit from a mixture of preservation and conservation through sustainable use approaches typified by this proposal. Halting this proposal will therefore have several hidden costs for biodiversity by diversion of DoC's meagre funds from other conservation work to cover efforts proposed by the applicant.

The proposal has built in audits, controls, monitoring and mitigation processes to safeguard against deterioration of biodiversity within TWC forests. These assure public transparency. But more importantly, they set bounds on the degree of environmental damage that could occur if unexpected outcomes arise from inadequate knowledge of ecosystem processes.

Unknowns exist in all ecological management programmes, including conservation, but especially in totally new styled initiatives like the forestry proposed here. However the newness of this proposal relates to its very minimal timber extraction regimes and the 'Natural Forestry' and 'Ecosystem Management' philosophy. Common sense and existing reliable ecological knowledge about overall ecological processes leads me to expect that risks to biota from these unknowns will be minimal and containable. Mathematical modelling is underway, and more is proposed, to take best professional practice to estimating critical assumptions and set bounds on uncertainty in predictions. A formal adaptive management approach to managing these risks is proposed in the same way that is used to fine tune conservation management on nature reserves by DoC. This proposal is an important role model because New Zealand lacks formal applications of adaptive management models in the way proposed.

Placement of the first trials of "Natural Forestry" in New Zealand in north Buller and Tasman is ideal for ecological risk minimisation and capturing benefits for biodiversity. TWC land is surrounded by a large matrix of inter-connected nature reserves. This buffers the TWC forests

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from ecological damage should unexpected effects emerge from the new harvesting philosophy. Equally if the expected benefits of increased abundance of threatened and common species occurs on TWC land, the new recruits and elevated population levels could spill over into the surrounding DoC reserve land. For a conservation biologist this innovative forestry initiative could not be better sited in New Zealand.

No known critically endangered species exist on TWC land, but 'Category B' and 'C' (DoC's second and third priority) threatened species are present and overall biodiversity in the forests is of high value. This signals the need for care and risk minimisation. I consider that such steps have been taken so that very little prospect of any harm in the intermediate term remains. Rigorous monitoring and adaptive management will ensure that the slight risks will be further minimised in the longer term. Prior reservation as part of the West Coast Accord and creation of new reserves by TWC have added safety to biodiversity outside the areas proposed for harvest.

Great spotted kiwi, kaka, western weka and long-tailed bats are the species of highest priority for risk assessment and management. There is sound ecological evidence that all are threatened by introduced predators (except in the case of bats where evidence is more tenuous). I consider it very unlikely that these species will be harmed if the proposal goes ahead; indeed I consider it more likely that conservation will be denied benefit if this proposal is halted.

Direct risks to biodiversity from logging are minimal and extra precautions to protect kiwi and weka from possum harvesters and dogs are proposed. Felling of old trees containing roosting bats will replace natural tree fall because natural mortality will be subsumed by careful tree selection. Danger to torpid bats is therefore likely to be the same whether or not the proposal goes ahead.

This proposal also leads the way for sound environmental management in New Zealand by exemplifying approaches that have captured large gains for biodiversity overseas. Particularly pleasing features of general importance to conservation include:
  1. encouragement of open audit and public scrutiny on production land;

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  2. the trend towards co-management, in which local corporations or community groups have real decision making power and responsibilities for conservation action;
  3. instead of leaving active conservation management to DoC, foresters will act as environmental stewards of their land;
  4. fostering examples of 'conservation through sustainable management' alongside a preservation approach to conserve biodiversity;
  5. attention to conservation of biodiversity outside nature reserves;
  6. adoption of an 'Ecosystem Management' rather than simply an economic sustainability approach to nurturing biodiversity;
  7. demonstrating commitment to sustained active management to restore biodiversity on the New Zealand mainland rather than just relying on biodiversity on off-shore islands;
  8. using financial profit as an opportunity to enhance biodiversity rather than threatening it. This proposal could act as a role model for other natural resource managers;
  9. building trust and mutual support between responsible resource users and conservationists;
  10. by honouring the West Coast Accord, the proposal will encourage negotiation and compromise.

The risks of not proceeding with this proposal go far wider than the lost benefits for biodiversity that would otherwise accrue to West Coast beech forests from the proposal.

Any unwanted environmental effects are likely to be very slight and will be rapidly reversible. The scheme is much more likely to realise immediate and tangible benefits for biodiversity.

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Executive Summary   Go there.
1 Introduction: the structure of this submission  (Go there.)
2. Effects on ecosystem function, habitats and threatened terrestrial fauna   (Go there.)
        2.1 An Ecosystem Management Approach is proposed   Go there.
        2.2 Past levels: what is natural and what can we expect if we do nothing?   Go there.
        2.3 Predation by introduced mammals and wasps: the immediate threat   Go there.
        2.4 Securing habitat quality: a basic first step but not sufficient in itself   Go there.
        2.5 The importance of large old trees   Go there.
        2.6 The importance of food supplies for birds   Go there.
        2.7 Fragmentation and roading   Go there.
        2.8 Recovery forests: a long-term habitat restoration initiative   Go there.
3 Risks and potential benefits to endangered species   Go there.
        3.1 Overview   Go there.
        3.2 Kaka   Go there.
        3.3 Other hole-nesting birds   Go there.
        3.4 Kiwi   Go there.
        3.5 Other bird species   Go there.
        3.6 Bats   Go there.
        3.7 Other fauna   Go there.
4. Restoration through predator control   Go there.
        4.1 Technological advances create opportunity for restoration   Go there.
        4.2 Goal of enhancing biodiversity   Go there.
        4.3 Practicalities: the enormous magnitude of the challenge to be natural gardeners in perpetuity   Go there.
        4.4 Scale of TWC Proposed Restoration Efforts   Go there.


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5 Monitoring   Go there.
        5.1 Monitoring and adaptive management: a key for added safety for biodiversity   Go there.
        5.2 Use of indicator or focal species to measure harvesting impacts   Go there.
        5.3 Useful focal species for TWC to monitor   Go there.
6 Wider conservation management implications   Go there.
        6.1 Audit and public scrutiny: the key to public confidence in the outcome   Go there.
        6.2 Co-management: giving DoC a hand   Go there.
        6.3 Conservation outside nature reserves: the crucial next challenge   Go there.
        6.4 Foresters as gamekeepers: adding conservation value to the foresters' estate
by active management                                     Go there.
        6.5 Thinking holistically: using an Ecosystem management approach   Go there.
        6.6 Commercial enterprise: an opportunity rather than a threat for conservation   Go there.
        6.7 Sustainability: the ethos of the RMA and key challenge for the 21st century   Go there.
        6.8 Active Management, reversibility and the environmental precautionary principle   Go there.
7 Conclusion: the TWC proposal will enhance rather than threaten biodiversity   Go there.
8 References   Go there.
Appendix 1: Curriculum vitae and my standing to evaluate this proposal   Go there.

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Appendix 2: Common and scientific names used for plants and animals in this submission   Go there.
Appendix 3: Responses to the Councils' Independent Reviewer and Salient Objections   Go there.










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1.        Introduction: the structure of this submission
Go to index.

My submission first identifies general ecological processes in West Coast beech forest ecosystems affecting biodiversity, habitat and threatened terrestrial fauna (Section 2) that might conceivably be affected by the proposal. It focuses on key ecological resources and processes that must be maintained if the proposed forestry is to be truly ecologically sustainable.

Section 3 then re-examines each of these key potential effects on particular threatened species identified as being present in the TWC estate and of high conservation value. Kaka, kiwi, western weka and bats are dealt with in some detail because they are particularly important in this regard to determine whether they are likely to be put at risk. Yellow-crowned parakeets , riflemen, bellbirds, tui and/or robins are singled out as potentially important focal species to monitor. A synthesis of the detailed survey data presented separately by Rhys Buckingham (Wildlife Surveys) is also presented in Section 3 and linked to the key question of whether timber extraction will threaten the wellbeing of the bird and bat communities present.

Section 4 considers the effectiveness of proposed ecological community restoration efforts through predator and browser controls.

As in all new endeavours, there are unknowns. I comment upon monitoring to minimising risks from these unknowns as demanded by the 'Environmental Precautionary Principle' 1. The importance of these monitoring protocols and their rationale is evaluated in Section 5.

General principles of conservation management approaches are considered in section 6, before conclusions and a synthesis are presented in Section 7.

1 This principle asserts that the environment should always be "given the benefit of the doubt." Worst case scenarios concerning "Unknowns" are therefore assumed to be likely and risks of unnecessarily restricting resource users are given less emphasis.

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My evaluation of the merits of this proposal comes from the standpoint of 22 years of professional experience and expertise as an applied population ecologist and wildlife manager. The detail of this experience is outlined in Appendix 1.

Appendix 3 records my responses to Professor John Craig's 'Officials Report' and objections raised by the Royal Forest and Bird Protection Society and the Department of Conservation.

Go to index.

2.        Effects on ecosystem function, habitats and

threatened terrestrial fauna
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2.1   An Ecosystem Management Approach is proposed    
There are several dominant themes that must be addressed to manage natural resources along 'Ecosystem Management' lines2. These do not guarantee that your ecosystem will be healthy, as introduced animals impact on indigenous species no matter what your management method is. However, forest managers recognise general principles that are more likely to result in genuinely ecologically sustainable outcomes. Ideally Ecosystem Management will recognise that:
  • all levels of biodiversity are interconnected, therefore managers should not focus on only one level
  • ecological boundaries do not follow administrative/political boundaries, so management has to be at the appropriate ecological scale
  • ecological integrity must be maintained through the conservation of viable indigenous populations, inclusion of natural disturbance and ecosystem representation
  • data collection is more important in natural forestry systems than the more commercially driven forestry practices which do not attempt ecological sustainability (several more species must be monitored to protect biodiversity)
  • success or failure needs to be evaluated through monitoring programmes and the results fed back to managers
  • management has to be flexible or adaptable, continually learning and revamping their practices to capture economic and ecological goals

    2 Grumbine (1994); Perley (1998).

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  • co-operation among all stakeholders is needed to accommodate adequate ecological scales
  • organisations have to change their old links and ways to meet contemporary ecological management requirements
  • Humans are part of nature. Both nature and humans affect each other

This proposal is geared towards Ecosystem Management. It meets many of the criteria set out by Grumbine3 as indicators of ecosystem management practices. This can be seen in the proposal through
  • a hierarchical approach, where sustainable use is based around the integration of ecological, economic and social factors4
  • an intention to cross administrative boundaries where necessary to manage resources at ecological scales
  • the group-tree-selection concept which is based upon natural disturbance both in time and space
  • investment in research that has provided them with baseline data
  • existing monitoring and commissioning of research for new monitoring programmes that will help indicate the health of their forests
  • assumption of the role of adaptive managers using scientific knowledge to form a feedback loop for their managerial practices
  • cooperation with local communities and DoC as a matter of policy
  • implementation of organisational changes to be more environmentally focussed and open to such interest parties as members of environmental groups5
  • a sustainable approach is intermingled with the concept that humans and nature are part of each other.
The broad thrust towards Ecosystem Management principles makes it much more likely that this proposal will be ecologically sustainable.

3     Grumbine (1994).
4    TWC 1998 overview P171.
5    TWC has operated an open door policy and issued a standing invitation to conservation NGO leaders, scientists and politicians to come and see the proposed operations themselves. Preface, P xiv of the TWC Sustainable Beech Use plan lists the large number of visitors guided to the trial logging area.

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Go to index.
2.2 Past levels: what is natural and what can we expect if we do nothing?
There are no long-term monitoring programmes in place to quantify recent trends in wildlife abundance in TWC forests, and few elsewhere in New Zealand. The perception that species are sliding further towards the "extinction vortex"6 comes from shrinking distributions and anecdotal reports that wildlife abundance was much higher at the end of last century. Several species have already gone from all or most of the TWC beech forests (e.g., kakapo7, South Island kokako, South Island brown kiwi, Little Spotted kiwi, South Island bush wren, yellowhead, South Island saddleback, South Island piopio, short-tailed bats, and an unknown number of invertebrate and plant species)8. Others persist over wider areas but may be in decline9. Habitat removal and/or severe modification undoubtedly contributed to historical declines, especially in distribution (rather than abundance).

However the factors causing initial declines are not necessarily the main threats now. Unfortunately there are signs of ongoing declines for some species even where habitats remain unchanged. A recent (1995) repeat of bird counts done in the 1970s in beech forests at Mt Misery (Nelson Lakes National Park) has detected declines in the abundance of 10 bird species (and increase in one). No habitat modifications have occurred in Nelson Lakes National Park in these intervening years – this is a sober warning of what might happen if preservation of land alone is considered to be a sufficient conservation response.

Unless we intervene soon there is no reason to expect a halt to further degradation of biodiversity in TWC forests.
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2.3        Predation by introduced mammals and wasps: the immediate threat

6    Soule (1987) coined the term "extinction vortex" to emphasise the combined effects of several ecological threats that are causing a global extinction crisis. New Zealand has an extremely high rate of extinction and endangerment for its size, principally because its endemic island fauna evolved in the absence of browsing and predatory mammals and snakes. Our species have therefore not coped well with the onslaught of invasive predators and competitors brought to New Zealand in this age of travel. 7     Scientific names for all plants and animals mentioned in this submission are listed in Appendix 2.
8    Smith (1888).
9    For example, a preliminary Population Viability Analysis (PVA) predicts ongoing declines for South Island kaka (Seal et al. 1993).

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Predation is the most urgent problem confronting wildlife conservation in New Zealand. The Department of Conservation considers predation to be a critical threat to 18 of 30 vertebrate species, such as our national symbol the kiwi, that are of highest priority for conservation10. New Zealand's attempt to protect these species are part of our national11 and international12 obligations to protecting biodiversity. In the past, conservation managers considered predator control in situ too unreliable, difficult and expensive, so the safest and most effective response was to shift threatened species to offshore islands where the predators did not occur13. Now that most of the critically threatened species are secure on offshore islands there has been a shift of emphasis towards restoration of mainland ecological communities. This proposal continues this trend. Ongoing declines of several species suggests that predation will continue to restructure New Zealand's mainland forest communities unless the effective predator control occurs. It is only recently that relatively safe and effective methods of predator control have become available for conservation managers that might allow sustained pest control for restoration of mainland ecological communities. Rats and stoats are the critical predator species in South Island beech forests, especially after beech seeding has triggered population irruptions14.

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2.4        Securing habitat quality: a basic first step but not sufficient in itself
In the past habitat removal or severe modification has undoubtedly caused declines and endangerment of several species15. Past unsustainable forestry practices have played their part in this regrettable situation, and strident public debate over clear felling and over-cutting of indigenous forests triggered the genesis of a popular conservation movement in New Zealand16.

Evidence has been cited that past forestry practices have threatened bird numbers by removing habitat. The past history of logging impacts provides a general precautionary tale. However, use of evidence concerning past methods for predicting impacts of the new approaches embodied in

10Department of Conservation Biodiversity Research Strategy (1997).
11Conservation Act 1987.
12Agenda 21, Convention on Biological Diversity.
13Clout and Saunders (1995).
14King (1983); Elliott (1996); O'Donnell et al. (1996) King & Moller (1997).
15Most convincing in this regard is Flux's (1989) demonstration that island biogeography theory can predict almost exactly how many species went extinct on New Zealand's four main islands between 1840 and 1975 simply by measuring the reduction in forest cover.
16Bigsby (1998) attributes this highly politically charged atmosphere and mistrust of foresters (Sage 1987) to this history.


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this proposal is unbalanced risk assessment. Work by O'Donnell & Dilks (1987) and O'Donnell (1991) is the most relevant of the published record to predict impacts of logging, but there are problems using it in this way to predict outcomes for this proposal, because:

  1. the proposal is not to remove the largest live trees or standing dead spars;
  2. the paper was based on data from a different forest;
  3. it tests the model by using data from forests heavily modified by historical methods not proposed here;
  4. Dr E.B. Spurr's data, used for the test of the model, compared forests logged recently c.f. long ago17. This assumes bird abundance was the same everywhere before logging and that logging was the only important ecological change between areas;
  5. the predictions of the model worked for yellow-crowned parakeets and yellowhead, but not for kaka (we should have little confidence in any model until its predictions are upheld for a replicated series of species or place, or until a plausible post-hoc hypothesis is tested for why the model should apply to one species and not another);
  6. the model assumes that the preferences indicated by the bird studies demonstrates need, and so retrieves the over-riding assumption that habitat variables limit the populations. All animals will show preference of some sort or another18 for particular foods or places, but this does not mean that such preferences have any tangible impact on their numbers19.
The general public and some conservation NGO leaders20 have apparently failed to realise that habitat modification is no longer the critical ongoing threat to biodiversity in New Zealand, and certainly of little relevance for the current proposal.

Since there has been no broad scale active conservation management intervention in the TWC and surrounding DoC forests, there is no reason to hope that the major declines registered over the past century are not ongoing. These inferences, albeit poorly quantified, emphasise the risk of doing nothing — declines seem inevitable unless there is active management intervention to

17a spatial comparison was used to infer temporal change.
18Gray & Craig (1991) demonstrate many ways that "habitat requirement" studies assume preference = need. This can be very missleading (sic) for conservation management.
19This over-aching (sic = over-arching?) assumption is acknowledged by O'Donnell & Dilks (1994).
20Sage (1998).

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control predators. Nevertheless it is important for long-term minimal risk for biodiversity to not do anything to deteriorate habitat quality in ways that will reduce eventual "carrying capacity" 21; once predator and competitor 22 control has restored numbers.
Go to index.

2.5        The importance of large old trees
The fundamental approach of TWC's proposed timber extraction is to leave the forest structure minimally altered relative to natural variations. Indeed the careful monitoring and matching of timber removals to what is there is designed to "track" natural changes 23. Nevertheless ecological knowledge emphasises that retaining the visible presence of the forest may not be enough. Critical habitat features, like tree holes and hollows are thought to be potentially important for hole-nesting birds and bats.

Monitoring of tree size and abundance is a critical safety check for biodiversity as forest use unfolds (see Section 5 and Appendix 3). Nevertheless there are already several inferences that holes do not critically limit current abundance of birds or bats. If predation or competition from introduced mammals and wasps suppress the population or is causing an ongoing decline, the population will be below the forest "carrying capacity" set by habitat variables such as food and nest/roost hole availability. There is ample evidence of the pervasive impacts of predation, and these predatory impacts have been operating for well over a century. In such circumstances we would expect the current populations to be very much below carrying capacity set by habitat variables. For example, in the only detailed study of its kind 24, yellowhead were found to have nine times more holes than they needed. During the first four years of this study, yellowhead density was about at carrying capacity, yet it was still not limited by nest site availability, nor through competition for nesting sites with yellow-crowned parakeet. Similarly it was also

21Carrying capacity as defined by Begon et al. (1996) as the maximum population size that can be supported indefinitely by a given environment, at which intraspecific compettition has reduced the per capita net rate of increase to zero. An idealised concept not to be taken literally in practice.
22 Competition:is defined by Begon et al. (1996) as an interaction between two (or more) organisms (or species), in which, for each, the birth and/or growth rate are depressed and/or the death rate increased by the other organisms (or species).
23 altering forest structure, allowing in light and freeing up space can trigger increased forest production. A century of intensive silvicultural techniques have "pushed" the ecological system in this way to maximise timber extraction. However "Natural Forestry" (Kohlm & Franklin 1997), "Ecosystem Management" (Perley 1998) and age-old methods (Benecke 1996) trade-off such economic benefits against retention of original forest structure to protect forest biodiversity.
24Elliott et al. (1996).


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suggested that it was unlikely that nest sites were limiting yellow-crowned parakeet density25. A recent review found no evidence of nest hole competition in New Zealand forests26.

Kaka numbers are also considered to be lowered far below the carrying capacity set by tree hole availability. A Landcare research team found virtually no re-use of the same holes for nesting in their 8 year research programme of kaka at Nelson Lakes National Park27.

Larger trees have more holes28 because of their size and therefore birds can use these larger trees more. It is unlikely that the quality of the holes in larger trees is different29. Therefore, holes in all tree sizes are equally likely to be useable. This is important for predicting harvesting impacts.

The critical question is whether the harvesting proposed will lower the carrying capacity below that which the current populations occur in the face of persistent predation. I think this is very unlikely indeed. Strict testing of trends in overall tree cavity abundance will occur as forestry proceeds provides a check that I am right. In the meantime every inference and available piece of evidence suggests that hole-nesting bird abundance is not currently limited by hole availability, and that there is no threat to this critical habitat element from the proposal.

Go to index.
2.6        The importance of food supplies for birds
Mistletoe, miro and rata are important food supplies for kereru and honeyeater birds like tui, bellbird and silvereyes30. These species will not be used or changed in abundance by the proposed scheme. The especial effort to leave trees with mistletoe is potentially important since it is being progressively eliminated by possum browsing31.

25 p276 of Elliott et al. (1996b).
26Butz-Huryn (1997).
27I contacted Dr Wilson (5 October 1998) to check that no recent contrary evidence, nor significant doubts about the interpretation of their kaka supplementary feeding experiment emerged in the anonymous peer review of the submitted paper (Wilson et al 1998) when it was submitted for publication. He confirmed that no such challenges emerged, and reiterated his belief that predation remains the urgent and most important threat to the subspecies. Colin O'Donnell (in litt., 5 October 1998) concurs with this overall conclusion that predation is the key variable, but points out that he observed two nests being re-used in the Windbag area (South Westland) after 15 years.
28 Elliott et al. (1996b).
29Elliott et al. (1996) could find no evidence that large trees were used any more than expected from their increased number of holes. This suggests that there is nothing in particular about the holes in big trees that attract the birds.
30 O'Donnell & Dilks (1986, 1994).
31Wilson (1984).


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Rimu is also an important food for birds. Retention of older trees and subsumation of mortality by careful tree selection are the principal ways that this food supply will be safeguarded.

The single greatest predictor of bird abundance in the beech forests involved in this scheme is the availability of the honeydew scale insect 32 and this "keystone" or "critical" 33 species is not expected to be affected by the low intensity timber extraction regime proposed. This gives me confidence that large scale and long-term changes will not occur from this proposal.

Epiphytes are important for food and shelter and floristic diversity. Extensive epiphyte gardens predominate on the larger older trees. These will be protected by the tree selection protocols that are central to the proposal.

The whole importance of food limitation for forest bird populations is unproven, and even more difficult to evaluate than the hypothesis that tree hole availability limits the population. Evidence for the mechanisms for the effects of past logging methods on bird numbers is almost completely lacking 34. Without this knowledge of mechanisms it is much harder to guess at the likely impact of small group tree removals when the bigger/older trees are left in place. However, the same general argument about the likely impacts of predation apply to the food limitation hypothesis i.e. when severe predation occurs, especially of adults as in the kaka case 35, food is most unlikely to be a limiting factor.

The monitoring and adaptive management approach acts as an overall safeguard for these risks. Similarly, the same large trees left in situ by the group-tree selection protocols to safeguard

32 See Gaze & Clout (1983), Clout & Gaze (1984), Moller et al. (1989), Moller & Tilley (1989) for this over-riding importance of honeydew scale insects.
33 Keystone or critical species (Paine 1994) are the crucial species to not alter in any ecosystem if conservation is the aim. These are the species which most affect the abundance of many other species in the system and so control key elements of ecological community structure and ecosystem functioning.
34Removal of foods and nesting hollows/roosts are mentioned by O'Donnell & Dilks(1987), but we do not know which, if any, of these are important. Indirect mechanisms such as the effects of logging on predation have not even been considered and could conceivably have driven the putative "habitat" effects from past destructive logging techniques.
35 See Wilson et al. (1998) for evidence of adult predation, and Seal et al. (1993) for the PVA that this is the key driver of decline in kaka populations.


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availability of cavities will also help ameliorate potential food impacts because the largest trees are also the favoured feeding trees for many species of bird 36.
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2.7        Fragmentation and roading

On average ca 3 - 4 gaps (maximum of 0.05ha each) will be created per hectare of forest in each harvesting event (every 15 years). Most passerines have territories in the order of a hectare, and bats in the order of 10s of square km, so localised effects are unlikely to be significant. This style of forestry is fundamentally different in that it does not trigger fragmentation of the habitat. The size and intensity of tree removal events is similar to natural levels of gap formation in the forest and artificial gaps replace natural gaps by (the process of subsumation) the tree selection and subsummation of natural mortality process. There will not be a cumulative effect from natural gaps plus artificials. The artificial gaps will replace (subsume) natural gaps that would otherwise form. Canopy cover therefore remains intact. Fragmentation is therefore maintained at broadly natural levels.

Fragmentation is a potential threat by disrupting dispersal between patches of suitable habitat. It also causes an increase in edge habitat compared to cores, and such edges are considered potential sites of intense predation and invasion by weeds. This "ecotone" idea has been promulgated from overseas work. DoC's Eglinton predator research team could find no evidence that stoats concentrated their activity near to roads in 1990/91 and 1992/93, and in 1991/92 traps along roads actually caught significantly fewer stoats37. The only direct test of this "habitat edge" hypothesis in New Zealand so far failed to find any change in probability of predation of yellow-eyed penguin chicks on edges c.f. middle of forest breeding areas38. It may be that New Zealand biota are so vulnerable to predation that any slight concentration of predators on habitat edges is irrelevant (since nestlings in centres are also nearly always eliminated even if there was less predator use of such areas).

36O'Donnell & Dilks (1987, 1994).
37Dilks et al. (1996).
38See Ratz (1997). The habitat patch sizes may have been too small in that study to detect such an effect, or the effect may not occur in new Zealand ecological conditions.


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Roads may also benefit biodiversity by allowing cost effective predator controls 39 and are also favoured feeding sites for long-tailed bats 40 because they create habitat edges.

Roads also present potential threats to forest communities, through the dispersal of invasive species via road and road traffic41. Male stoats are thought to use the roadside habitat more often than females42 but there has been little research into the effects of roading on New Zealand's ecology43.

In any event, the proposed application reduces requirements for roads by about 10-fold, traffic is infrequent and the roads are narrow. They most certainly do not represent barriers to dispersal in the way large motorways do overseas.
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2.8        Recovery forests: a long-term habitat restoration initiative
The primary way that this proposal will confer benefits on biodiversity will be through predator control. However some small areas of 'recovery forest'44 will be restored by silviculture methods directed to recreating more natural forest structures. There is ample evidence that bird abundance is reduced in recovery forests compared to unlogged forests45. Active intervention by foresters will speed the restoration for the long-term benefit of regional biodiversity.







39Moller & Alterio (1998).
40O'Donnell PhD thesis (1999).
41Timmins & Williams (1991).
42Murphy & Dowding (1994).
43see Spellerberg & Morrison's (1998) literature review on the ecological effects of new roads.
44Heavily cut-over forests from unsustainable forestry in the past.
45See Rhys Buckingham's evidence for this hearing, O'Donnell and Dilks (1987) and O'Donnell (1991).


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Go to index.

3.        Risks and potential benefits to endangered species


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3.1        Overview
TWC forests have some areas of high species richness and abundance46. In no case is there unequivocal evidence that the nationally threatened biota present in the TWC forests are at critically low abundance (i.e. below the "Minimum Viable Population" 47) in ways that threaten long-term local persistence. Thus we do not know if low abundance itself is a threat. Nevertheless the "Environmental Precautionary Principle" applied in this proposal aims to set a proximate goal to not do anything that lowers threatened wildlife abundance below its current level, or below its current trajectory of ongoing decline. I also consider that nothing in the proposal will greatly reduce the prospects of population recovery later, assuming that effective and widespread predator controls can be achieved and the adaptive management process is adhered to.

The standard DoC criteria for threatened species work48 lists the following classifications for species on TWC land:

Category A: (Highest priority): No species on TWC land49                                                                                  
Category B: (Second priority): Great Spotted kiwi                                                                                  
South Island kaka                                                                                  
Blue Duck                                                                                  
New Zealand falcon                                                                                  
Long-tailed bat                                                                                  
Western weka                                                                                  
Category C: (Third priority): Yellow-crowned parakeet                                                                                  

46 Buckingham (1999).
47Gilpin et al. (1986); Hamilton & Moller (1995).
48Molloy et al. (1994).
49 Short-tailed bats are Category "A" species. R. Buckingham and his co-workers (Buckingham & Nilson 1994; Buckingham & Brown 1996; Buckingham 1998; 1999) found no evidence of this species on TWC land. Similarly Dr. W.J. Hamilton found no short-tailed bats at ca 30 randomly chosen sites on TWC land surveyed with automatic bat detector listening stations (O'Donnell and Sedgeley 1994). However Dr. Hamilton recorded short-tailed bats repeated over five nights in farmland ca 1km from a TWC forest edge at Station Creek, Maruia Valley. Short-tailed bats are relatively cryptic even when survey teams have ultrasonic bat detectors. For example O'Donnell et al (1999) did not discover short-tailed bats in the Eglington Valley until 1998, despite 6 years of intensive work on long-tailed bats at the same site. Further investigation may yet reveal short-tailed bats living in the area, but so far the historical and current evidence (Molloy 1995) suggests that this species have gone extinct over most of the TWC estate.


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I concur with R. Buckingham50 that the proposed harvesting is most unlikely to harm these threatened species in TWC forests. The TWC estate has a high species diversity and bird abundance in some areas. It is important to note that the best areas of habitat in the region were taken into DoC reserves at the time of the West Coast Accord. This creation of reserves to exclude sites of importance for wildlife from harvesting was continued by TWC when preparing these plans 51 . What remains in areas zoned for harvesting therefore has broadly much lower biodiversity value than the region as a whole. In this way a precautionary approach has already been taken to minimise risks to biodiversity from harvesting52.

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3.2        Kaka
The threatened status of kaka is well researched, and their low abundance and infrequent success in breeding in the South Island are major causes for concern. Historically and on a very large spatial scale, habitat removal undoubtedly caused declines in the distribution of kaka. However clearfelling or over-cutting is not proposed in this proposal, so it would be a non sequitur to link these historical patterns to predictions of what might happen now.

50See his evidence to this hearing.
51Buckingham (evidence from this hearing) summarises the criteria used (conservation importance, areas with regionally threatened species, areas with notably high density or diversity, locally unique or rare habitats) in reserve selection. A total of 14 additional reserves were created.
52The extensive reservation approach used here parallels the superb initiatives planned in Chile's Rio Condor project (Arroyo 1996). Prominent New Zealand activists have publicly supported the Rio Condor project (eg Mark 1998). I consider the current proposal to match the Rio Condor project in every respect but one in its concern and detailed planning to conserve biodiversity. The one exception is that this proposal is to use group tree selection whereas the Rio Condor project was to use coupes. There is no doubt that group tree selections the size of natural gaps is far better for biodiversity than coupes. I therefore consider the TWC proposal to be even better than the Rio Condor project and do not understand why local preservationists do not prefer it.


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A Landcare Research team led by Dr Peter Wilson has tested the hypothesis53 that reduction of honeydew by introduced social wasps reduces kaka breeding rate and/or success through competition54. A supplementary feeding experiment, now finished, discounted the competition hypothesis55. Instead predation of chicks and sitting adult females at nests by stoats is now considered to be the key threat to South Island kaka56. Reduction in numbers by predators means that this species is most unlikely to be limited by food or hole availability. Therefore this proposal will not depress kaka numbers. In fact it may enhance them enough through predator control efforts.
Go to index.

3.3          Other hole-nesting birds
As for other New Zealand hole nesting bird species, yellow-crowned parakeets (a category C threatened species) are vulnerable to introduced predators57. However, yellow-crowned parakeets are relatively more susceptible to stoat predation than most other endemic hole nesting birds58. Yellow-crowned parakeets nest later than most other hole nesting forest birds and their breeding season extends into the time when stoats are reaching their highest numbers. Yellow-crowned parakeets nest in holes with only one entrance. The incubating adult is always a female. Therefore nest predators often "trap" and kill the incubating adult female as well as eggs and chicks. This causes a sex-biased death rate due to predation, with fewer females available to re-nest after nest predation. Additionally both the incubating female and older nestlings are highly conspicuous to predators due to their noisy vocalisation during feeding59. Loss of adults to predators is usually a catastrophic threat for any New Zealand bird because they tend to be naturally long-lived and slow reproducers60.

53first suggested by Beggs & Wilson (1991).
54O'Donnell & Rasch (1992) also speculated that competition with possums for mistletoe could threaten kaka. The supplementary feeding experiment subsequently done by Dr Wilson's team refutes this hypothesis (Wilson et al. 1998).
55Wilson et al. (1998).
56This was identified as the probable key determinant of extinction probability in a Population Viability Analysis (PVA) done in 1993 (Seal et al. 1993). I contacted Dr Ron Moorhouse, DoC's science & research scientist studying South Island Kaka (31 August 1998) to solicit his opinion of the key threat to the bird. He holds the view that predation of adult female kaka is indeed the key threat and has suppressed the population well below the level where nest hole availability has any influence on abundance of kaka. Dr Wilson also mentioned that an updated PVA analysis has recently been prepared that reconfirmed the overwhelming importance of predation of adult females in depressing kaka numbers.
57 Elliott et al. (1996a).
58Elliott et al (1996b).
59Elliott et al. (1996a).
60Ecologists call them 'K-selected' for this reason. Reviews of extinctions (Lovegrove 1992) and mathematical models have repeatedly shown that killing of adults is the death knell for endemic species (Seal et al. 1993, Hamilton & Moller 1995). Predation of adults eats into the "capital" of the biological population whereas predation of eggs and chicks only eats away at the annual "interest".


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Rifleman are thought to have declined in TWC forests61. I consider the evidence for this decline to be statistically weak62, as is also stressed by R. Buckingham63. Nevertheless declines in rifleman have been noted elsewhere in New Zealand, notably on mainland Stewart Island, and in the Granville State Forest, the latter covered by this proposal64. Rifleman use very small holes which are super-abundant. Any putative declines are most likely to be driven by predation or competition for insect foods with vespulid wasps, but this is speculation.
Go to index.

3.4         Kiwi
Great spotted Kiwi are present on some parts of the TWC estate65. Like all kiwi species on the mainland they are considered threatened, though Dr J. A. McLennan, who studied the great spotted kiwi for several years, considers them to be the most secure of all the mainland populations66. A recent survey of the high altitude ('subalpine') Saxon (Heaphy area) population showed no declines in the population after 10 years since Dr McLennan's initial baseline study there. However there have been no repeated surveys of the lowland great spotted kiwi populations to gauge whether they are stable or declining. Dr McLennan suspects the latter to be more likely and as a rule of thumb suggests that kiwi are holding their own in areas above 4.5 m of annual rainfall (the high altitude and/or rainfall seems to represent a refugia, probably from predator populations). Earlier more widespread distribution within the lower altitude dry beech forest has now disappeared. Dr McLennan cites the low ratio of juvenile to adult kiwi recovered by trained research dogs as evidence of predation67. Accordingly we can infer that kiwi on TWC land are limited mainly by predators. Predation is listed in DoC's Kiwi Recovery Plan68 as the

61 Buckingham (1999).
62Two points in time are insufficient to prove a trend. The studies compared were in different places and formal statistical testing is not provided. It is valid to draw preliminary patterns from dispirit studies but their statistical power is usually (definitely in this case) limited.
63Buckingham (1999).
64Buckingham & Nilsson (1998)
65See Rhys Buckingham's evidence for this consent application.
66Dr J.A. MacLennan, pers. comm. December 1999.
67Juvenile Great spotted kiwi constituted 3-4% of the catch, about the proportion found in north island brown kiwi before predator controls were applied (McLennan et al. 1996). Now that predators (especially stoats) are controlled the proportion of juveniles is 30 40% for North Island brown kiwis, about the same as occurs for little spotted kiwi on Kapiti island where no predators exist. Mathematical modelling also suggests that 30- 40 % juveniles is expected if predation by introduced mammals were eliminated.
68 Butler & McLennan (1991).


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primary threat to be mitigated. The great spotted kiwi studied by Dr McLennan bred every year so there was no evidence of habitat quality limitations. In the absence of other information and the expected impacts of predators, it is safe to assume the same lack of habitat limits occur for great spotted kiwi on TWC land.

Dogs are an occasional threat to kiwi and relatively easy to manage69. Proposed policies will ban dogs from all kiwi areas.

There is anecdotal evidence that cyanide paste used by possum harvesters occasionally kills kiwi. Small residues of brodifacoum have been found in North Island brown kiwi, but there is no evidence of direct poisoning by brodifacoum70. Kiwi survival has now been monitored through several aerial 1080 poison drops without registering kiwi mortality. Gin trapping by possum hunters kills some adults71. Survivors are often missing claws and around 7% of the Great spotted kiwi adults caught by Dr McLennan carried this sign, even though the intensity of possum hunting had declined a decade before his study.

The proposal already plans to ban dogs from kiwi areas but I suggest that the above risks will be further avoided or mitigated by one or more of the following additional strategies:72

  1. ban possum harvest from kiwi areas;
  2. insist that victor traps are used instead of gin traps;
  3. insist that traps and poison pastes are set up "ramps" at least above 35 cm and for preference above 70 cm, to eliminate kiwi (and Weka) by-catch;
  4. restrict harvesting during the kiwi breeding season (late winter to early summer) in kiwi areas.

Great spotted kiwi are shyer than the other kiwi species73. They roost above ground, commonly in raised root buttresses. They are prone to bolt when disturbed and so are very likely to flee

69Taborsky (1988) records a mass killing of as many as 500 brown kiwi in Waitangi State Forest, Bay of Islands by a rogue dog.
70Robertson et al (1999).
71See McLennan (1987).
72Choice of optimum strategy should be dictated by practicalities of enforcement once the designated areas are precisely identified.
73Dr. J.A. McLennan pers. comm..


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from the vicinity of harvesting gangs and so are not in danger of being killed. Direct impact of logging operations will probably be limited to occasional disturbance of nesting and potential loss of the current year's egg or chick. This is most unlikely to impact on the population's viability since the adults are long-lived 74.
Go to index.

3.5        Other bird species
Kereru gains its threatened status mainly from declines in abundance in the top half of the North Island 75. There is no suggestion that their numbers are low enough to make them regionally threatened in Westland. Kereru suffer intense predation on the mainland and reach much higher abundance on predator-free offshore islands. Accordingly, predation is likely to be holding numbers well below the habitat's carrying capacity. The proposal involved such slight habitat modification that the prospect of any impact on kereru is an extremely remote possibility unless abundance of rimu (an important food 76) is significantly reduced. Kereru breeding success responds rapidly to predator control so prospects for increase populations from the proposed predator control 77 programme are good. This could be particularly beneficial for wider biodiversity if their hypothesised critical role in seed dispersal is correct78.

Western Weka thrive in highly modified habitats. They are very much more adaptable to habitat change than kiwi. Predation has been a particular problem in attempts to restore North Island weka. The precautions taken to protect kiwi from predation are likely to also protect weka.

New Zealand falcon are naturally rare. Any scenario that predicts that the current proposal would in some way harm them would be entirely speculative. The ecological needs and population trends of this species are not well understood.

74Annual survival is around 0.92; Dr J McLennan, pers. comm.
75Clout et al. (1995); Pearce et al. (1993); James & Clout (1999).
76O'Donnell & Dilks (1987).
77James and Clout (1999).
78"Bush needs Kereru just as Kereru needs bush".

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Similarly kea are most unlikely to be affected in any way by the proposal. Rata and dead trees are potentially important food sources for these birds79, but are unlikely to be impacted by the proposal.

A localised population of blue ducks occurs in one part of the estate. Since they are closely associated with streams which are very unlikely to be altered80, there seems little chance that the proposal will impact on them.
Go to index.

3.6          Bats
Recent work81 has highlighted the need for a change of emphasis to increasing concern for South Island long-tailed bats as well as short-tailed bats. Formerly it was the short-tailed bats that were considered most endangered and long-tail bats were considered relatively common. More research of both species is urgently needed to see if the findings in the Eglinton Valley are representative of ecological factors impacting on bats elsewhere. The relative importance of long-tailed bat populations on TWC land compared to surrounding DoC land, or populations elsewhere in South Island, has not been demonstrated nor measured82.

Threats to birds are potentially different from those for bats. Very important in this regard is the lack of detailed information one way or the other about the importance of predation on bat numbers. The sparseness and apparent elimination of long-tailed bats from much of the TWC estate, even where no habitat modification has occurred, certainly points to some non-habitat related threat. Predation by introduced mammals is the most likely explanation, but this is speculation. DoC's bat recovery programme83 lists predation by rats, stoats and feral cats as a threat to bats. If they are not vulnerable to predation their populations may be much closer to the carrying capacity set by food availability or roost hole availability than expected for the bird species. Competition for insect prey with prolifically abundant introduced social wasps is potentially very important in honeydew beech forest areas84.

79O'Donnell & Dilks (1987).
80See Dr Allibone's evidence to this hearing.
81 O'Donnell (1999).
82 Unless unpublished accounts of such a demonstration exist.
83 Molloy (1995).
84See Moller & Tilley (1989), Thomas et al. (1989; 1990), Harris (1991) and Moller (1996b) for reviews; and Barr et al (1996) and Toft & Rees (1998) for experimental evidence.


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Bats go into torpor for some months of the year and so can not fly away if their roost tree was felled. O'Donnell85 records up to 123 bats roosting in one tree at a time. A high proportion of a local social group might then be killed if a key roost tree is felled in winter. However the proposal will not add to this risk because the harvesting replaces natural tree fall (mortality is subsumed because leaning and defoliated trees are selected). There is even some prospect that felling gangs will detect bats in the hollow trees just felled (their contracts stipulate that they must cut up such trees into short lengths to accelerate decomposition) and could be required to report them and where possible mount a "bat rescue" attempt86.

A population of long-tailed bats in the Eglinton Valley had at least 3 separate "cryptic" social groups that restricted their roosting to a much smaller area within a very large range87. Replicate studies are needed to determine if this is a general pattern for short-tailed bat populations. Large areas of that range may have had no roosting by other social groups, or all might have been used. There is no certainty that the bats could (or could not) move or extend their areas to include new holes nearby. Most importantly, the proposal strives to maintain a large number of holes by various strategies. Had historical coupe clear-felling been proposed, then a risk of destroying or seriously disrupting the roosting area would exist, but this is not proposed88. The current proposal represents a significant start towards assessing and potentially mitigating any putative impacts on bats. A formalised model of tree hole availability and the impacts of logging on it will objectively measure these risks long before any putative changes are imposed on the system89. The model can also test various mitigation measures, especially ones involving tree selection criteria.

85O'Donnell PhD thesis (1999).
86Such efforts are in their infancy in New Zealand but are well practised in the UK. There is no guarantee that they will succeed here but I urge that they be tried. It represents a potential way that the harvesting can reduce natural mortality of torpid roosting bats that would proceed anyway.
87Other social groups may have been present (Colin O'Donnell, in litt. 5 October 1998). Bats ranged over 3.33 10.85 km of the Eglington Valley but roosting areas were ca 0.92 2.86 km across.
88TWC might still consider it prudent to mount a study to identify roosting areas in their forests, but this is a large task (a minimum of two years work from a dedicated and experienced team) and in the end it will not prove one way or the other what the putative logging impacts might be. Identification of roosting areas would require radio tracking and there is no practical other way of identifying the areas. Very few roosts leave external signs of their presence.
89A model commissioned by TWC from Ecosystems Consultants Ltd. is in the preliminary stages of preparation.

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Short-tailed bats roost hole requirements will probably be different from those of long-tailed bats90. However, this evidence is very distinct from any expectation that such holes will be in limited supply, either before or after logging, or in the presence of both bats. There has not yet been an analysis of DoC's wider survey data for both bat species to test whether there are fewer or more bats in heavily cut over or coupe logged sites.

Long-tailed bats in the Eglinton Valley shifted roosts regularly, often at almost daily intervals. This behaviour is markedly different from most other overseas bats studied91, perhaps in part because tree cavity dwelling bats have received little study until the New Zealand effort. The crucial issue for our present risk analysis is whether or not they need to shift so often amongst such a large number of different holes or do they just prefer to do so. Does the continuous mixing reflect ecological or behavioural needs, or simply preference? It may just reflect a superabundance of holes available92. It is not known for sure what effect reduction in number of holes in the roosting zone might have on the bats and whether there the overall area of the roosting zone will simply expand. It was clear from the Eglinton Valley studies that vast areas with abundant tree holes existed within the large foraging range of the social groups.

Twenty-two percent of bat roosts in the Eglinton Valley were in standing dead trees. These were favoured roosting sites. TWC do not propose to remove the largest live trees or standing dead trees or spars93. These standing dead trees will be left in situ, therefore the number of holes present in large standing dead trees should not be greatly affected at TWC sites (e.g. Maruia).

The ultimate safeguard for bat impacts rests on rigorous population monitoring and the adaptive management framework in this proposal. This only allows retrospective assessment of impacts but sensible and extensive measures have been planned by TWC to ensure ongoing abundance of roost sites.

90O'Donnell et al. 1999 demonstrates that they use larger diameter stems than do long-tailed bats.
91Especially during the breeding season (Dr. J.A. McLennan, pers. comm.).
92It may be that the bats move regularly so that they can gain information about one another for social organisation. If this hypothesis is true, then movement may be necessitated simply because a superabundance of holes exists, forcing the bats to shift more often to stay in contact.
93These spars are also important food and sheltering places for lizards (Whitaker 1997; 1999)


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I urge that consideration be given to long-term repeated surveys of bat abundance in the sustainable use areas, including:

  • retention of dead spars
  • retention of large trees
  • subsumation of natural mortality ('gap-make' trees would fall soon anyway so risk to torpid bats from trees falling is no greater than would occur anyway).

Go to index.

3.7        Other fauna
Many of New Zealand's native freshwater fish species would be unaffected by the proposed felling regimes94. There is a possibility that TWC forests are home to several endangered and/or threatened fish species including endangered kokopu species, the brown mudfish and the lamprey. Threats from starvation by the loss of terrestrial food resources caused by tree removal are unlikely. Many of New Zealand native fish are opportunistic feeders and if the abundance of one prey item declines alternative food species will be used. Loss of shade cover caused by tree removal is not important for many New Zealand species, while, riparian margins of 20 m would provide sufficient shading for those species such as Galaxias postvectis, G. fasciatus and G. argenteus common in forested streams. The proposal adequately addresses the major concerns of sediment inputs. This proposal could also provide opportunities for habitat enhancement such as placement of slash within streams to provide cover and the placement of appropriate culverts to ensure introduced species are kept restricted in their range while climbing native species (e.g. eels) have passage upstream. Generally, while there is need for a more comprehensive survey of waterways covered, the proposal presents a low risk to indigenous freshwater species and recreational fishing.

Ten to eleven species (5 geckos, 5-6 skinks) are recognised from north Westland and Buller region95. Only two species (the 'West Coast' forest gecko and the 'West Coast' green gecko) are confirmed to be present in TWC forests. The gecko species (Naultinus tuberculatus, Hoplodactylus aff granulatus, H. maculatus) are not regarded as seriously threatened or at risk and are widespread in distribution. Presently there are no known populations of skinks in the

94NIWA Client Report TIM00201 December 1999.
95Whitaker (1999).


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Inangahua Working Circle and only scattered records of skink species (Oligosoma infrapunctatum, O. nigriplantare polychroma, O. aff nigriplantare 'Grey Valley" and O. sp. 'Denniston') have been recorded in North Westland. The harvesting regime proposed by TWC should not result in any changes to forest structure or composition that would significantly affect lizard habitat, therefore direct ecological impacts are expected to be negligible96. However, lizard populations could conceivably be affected by indirect ecological interactions97 if harvesting resulting in changes to ecosystem health and stability98. Whitaker (1999) and Buckingham (evidence for this consent hearing) are concerned that possible increased competition and predation pressure from introduced species (such as wasps and mammalian predators) could not be predicted. I can not see how this could occur if harvesters are simply subsuming natural gap formation. The size of gaps and frequency of gap formation should not be greatly different from natural sizes and rates. The canopy would remain intact. It therefore seems most unlikely that changes in predator/prey interactions would occur. Whitaker (1999) considers that mitigative measures are not required for lizards with the proposed harvesting regime but environmental monitoring is necessary to detect changes to the lizard fauna.









96Whitaker (1999).
97Indirect ecological interaction: a perturbation in an ecosystem causing a ripple effect that brings about changes in the birth rate, growth rate or death rate of species down the food web.
98Whitaker (1999).

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4.         Restoration through predator control

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4.1          Technological advances create opportunity for restoration

Various methods of direct and indirect poisoning have killed large proportions of tagged predator populations in New Zealand forests99, so a growing suite of effective control strategies are becoming available to conservation managers. However, large proportions of native passerines are sometimes poisoned when poison baits are applied and exposed on the ground100 and few other species have been adequately monitored or long-term studies assessing the overall population impact completed. Risks of poisoning native wildlife can be reduced. Risks of poisoning robins were almost entirely eliminated when poison was contained in bait stations101, and sustained large-scale control of predators (by deploying poison either aerial or in bait, along with trapping) has resulted in the successful recovery of threatened populations such as kokako102. Extensive research is required before rigorous assessment of the costs and benefits to the native wildlife communities and optimise methods of the predator control strategies can be found. Nevertheless, a positive outcome is very likely.

This proposal will add conservation value to forests by controlling introduced pests as a matter of routine forest stewardship. TWC research has striven to identify a cost-effective method that can be derived by staff on routine visits to forests for their other forestry duties. The proposed method of placing control stations (containing poisons) along the roads improves the cost-effectiveness of control programmes while still remaining very effective at killing predators103. It will provide safe and cheap protection of native wildlife over extensive areas of the TWC forestry estate. Research into non-target impacts of these poisoning operations is first being completed before extension and routine application of the method is considered sufficiently safe.

98Alterio et al. (1997); Brown et al. (1998), Alterio & Moller (1998); Alterio (in press); Alterio & Moller (in press); Dilks & Lawerence, (submitted);
99Gillies & Pierce (1999); Murphy, et al. (1999).
100Brown (1997); Powlesland, et al. (1999).
101Brown (1997).
102Innes, et al. (1999).
103Alterio (in press); Alterio and Moller (in press).


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Until the risks are measured it is difficult to prescribe detailed methods or the scale of control interventions that will be possible.

The secondary poisoning approach researched by TWC generated several subsequent investigations by University and DoC teams in the last few years. This is an example of the way research funded by a proposal like this can bring lasting benefits to other conservation endeavours throughout New Zealand. If this proposal is approved, more such research and practical benefits are likely to accrue for conservation throughout New Zealand. The Foundation for Research, Science and Technology is attempting to foster business investment of this sort through the new Foresight programme and NERF. The TWC effort proposed here is therefore in line with New Zealand government science policy.

TWC now seek the opportunity to capture the benefits from their research to enhance bird (and potentially bat104) numbers in their on forests. In my opinion the prospects for success are high. Valuable restoration of both common and threatened species is likely.
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4.2        Goal of enhancing biodiversity
New Zealand society wants to maintain representative ecological communities on the mainland, partly to further protect biodiversity but also so people can all freely interact with and enjoy the species that make New Zealand forests part of our national identity. TWC is dedicated to helping perfect and include techniques for pest and predator control aimed at maintaining or even improving our indigenous forest communities. This is a key reason for my overall support for the proposal and my overall conclusion that it should be approved.

The techniques to be applied are derived from several commissioned research projects to find the most effective methods to kill predators, minimise risks to non-target species and design optimum intervention strategies. The overall strategy and planning is outlined in their restoration strategy105 which involves the following general approaches:

  • trials of "multi-predator" control methods using secondary poisoning methods,

104though firm evidence for a role of predation in limiting bat numbers is unvailable, predation is listed in DoC's bat recovery plan as a likely threat (see Section 4.5).
105See Brown et al (1996) or www: timberlands.com (sic) (http://www.timberlands.co.nz was intended, Ed.. )for details.


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  • an initial phase (2-3 years) of research to measure efficacy of killing target predators and risks to non target species. Research is now swinging to the latter emphasis.
  • experimental management trials on 2-3 intermediate sized areas once risks to non-targets are considered minimal,
  • pulsing of poisons to maintain efficacy and minimise poison deployment,
            -     research projects started to learn how key parts of the ecological systems responds to the proposed management,

            -     joint funding with government science providers,

            -     the restoration project should be overseen by a steering committee made up of all stakeholders (Foresters, DoC, Conservation NGOs, research agencies etc),

            -     initial independent audit by conservation scientists after 3 years; and the restoration project be trial for 8 years at least before its overall success is evaluated.

The overall Forest Community Restoration Project aims106:



To establish and implement methods to protect and enhance
biodiversity within honeydew beech forests of northern Westland
by minimising the risk of extinction and increasing densities and diversity
of indigenous species.


This long-term goal is realisable by triggering the increase in abundance of extant species and extending the distribution of species now persisting within small areas of the TWC estate through control of introduced mammals, and eventually re-introduction of species previously present which now only exist on the offshore islands or in refuges on the mainland. Conservation of biodiversity includes retention of original ecological processes within the community and ecosystem, not just conservation of the species themselves. Increased abundance of some species may be essential to reinstate natural processes with long-term consequences. For example, enhancement of kereru numbers may trigger increased seed dispersal and reduction of wasps (Vespula spp.) may restore litter invertebrates to re-instate former rates of forest litter

106See Brown, et al (1996).


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breakdown; and elimination of browsing pressure could reinstate former rates and directions of plant succession.
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4.3        Practicalities: the enormous magnitude of the challenge to be natural gardeners in perpetuity
Restoration must proceed by expensive and intermittent intervention to kill the introduced predators, browsers and competitors. The key to success is to reframe the traditional role of the conservation manager as solely a passive protectionist in favour of a role as a gardener of near natural systems who constantly weeds out the alien species so that native species can flourish. This will demand innovation to develop new techniques and long-term commitment to constantly intervene because introduced pests are common, widespread and difficult to control over large areas of forest. They breed quickly and disperse widely, so numbers quickly resurge following localised control operations. The current proposal is an excellent example of the necessary change in philosophy that is expected to capture new gains for conservation of biodiversity.
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4.4        Scale of TWC Proposed Restoration Efforts
TWC plans to devote between 5 and 10% of annual net revenue derived from sustainable management of beech forests on research, pest control and monitoring strategies of pest and predator species107. Possum numbers are to be maintained at medium to low levels throughout its forests. In TWC managed areas identified as "Integrated Management Landscapes" by the Department of Conservation, TWC will work co-operatively with the Department to achieve mutually agreed targets for pest control. Population monitoring of possums, wasps and predators to follow the success of control operations will be undertaken in eastern Paparoas and Station Creek in the Maruia Valley using annual trap-catch surveys, spotlight counts and tracking tunnels108. Some possum control strategies are known to control rats, mice and stoats and these strategies will be used until other multi-predator control systems are developed. TWC intends investing in predator control research, specifically secondary poisoning109. Predator usage of undisturbed, natural and harvest gaps will also be monitored in a one-off study110.

107Section of RMA Consent Application.
108Section 9.1.2. of Application.
109Section of Application.
110Section 9.1.3. of Application.


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Preliminary plans are to mount at least two and maybe three "mainland island" restoration areas as a first step111 before extending it further across the TWC estate. Considering that DoC nationally is currently only mounting 6 such initiatives112 the proposed scale of intervention by TWC is admirable.

The proposed new predator control in sustainably beech use areas will parallel that mounted by TWC at Okarito and Saltwater forests where sustainable forestry principles have been applied for the last decade. As yet, there is no formal report of the action and outcome but I. James113 reports that possum control has been undertaken since 1993 at Okarito. TWC has concentrated their effort in the southern 50% of the Okarito forest. In 1996, DoC did an aerial 1080 control operation in the northern 50% of the forest. TWC possum control operations until 1999 used 1080 jam "Feratox" and cyanide. This year "Feratox" has been placed in bait stations with the disposal of possum carcasses. "Talon" (300g) has been placed in bait stations in spring and early summer. Spotlight counts have occurred before and after possum control operations. Rat and mice interference has been observed at approximately 50% of "Talon" bait stations. Stoats have been controlled by secondary poisoning of their prey (rodents and possums). Stoat numbers have been monitored by DoC using tracking tunnels in the winter of 1999. Monitoring of stoat numbers is to be repeated by TWC this coming winter. Ian James114 reports that bird numbers are no different or higher on the TWC land now as compared to nearby DoC land where no logging has occurred but predators have been controlled. Formal repeating of these results would be helpful to build confidence in the proposal. This track record contributes to my confidence that real and practical commitment to predator and browser control will ensue if this proposal is approved.

In my opinion the main priorities to maximise conservation benefits are to:

  • control stoats and rats, believed to be the most urgent and important threat

111Brown et al. (1996).
112 DoC (1998).
113pers. comm.
114pers. comm.


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  • instigate possum control after a short period of predator removals only115
  • mount wasp control only after control methods have been perfected and only if the value of such effort has been demonstrated at DoC's St. Arnaud honeydew beech forest restoration forest project116
  • concentrate restoration in largely unmodified areas (wildlife abundance will build to higher levels in such forests after sustained predator control)
  • prioritise restoration in areas adjacent to DoC areas that have high conservation value (so DoC land receives the maximum chance of benefit from TWC efforts)
  • co-ordinate restoration efforts with those of DoC (to foster co-management and team building and maximise regional impact)

I consider the above to be a worthwhile and practical approach that nicely complements efforts of DoC outside Westland. This maximises learning and benefits for conservation everywhere while adding tangible conservation value to the TWC estate.











115These interventions are staged to partition the effects of predators from possums, this is another example of an adaptive management approach.
116 Introduced social wasps have enormous impacts on the beech forest system (Moller & Tilley 1989, Thomas et al. 1990, Harris 1991, Moller et al. 1991, Barr et al. 1996, Toft & Rees 1997) but their control is still extra-ordinarily expensive and impracticable in many situations Beggs et al. (1998). Effective biological control of wasps is underway but mathematical modelling predicts that the current attempt will probably be only marginally effective (Barlow et al. 1996). The proposal wisely plans to concentrate initial efforts on mammalian predator controls where a cost effective return for native biodiversity is more assured. TWC will review the attempted long-term control of wasps in DoC's "mainland island" experiment at St Arnaud before deciding their own response to wasps in their forests.

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5.        Monitoring

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5.1        Monitoring and adaptive management: a key for added safety for biodiversity
Sound wildlife management demands well designed monitoring. Provided sound monitoring is coupled with learning and adjustment of subsequent management, all of wildlife management can be viewed as scientific experimentation117. I view the commitment outlined in the proposal to sound monitoring to be exemplary.

Monitoring birds imposes difficulty due to high cost to achieve reliable data. Instead a recommended programme to establish the risks to fauna will be a focus on the monitoring of what are recognised as key drivers to their maintenance, large old trees and pest numbers.

The former is covered in terms of the monitoring target being set in relation to maintaining a similar forest structure and density, while the latter will be instigated as part of pest management strategies and will demonstrate the effectiveness and long term trends in relation to key pests.

Direct bird monitoring will apply only in terms of establishing trends in representative areas on the basis that if a trend prevails in representative areas in a forest then subject to the same management elsewhere a similar trend should prevail. Therefore all trends must be assessed relative to nearby representative areas that are not being logged (most probably on DoC land).

I suggest that initially two sorts of areas should be compared using a Before: After/Control: Impact ('BACI') design:116
  1. Harvested areas with predator control, and
  2. Unharvested areas with predator control, but,
where five years pre-treatment monitoring and five years post-treatment is done on (i).

117Romsburg (1981); McNab (1983); Sinclair (1991).
118Manly & Brown (1999).

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If after 10 years:

  1. Indigenous fauna in (i) is lowered or increased less rapidly after harvesting commences there are grounds for concern that some unexpected impacts on habitats have occurred from harvesting. If this arises by year 10 an intensified scale of monitoring should be mounted; or
  2. If change in indigenous fauna is the same or elevated in (i) after harvesting compared to area (ii) there is either no effect of harvest or a "net conservation benefit" is accruing in some way. Ongoing low intensity monitoring is then all that would be required.

Adverse trends, if they eventuate, would need further investigation. However the primary expectation, based around the well-established rapid and positive response that arises for birds from effective pest control, is that there will be increased fauna abundance rather than a reduction.

As animal abundance varies greatly in space, there is a statistical challenge to get adequate replication for the experimental approach119. The "BACI" approach may give increased statistical power by having the before and after comparison on the same areas. A staircase replication120 could add confidence if the expected extension of predator controls into wider and wider areas121 eventuates.

Critical habitat features, like tree holes and hollows are thought to be potentially important for hole-nesting birds and bats. For this reason TWC have commissioned a mathematical modelling exercise to identify the most important parameters to measure to allow confident prediction of the density of tree holes retained in the forest.

A tree-cavity model under construction for TWC can most rigorously calculate the risk of tree felling killing torpid bats. This model will incorporate the bats' selectivity, the tree size selections used, and the months of the year in which felling is proposed.




119Moller & Raffaelli (1997); Rafaelli & Moller (in press).
120Walters & Holling (1999).
121 Brown et al. (1996).

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5.2        Use of indicator or focal species to measure harvesting impacts
In the United States the Forest Service is required to maintain viable population levels of native wildlife populations on public land and to prepare forest plans that include periodic evaluation and monitoring of management objectives122. Given the great diversity of species, monitoring of all the biological components of managed ecosystems is impossible. There is no easy method to decide how management can consider the full complement of species that occur in forest systems. Based solely on pragmatic considerations, management of biological systems may be simplified and made more cost-effective by considering only a small group of indicator species as surrogates for the complete system123. The concept of an 'indicator species', is one of a species that is associated highly with a specific habitat type and can be monitored to determine the possible reaction of the species to changes in this habitat type. Moreover, if this species is associated positively with a number of other species, then one may assume that habitat needs of the other species are also being met. Usually more than one indicator species must be selected because a single species can only serve as an ecological indicator for a narrow range of conditions within a habitat type.

Use of indicator species124 to guide forest management in the United States and New Zealand125 has been controversial. The general consensus has become that no species is likely to be a wholly satisfactory indicator of the viability of other species because of important differences in dynamics of individual species. However, this does not say that some species do not provide an integrated indication of the status of some portion of the forest system. The United States Forest Service has proposed changing to a 'focal species' concept which would allow a variety of approaches to selecting species to monitor and assess for viability126. The key characteristic of a focal species is that its status and time trend provide insights to the integrity of the larger ecological system.


123U.S. Laws, National Forest Management Act (1976), Bull et al. (1986), Morrison et al. (1986).
124Szaro & Balda (1982), Landres et al. (198), USDA Strategic Plan.
125 Indicator species as used by the USFS may be plant or animal species and in some cases may be used to refer to groups of species. Hutcheson et al. (1999).
126 The term focal includes several existing categories of species used to assess ecological integrity including; indicator species, keystone species, ecological engineers, umbrella species, link species and species of special concern (US Forest Service Manual).

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I believe it would be unwise to impose a rigid monitoring protocol on the consent before more focused research on ecologically important parameters has been completed to ensure that the focal species will serve their proposed function and that scientifically defensible counting regimes can be devised. About two years would be needed to do pilot studies, measure statistical variance in counting methods and design the most cost-effective yet scientifically defensible monitoring method.

Selection of the monitoring method and protocol details127 to monitor abundance will depend on:

---             repeatability of method by different observers

---             variability of counts (this affects the statistical power of the population index)

---             natural variations in conspicuousness and other factors affecting the relative counting technique128

---             natural fluctuation in population levels (interannual variability determines how many years must be monitored)

---             the size of difference in population trend proposed as significant129

---             cost and practicality

Go to index.
5.3        Useful focal species for TWC to monitor
Yellow-crowned parakeets would probably be useful as indicators of the well-being of hole nesting birds; bellbirds or tui for honeyeaters and impacts on fruit, nectar and insect foods130; and robins for ground insect feeders. Rifleman are potentially useful too, partly because they may be declining131 and also because they are relatively easy to monitor compared to yellow-crowned parakeets. Yellow-crowned parakeets fluctuate with beech seeding (it triggers prolific breeding) so it is possible that riflemen are a more stable (and therefore more tractable) species to monitor for tree hole availability.


127 important details include number of counts, their spatial and temporal distribution (within and between years).
128optimum time for counts will be that when natural variability is low.
129this dictates the minimum size of difference in trend that must be detected with certainty (statistical power).
130 Bellbirds are omnivorous in south island beech forests (Moller & Butz-Huryn 1996).
131See R. Buckingham's evidence for this hearing.


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Yellow-crowned parakeets are also potentially good 'indicator' species for forest health in relation to predator impacts and logging practices 132. These birds are essentially a beech forest species that use large diameter trees both for feeding and for nest and roost sites 133. As hole nesters, yellow-crowned parakeets could be susceptible to severe reduction of suitable nest/roost cavities should unexpected reductions occur because of beech forests logging practices 134. Yellow-crowned parakeets were formerly common throughout South Island forests 135, today though they remain widespread and in some cases locally common 136. Some ecologists suggest that they are rare or absent in heavily logged forests 137 but severe modification is not planned by this proposal. Also this rarity or absence does not always seem to be the case, with yellow-crowned parakeets still present in relatively high numbers in several modified beech forests 138, including those owned by TWC.
The relatively high abundance of yellow-crowned parakeets in beech forest would make indexing of their abundance much more logistically feasible than for the rarer and more endangered species like kaka 139. The continuing threats facing yellow-crowned parakeets and other endemic species in New Zealand forests such as tree hole loss and introduced predators makes them ideal as an "indicator" of the health of the forest wildlife community as well as for other hole nesting species.





132O'Donnell and Dilks (1986).
133R.H. Taylor telephone conversation with Dr. W. Hamilton 28/11/99.
134O'Donnell and Dilks (1986); Elliott et al. (1996b).
135Buller (1868), Reischek (1884).
136O'Donnell and Dilks (1986); Buckingham (1998).
137O'Donnell (1991).
138 Buckingham (1998).
139 O'Donnell (1996); and telephone conversations with Dr W Hamilton and R. Buckingham (28/11/99); R. Taylor (28/11/99); Terry Green (29/11/99).


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6.        Wider conservation management implications

In this section I review some of these wider implications of the current proposal and relate them to current international trends in conservation and natural resource use.
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6.1        Audit and public scrutiny: the key to public confidence in the outcome
A continual plea of conservationists is that that our plants and animals belong to us all. Private land ownership is seen as potentially threatening to biodiversity because it is portrayed as a warrant for landowners to do what they like out of sight on their own land. International evidence is mounting140 that the reverse may be true in some circumstances – that private ownership141 and control can become all the more an incentive to looking after the plants and animals in private care provided that property rights are well defined and economic interests are secure. Two issues are embodied here: scrutiny and problem ownership. This proposal sets regular, independent and open audits in place so that the general public can learn what is going on. The managers have acquired ISO/14001 Environmental management certification and seek other forms of independent ecological audit. The system of tagging timber extracted and the stump from which it was cut along with GPS mapping gives the ultimate safeguard that independent auditors can check whether protocols are being followed.

These are valuable principles that should be encouraged for conservation of biodiversity by all natural resource users.

All these factors provide the tools to give public confidence142 and Council capacity to ensure appropriate outcomes.




140Ackroyd & Hide (1991); Field (1994).
141Technically TWC land is still publicly owned land, but the perception nurtured by preservationist antagonists of this plan is that TWC can not be trusted to follow the protocols and that public scrutiny will not be possible.
142The public debate surrounding theis proposal (eg Hagar & Burton 1999) is undoubtedly partly because of a history of unsustainable forestry in the past. Both foresters and conservationists have been challenged to "break their historical shackles" by accepting this proposal (Moller 1998a).

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6.2        Co-management: giving DoC a hand
The World Wide Fund for Nature (WWF) and International Union for Conservation of Nature (IUCN) have been working hard since the mid 1980s to encourage collaborative management143 throughout the world. These international Conservation NGOs realised that top-down imposition of preservation on local communities was often not as effective as a mass of local, smaller scale, "bottom-up" approaches to nature conservation. New Zealand lags the world in fostering effective "strong co-management"144, partly because of well-meaning but unreasonable and short-sighted opposition from preservation-oriented Conservation NGOs. The view continues to be promulgated that the only way to safeguard conservation is by publicly owned reservation administered by a central "top-down" agency like DoC. This takes away the incentive from other enterprises, or individuals to act in an environmentally responsible way. Co-management takes time and planning to establish, but in the end is a lasting, sustainable and effective method of looking after biodiversity. It is also a cheap method for taxpayers to achieve both conservation and economic aspirations.

In this application TWC is proposing to use some of the net revenue145 from a sustainable forest use to invest back into active conservation management, monitoring and research. It is a form of co-management that will marry biodiversity enhancement expenditure and risk management with profit earning. The co-management principle is embodied in the 'New Zealand Biodiversity Strategy' that is currently being formulated. That strategy tries to engender responsibility for conservation well beyond what DoC can achieve and this sets the tone for conservation in New Zealand in the 21
st century.






143Often shortened to "co-management".
144 See Borrini-Feyerabend (1996) for a discussion about the way strong co-management involves devolution of real decision making power and action to local communities; and Moller (1997, 1998c); Taiepa et al. (1997); Moller & Hamilton (1999); and Moller et al. (in press) for how New Zealand lags in applying the lessons learned overseas.
145Between 5% and 10%; Section of Consent Application.


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6.3        Conservation outside nature reserves: the crucial next challenge
A related issue to co-management is the urgent need to foster active management of conservation outside nature reserves. Part of the myth of asserting that conservation must proceed only by preservation is a damaging idea that somehow conservation is a process that occurs only within lines on a map surrounding a nature reserve. Ecological processes and forces flow over these artificial lines drawn by people146 . It can lead some resource users to believe that if we have a reserve somewhere else we can do what we like outside those reserves. The proposal is an excellent example of the total reversal of this principle. It sets out to do nothing that diminishes biodiversity outside the extensive existing matrix of nature reserves around the area proposed for use. This acts as a model for other prospective resource users and is something that New Zealand must foster. Several of New Zealand's threatened plants occur only outside existing nature reserves 147.
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6.4        Foresters as gamekeepers: adding conservation value to the foresters' estate by active management
The proposed control of introduced predators to restore populations of native wildlife (in the same way pioneered by the Department of Conservation) is part of a paradigm shift in New Zealand's conservation management as a whole towards a more active interventionist approach from a previously more passive preservation approach. Part of what Dr David Norton 148 called the "myth of reserves" 149is that all you need to do to safeguard conservation is to create the reserve. Effective widespread conservation on DoC land is effectively precluded by inadequate financial and people resources. Predator control is expensive and must be maintained in perpetuity, rather like a gardener continually weeds out the unwanted species to allow others to flourish. Commitment to definite plans is difficult before the exact methods and cost-effectiveness of predator controls has been measured, and before the scale of the beech forest use

146 This flow across TWC and DoC land boundaries makes the siting of this TWC proposal ideal. If some unexpected effect of logging ocurs in TWC land the surrounding matrix of reserves can buffer the effects so risks are minimised by having the TWC plan where it is proposed. On the other hand, if the expected net benefits to biodiversity accrue, these can flow onto the surrounding nearby DoC land where reserved land unprotected by predator control will then benefit.
147This is not an argument for disbanding nature reserves we need a diversity of approaches for conservation of biodiversity it is a plea to foster examples for wise use of natural resources outside nature reserves in the way proposed here.
148 An ecologist from the School of Forestry, University of Canterbury.
149 See Dr David Norton's (1998) review of reserves as conservation tools.

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and revenue are assured. Commitment to expending a percentage of revenue to predator control is therefore a logical and practical solution to the uncertainty.

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6.5        Thinking holistically: using an Ecosystem Management approach
The Ecosystem Management approach evident in this proposal is new for New Zealand but at the cutting edge of quests for ecologically sustainable resource use overseas150. New Zealand biodiversity will benefit from the general approach in other forestry proposals and agricultural land use practices.

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6.6        Commercial enterprise: an opportunity rather than a threat for conservation
It has been obvious from the public debate of the TWC beech proposal that there is mistrust amongst preservationists that big business concerns could deliver conservation safeguards or gains. Investment in an industry relying on extraction of natural resources was considered a threat to environmental protection by preservationists because they suppose there will always be a commercial benefit from rapid over-exploitation of the resource and then transferral of the investment and profits to a new extractive industry elsewhere151. TWC's mandate as a State Owned Enterprise will not allow this transferral of investment to other extractive industries. Apart from the areas set aside for additional nature reserves and scenic reserves, the available area is to be fully used by TWC for sustainable logging. There is no other resource for this enterprise to transfer its attentions to if it over-exploits the forest. This offers a large incentive for the company to maintain its rate of extraction within the ecological limits set by the productivity of the ecosystem to allow forestry in perpetuity. In this case the economic gain from forestry is in part directed back to enhance biodiversity values: a true win:win for conservation and economic interests.

A recent review152 identifies many ways in which economic models and approaches can enhance conservation outcomes in New Zealand. New Zealand can do better for its plants and animals in future by fostering models of business profits being directed to enhance rather than damage

150Grumbine (1994).
151This was called the "tragedy of the commons " by Harden (1986).
152Hartley (1997).

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biodiversity. I believe this proposal will act in this way and hasten healing of a damaging division between business and conservation interests.

Go to index.

6.7         Sustainability: the ethos of the RMA and key challenge for the 21
st century
IUCN and WWF have recognised that sustainable development is the fundamental challenge facing biodiversity in the 21
st century153. Preservation is an important, sometimes critical element of protection of biodiversity. New Zealand is the envy of the world in its extensive network of nature reserves, and no region within New Zealand is more provided by reserves than the West Coast. But this proposal can demonstrate that biodiversity can be protected, indeed enhanced, within the context of 'conservation through sustainable use'154. Rather than seeing conservation and use as alternatives demanding compromise, we need to learn and expect that each can co-exist and benefit from the other. Diversion of profits for active management to create net conservation gain, research and monitoring are obvious examples of benefits for conservation from this proposal. Retention of biodiversity for normal nutrient cycling, maintenance of intact forest cover to reduce erosion and wind-throw are examples of many ways that the long-term sustainability of low extraction forestry will be safeguarded by caring for biodiversity. The RMA's definition of "protection" of significant natural values does not demand preservation.

I therefore consider that this proposal is an overdue example that should force New Zealand society to understand that preservation and conservation are two separate things. Both need the other for maximum protection of biodiversity.




153See "Caring for the Earth, a Strategy for Sustainable Living", IUCN (1991).
154See Grigg & Hale (1995) for numerous case studies for the way conservation can be enhanced by investment and concern to ensure future use.

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Go to index.

6.8         Active Management, Reversibility and the Environmental Precautionary Principle
This proposal marks a paradigm shift for forestry and conservation alike155. All new initiatives must be a step into the unknown. If we never step into the unknown we will never innovate and find better ways to conserve biodiversity. There are ecological unknowns and potential risks from the proposed timber extraction, just as there are ecological risks to biodiversity from vesting the land in DoC to manage as a nature reserve. The same adaptive management approach proposed by TWC to circumvent uncertainty has been used by DoC to learn how best to restore North Island kokako populations156. Adaptive management is gaining momentum overseas to be the main tool to learn how to manage natural systems in forestry, fisheries, agriculture and conservation157. Its power could be evaluated for other New Zealand natural resource users if this proposal is given consent.

There are risks of non-use of natural resources, but these are often not considered in conservation debates158. The Environmental Precautionary Principle urges that unknowns are assumed to fall in the direction which best protects biodiversity. In this case uncertainty exists either way, so the principle can be followed only by using best professional practice to minimise risks and mitigate unwanted effects. The use of adaptive management and stringent monitoring are the keys to learning how the system will respond to management and to check best professional guesses about outcomes.

Best professional practice demands minimisation of risks by restricting the spatial and temporal scale of perturbations. This philosophy is embodied completely in the group-tree selection that underpins this proposal.

The other fundamental approach of conservation managers when faced with uncertainty about what to do is to ensure reversibility of actions. Of potential serious concern is the repeated demonstration by community ecologists that communities do not necessarily return to the same

155Several short articles in New Zealand Forestry November 1998 underscored the magnitude of this paradigm shift. I urge the Commissioners to read this series of cameos (Bigsby 1998, Moller 1998a, Perley 1998, Sage 1998, Salmon 1998) to sample the breadth of scientific and conservation opinion abroad on the TWC proposals.
156Innes et al. (1996, 1999).
157Walters & Holling (1990); Ludwig et al. (1993); Lancia et al. (1996); McLean & Lee (1996); Parma (1998); Dovers & Mobbs (no date).
158See Moller et al. (1997) for the way this misrepresented the RCD introduction debate.

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state after they have been perturbed159. In this proposal this risk is minimised by the fact that the proposed timber extraction is to be at very low intensity that mimics the small natural perturbations in both spatial and temporal scales. Species ratios are not altered. Size and age distributions will hardly be changed. Little extra roading is needed and what is there will be in stable valley bottoms. Roads cover minimal areas and will eventually overgrow160. By not "pushing" the system but "going where it goes naturally" the reversibility of the actions proposed is ensured and reversion from small changes should be rapid in ecological terms.

Major ecological disturbances (earthquakes, cyclones, floods) are natural events. Even though they are infrequent events in human terms they can be relatively frequent within the 'generation time' of a forest. Accordingly they can place a fundamental "stamp" on the structure of the forest that will be evident for centuries. Management proposed by TWC tracks these major natural forest restructuring events by ensuring its modifications are at a comparatively micro-scale.

Reversibility is thereby embedded in the philosophy of the management approach being taken in this proposal. This reduces long-term risks for biodiversity.









159 Begon et al. 1993; Moller & Raffaelli (1998), Rafaelli & Moller (in press).
160probably in about 50 years to seral scrub if left unused.

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Go to index.

7.        Conclusion: the TWC proposal will enhance rather
than threaten biodiversity

In consideration of the risks and management of risks in this proposal I believe that it exemplifies many of the key approaches already being fostered overseas to ensure conservation of biodiversity. This judgement stems from:

the proposal is very likely to be ecologically sustainable                                                                                          

most threatened species in TWC forests are held well below the carrying capacity set by habitat because of predation by introduced mammals and wasps

it is entirely possible that after sustained predator control for several years fauna may be restored to populations far above current levels

no significant habitat modification will occur through logging especially over the duration of consent applied for; this will ensure that logging is very unlikely to depress current populations of birds or bats from current levels;

nor will the habitat be modified by the proposal in ways that would reduce the populations of birds attainable after prolonged predator control;

application of the adaptive management approach will allow TWC to learn about unknowns in the system, and converge their management on a better and better outcomes for forestry and biodiversity.

perturbations to the system are on small spatial scales and short-term, so they pose minimal risks                                                                   

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the scheme represents a well-researched proposal to achieve "conservation through sustainable use"161. New Zealand desperately needs such models to add diversity to its well-established preservation based approach of supporting indigenous biota. The proposal represents such a model.

promulgation of the proposal will debunk a damaging myth believed by some (but not all162) conservation NGO's that the only way to achieve conservation of biodiversity is by non-use of natural resources (reservation). Responsible use does not mean destruction. Failure to expose this myth puts the future of New Zealand's indigenous biota at risk.

this proposal is an example of small-scale, local, bottom-up approaches to nurture biodiversity. Co-management is proving very successful overseas, but New Zealand lags well behind this international trend of implementing conservation in this way163.

research and management on beech forest and predator ecology, predator control and monitoring of biodiversity funded as part of this proposal will be of use to conservationists and DoC elsewhere in New Zealand164.

the TWC estate is surrounded by an extensive network of DoC reserves. This makes it an ideal place for New Zealand to mount such a first model of sustainable indigenous forestry because the surrounding ecological landscape can provide a buffer for any unintended and unwanted ecological impacts; if the intended net conservation benefits accrue from ecological community restoration through predator controls, recruits of threatened species generated within TWC forests could then "spill" into nearby DoC land. The surrounding reservation (DoC) and those reserves added by this proposal (TWC) makes the West Coast the safest place to learn sustainable forestry protocols "by doing" them165.

161 Grigg et al. (1995).
162 The Maruia Society (now called Ecologic) have been broadly supportive of the proposal (Salmon 1998) but have not featured greatly in the public exchanges.
163 Moller (1996), Taiepa et al. (1997), Moller (1998b).
164This has already happened from the predator research funded by TWC and done by Ecosystems Consultants. The research pioneered the use of secondary poisoning as a targeted means of killing stoats. Several similar research projects have been spurred by the initiative taken.
165 North Americans often refer to adaptive Management as "learning by doing" Walters & Holling (1990).

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independent and full scrutiny of TWC plans is proposed in a way that helps ensure best professional practice, and that the potential biodiversity gains will be accurately assessed.

high profile public debates of this emotive nature often fail to acknowledge the risk of doing nothing (i.e. in this case of not going ahead with the sustainable forestry scheme). DoC is underfunded and desperately needs help of responsible private interests like TWC to control pests within beech forests

any unwanted and unexpected ecological effects from the proposal are rapidly reversible                                                                                      

the overall ecological risks of proceeding with the proposal are very small and have been minimised by several practical protocols as demanded by best professional practice and the Environmental Precautionary Principle.

I therefore conclude that biodiversity has a lot to gain from approval of this proposal. I consider it visionary from a conservation biologist and conservation manager's perspective and more than meets the requirements on the RMA.

I believe that a decision to halt this proposal, for reasons having nothing to do with sustainability, will set New Zealand conservation back by several decades.

This proposal deserves the RMA Commissioners' support.






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Go to index.

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O'Donnell, C.F.J., Dilks P.J. 1986. Forest birds in South Westland. Status, distribution and habitat use. New Zealand Wildlife Service, Occasional Publication No 10. 179 pp.

O'Donnell, C.F.J., Dilks, P.J. 1987. Preliminary modelling of impacts of logging on forest birds in South Westland. Science & Research Internal Report 1. Department of Conservation, Wellington. 30 pp.

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O'Donnell, C.F.J., Dilks P.J. 1994. Foods and foraging of forest birds in temperate rainforest, South Westland, New Zealand. New Zealand Journal of Ecology 18: 87 - 107.

O'Donnell, C.F.J., Dilks, P.J., Elliott, G.P. 1996. Control of a stoat (Mustela erminea) population irruption to enhance mohua (yellowhead) (Mohua ochracephala) breeding success in New Zealand. New Zealand Journal of Zoology 23: 279 - 286.

O'Donnell, C.F., Christie, J., Corben, C., Sedgeley, J.A., Simpson, W. 1999. Rediscovery of short-tailed bats (Mystacina sp.) in Fiordland, New Zealand: preliminary observations of taxonomy, echolocation calls, population size, home range and habitat use. New Zealand Journal of Ecology 23: 21-30.

O'Donnell, C.F., Sedgeley, J.A. 1994. An automatic monitoring system for recording bat activity. Department of Conservation Technical Series No.5: 16 pp.

O'Donnell, C.F., Sedgeley, J.A. 1999. Use of roosts by the long-tailed bat, Chalinolobus tuberculatus, in temperate rainforest in New Zealand. Journal of Mammalogy 80: 913-923.

O'Donnell, C.F.J.; Rasch, G. 1991. Conservation of kaka in New Zealand. "A review of status, threats, priorities for research and implications for management". Department of Conservation Science and Research Internal Report No. 101.

Pierce, R.J.; Atkinson, R.; Smith, E. 1993. Changes in bird numbers in six Northland forests 1979-1993. Notornis 40: 285-293.

Paine, R.T. 1974. Intertidal community structure. Experimental studies on the relationship between a dominant predator and its principal predator. Oecologia 15: 93-120.

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Parma, A.A., NCEAS Working Group on Population Management. 1998. What can adaptive management do for our fish, forests, food and biodiversity? Integrative Biology 1: 16 - 26.

Perley, C. 1998. Assessing Timberland's sustainable beech management using concepts of ecosystem health and ecosystem management. New Zealand Forestry November. 3-7.

Powlesland, R.G., Knegtmans, J.J.W., Marshall, I.S.J. in press. Costs and benefits of aerial 1080 possum control operations using carrot baits to North Island robins (Petroca australis longipes), Pueora Forest Park. New Zealand Journal of Ecology 23: 149-159.

Raffaelli, D., Moller, H. (in press) Manipulative field experiments in animal ecology - do they promise more than they can deliver? Advances in Ecological Research

Ratz, H. 1997. Ecology, identification and control of introduced mammalian predators of Yellow-eyed Penguins (Megadyptes antipodes). PhD Thesis, University of Otago.

Reischek, A. 1884. Notes on New Zealand ornithology. Transactions of the New Zealand Institute 17: 187-198.

Robertson, H.A., Colbourne, R.M., Graham, P.J., Miller, P.J., Pierce, R.J. 1999. Survival of brown kiwi (Apteryx mantelli) exposed to brodifacoum poison in Northland, New Zealand. New Zealand Journal of Ecology 23: 225-231.

Romsburg, H.C. 1981. Wildlife Science: gaining reliable knowledge. Journal of Wildlife Management 45: 293 - 313.

Sinclair, A.R.E. 1991. Science and the practice of wildlife management. Journal of Wildlife Management 55: 767 -773.

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Soule, M.E. 1987. Viable Populations for Conservation. Cambridge: Cambridge University Press.

Salmon, G. 1998. Timberlands' beech project deserves to succeed. New Zealand Forestry: November issue, Pg 8.

Sage, E. 1998. Beech scheme - an ecological and economic fiasco. New Zealand Forestry: November issue, Pg 9-10.

Smith, W.W. 1888. On the birds of Lake Brunner district. Transactions of the New Zealand institute 21: 205–224.

Spellerberg, I.F. Morrison, T. 1998. The ecological effects of new roads: a literature review. Science for Conservation No 84. 55 pp. Department of Conservation, Wellington.

Seal, U., Garland, P., Butler, D., Grant, A., O'Donnell, C. 1993. Population Viability Analysis: Kea (Nestor notabilis) and kaka (Nestor meridionalis). Results of a workshop for kea and kaka in Christchurch, New Zealand, 2-5 December 1991. Department of Conservation and IUCN/SSC Captive Breeding Specialist Group, Minnesota.

Szaro R.C., Balda, R.P. 1982. Selection and monitoring of avian Indicator species: an example from a ponderosa pine forest in the Southwest. GTR-RM-89. June 1982. USDA Forest Service.

Taborsky, M. 1988. Kiwis and dog predation: observations in Waitangi State Forest. Notornis 35. 197-202.

Taiepa, T., Lyver, P., Horsley, P., Davis, J., Bragg, M., Moller, H. 1997. Co-management of New Zealand's Conservation Estate by Maori and Pakeha: a review. Environmental Conservation 24: 236 - 250.

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Thomas, C.D., Moller, H., Toft, R.J., Tilley, J.A.V., Harris, R. 1989. The impact of Vespula wasps on native insects and birds: second year research report. DSIR Ecology Division Report No. 25. 44 pp.

Thomas, C.D. , Moller, H., Plunkett, G.M., Harris, R.J. 1990. The prevalence of introduced Vespula vulgaris wasps in a New Zealand beech forest community. New Zealand Journal of Ecology, 13: 63-72.

Timberlands West Coast Ltd. 1998. Overview plan for the sustainable management of beech forests. Timberlands West Coast, Greymouth.

Timmins, S.M. Williams, P.A. 1991. Weed numbers in New Zealand's forest and scrub reserves. New Zealand Journal of Ecology 15: 153-162.

Toft, R. Predation of orb-web spiders (Araneidae) by introduced common wasps (Vespula vulgaris) in a New Zealand beech forest. University of Otago Wildlife Management Report No. 75. 25 Pp.

Toft, R. J.; Rees, J. S. 1998. Reducing predation of orb-web spiders by controlling common wasps (Vespula vulgaris) in a New Zealand beech forest. Ecological Entomology 23 : 101-106.

U.S. . Laws, Statutes, etc., Public Law 94-588. National Forest Management Act of 1976. Act of Oct. 22, 1976. 16 U. S. C. 1600 (1976).

USDA, 1997. Interior Columbia River Basin Ecosystem management project Eastside Environmental Impact Statement. Vol 1. FS-652,. Washington, DC. USDA Forest Service.

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USDA, 1999. Sustaining the people's lands: recommendations for stewardship of the national forests and grasslands into the next century Committee of Scientists Report, 15 March, 1999. Washington, DC. USDA Forest Service

USDA, 1999. Draft USDA Forest Service Strategic Plan (2000 Revision). FS-652, November, 1999. Washington, DC. USDA Forest Service.

Waters, C. 1997. Challenges in adaptive management of riparian and coastal ecosystems. Conservation Ecology.

Walters, C.J., Holling, C.S. 1990. Large-scale management experiments and learning by doing. Ecology 71: 2060-2068.

Wilson, P.R. 1984. The effects of possums on mistletoe on Mt Misery, Nelson Lakes National Park. Pp 53-60, In: Dingwall, P.R. Protection and Parks: essays in the preservation of natural values in protected areas. Department of Lands and Survey Information Series No. 12.

Whitaker, A.H. 1997. Timberlands West Coast Limited: The herpetofauna of Beech Working Circles 1 and 3, Grey Valley and Maruia Valley, north Westland. Unpublished report, Timberlands West Coast Limited, Greymouth.

Whitaker, A.H. 1999. Timberlands West Coast Limited: The herpetofauna of the Inangahua Working Circle (BWC3), north Westland. Unpublished report (draft), Timberlands West Coast, Greymouth.

Wilson, P.R. , Karl, B.J., Toft, R.J., Beggs, J.R., Taylor, R.H. 1998. The role of introduced predators and competitors in the decline of Kaka (Nestor meridionalis) populations in New Zealand. Biological Conservation 83: 175 - 185.

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Go to index.
Appendix 1:           Curriculum vitae and my standing
to evaluate this proposal

I obtained a BSc (1975) and MSc (First Class Honours; 1977) from the University of Auckland, and a PhD from the University of Aberdeen, Scotland (1983). I have both a botanical and zoological training (double majors) and in the past 10 years have taught wildlife and conservation management at the University of Otago. I can therefore evaluate both science and management, especially in South Island beech forests where I have researched for over 10 years.

The wider context of my commentary stems from over 23 years of experience in the application of ecological science for conservation, pest control and sustainable harvest. I was awarded the New Zealand Ecological Society Award in 1990, its inaugural year. This is the Society's top award for scientific excellence and is granted "in recognition of outstanding achievements in the study and application of ecological science". Other awards received by me include the Prince & Princess of Wales Science Award, 1994 (granted by the Royal Society of New Zealand), a Waitangi Fellowship (1995), a British Council Travel Award (1995), a Stapledon Memorial Trust Travel Fellowship (1995), and a British Council Higher Education Link Fellowship (1997 – 1999). I have published 85 peer reviewed scientific papers or book chapters, and a further 92 popular articles and reports.

I am particularly experienced in ecological processes and the impacts of introduced mammals and wasps on birds and weeds in beech forests like those under consideration in this application. I have supervised student research on bats166 and mathematical modelling of Okarito brown kiwi population viability167 and robin trends with and without predator control168.

My evaluation of this submission is from the standpoint of a professional conservation scientist and harvest management scientist. I served (1991-1994) on the Scientific Advisory Committee

166O'Donnell (1999).
167Joyce (1995).
168Brown (1994).

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for World Wide Fund for Nature (WWF-NZ) and currently is a member of the International Union for Conservation of Nature's (IUCN's) Australasian "expert panel" on Sustainable Use, and another expert panel on "Co-management". These expert panels are made up of an international coalition of conservationists, scientists and managers.

I am the Minister of Conservation's appointee on the New Zealand Game Bird Habitat Trust Board, a group of managers dedicated to habitat creation and enhancement to support sustainable harvest.

I work 80% of the time for the University of Otago, and 20% of the time for Ecosystems Consultants Ltd.

I have visited trial beech forest use areas covered in these proposals and flown over the areas in question. I have also visited several of the beech forests as part of 5 years research on wasps and their impacts on indigenous bird species.

Go to index.

Appendix 2:        Common and scientific names used for plants and animals in this submission169

Bellbird (Anthornis melanura)
Great Spotted kiwi (Apteryx haastii),
Kaka (Nestor meridionalis)
Kakapo (Strigops habroptilus)
Kereru (Hemiphaga novaeseelandiae)
Little Spotted kiwi (Apteryx owenii)
New Zealand falcon (Falco novaeseelandiae)
Rifleman (Acanthisitta chloris)

169 Some of these subspecies will be elevated full species after publication of a paper in New Zealand Journal of Zoology submitted by Richard Holdaway, Trevor Worthy and Alan Tennyson.

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Silvereyes (Zosterops lateralis)
South Island brown kiwi (Apteryx australis)
South Island bush wren (Xenicus longipes longipes)
South Island kaka (Nestor meridionalis)
South Island kokako, (Callaeas cinerea cinerea)
South Island piopio (Turnagra capensis capensis)
South Island saddleback (Philesturnus carunculatus carunculatus)
Tui (Prosthemadera novaeseelandiae)
Yellowhead (Mohoua ochrocephala),

Short-tailed bat (Mystacina tuberculata)
Long-tailed bat (Chalinolobus tuberculatus)

Wasps (Vespula vulgaris, Vespula germanica)

Beech (Nothofagus)
Miro (Podacarpus ferrugineus)
Mistletoe (Elytranthe)
Rata (Metrosideros umbellata )

Go to index.

Appendix 3:        Responses to the Councils' Independent Reviewer and Salient Objections

Report by Council's Independent Reviewer, Professor John Craig

I agree with Professor Craig's conclusion that:
the proposed extraction regime is inherently conservative and that this greatly reduces the risk to biodiversity;                                                      

to not control introduced predators, 'harvesters' of native wildlife, would cause unsustainability                                                      

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'protection' of biodiversity must primarily focus on mitigation of these predatory impacts (reservation alone will not achieve this);                                                                  

that intervention has historically been mainly species based according to national priorities and this proposal is a pleasing extension of the same principle to local levels for Ecosystem Management ends;                

that minimal changes to forest functioning will occur from the proposal;                                                                   

that "sustainability is a journey" so that adaptive management approach coupled with ongoing consultation with stakeholders and future society is needed;                                                                 

that "sustainability is a journey" so that adaptive management approach coupled with ongoing consultation with stakeholders and future society is needed;                                                                 

that a range of harvesting regimes should be planned and trialed (e.g. 30%, 50%, 70% of predicted annual productivity) to hasten learning the approach Professor Craig is advocating is in accordance with best professional practice overseas;                                   

that a range of harvesting regimes should be planned and trialed (e.g. 30%, 50%, 70% of predicted annual productivity) to hasten learning170 the approach Professor Craig is advocating is in accordance with best professional practice overseas;                                   

that a more explicit design for adaptive management changes be declared;                                                                                                           

that more explicit targets for pest control achievements would be desirable (though I doubt that adding many more details right away is practical, nor that ecological research is available to set optimal targets).                                           

that more explicit targets for pest control achievements would be desirable (though I doubt that adding many more details right away is practical, nor that ecological research is available to set optimal targets).                                           

Although I therefore agree with the general thrust of Professor Craig's comments, I disagree on the following (mostly minor) points:
on p. 8 of his report, Professor Craig expresses concern that compensatory growth and recruitment will bring about a forest with younger but faster growing trees. This misses the point that artificial gaps subsume natural gaps. By selecting 'gap makers' (large leaning or defoliated trees that are about to fall) the foresters will retain forest tree size/age ratios at near to natural levels. Therefore I see little prospect of cumulative effects of harvesting in the way envisioned by Professor Craig.

On pp 9, 12, 13, 14, 16 Professor Craig calls for more specific targets for pest control. I believe it is impractical and potentially unjust to set such targets until the net revenue from forestry has been established by the market. Since DoC do no sustained predator control on nearby land and none would occur on TWC land if this proposal does not go ahead, I believe that any predator control at all will be an advance for protection of biodiversity, as required

170 Walters & Holding (1990) referred to this as an "active adaptive management" approach. It is much more likely to provid lessons about how the system operates and allows faster convergence on the optimal management regime.

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by the RMA. I prefer that an upper and lower threshold of expenditure (like the 5% to 10% stipulated) be set so that escalation of the profits is reflected in added benefit to biodiversity. If profits drop or are lower than expected I believe it would be an 'unfair and unreasonable burden' to stipulate a fixed amount of expenditure on the proposer at the outset. If the Councils require such a fixed amount, it may be necessary to delay the final target at least until initial start-up costs have been incurred and extraction is at full swing. It is possible that 10 years may be needed before market indicators gain set reasonable expenditure.

If it is decided to stipulate a fixed target for pest control, I can not see how it could be expressed in meaningful ecological terms. The amount of pest control needed to restore native species is not known 171so setting a sensible target is difficult. The area protected, and/or the interval (years) between successive control operation could be stipulated172. A simple matching of expenditure relative to DoC seems even less sensible in that it has no ecological basis and DoC and TWC will experience different cost effectiveness in the methods they propose to use (physical features of their land and methods will probably differ).

Setting practical pest control targets at the outset is also hampered by unmeasured risks to non-target species and inadequate replication. Trials so far of the secondary poisoning technique are very encouraging but the Ecosystems Consultants Ltd. team concluded173 more stringent tests of risks to non-target species before the method is cleared for regular and widespread use.

Extra expenditure for mitigation of roading impacts seems to ignore the fact that the proposal will add net conservation value from predator control to many areas of the TWC estate. Similarly the intervention into Recovery Forests will hasten restoration of the forest structure to a state more like its original. This will probably happen in ca half the time with TWC's intervention174. Both these initiatives are likely to add much more conservation gain than the small loss incurred from roading. Accordingly the Councils may consider that a net

171 Moller (1989) coined the term 'Ecological Damage Threshold' for the pest population abundance required to protect a species. It is unknown for New Zealand biota in general.
172Modelling by Brown (1995), Moller & Brown (submitted) predict ca 3 year return times are needed to restore robin populations.
173Alterio & Moller (in press).
174Kit Richards, pers. comm.

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conservation gain has already been achieved without the need for the added expenditure suggested by Professor Craig.              

Professor Craig suggests sensible precautions to identify bat roost trees. However I doubt that they can be detected very often. I argue in my evidence that felling of bat roost trees will happen at natural rates anyway. Directional felling of gap makers and trees in their "felling shadow" may even increase roost trees, provided that the tree selection can subsume natural mortality 175. I therefore consider the need for identifying additional procedures for sustaining bats after 6 months to be unnecessary. As stated in my evidence I believe monitoring of bats is the key safety measure.

Similarly special added procedures to protect mistletoe seems unnecessary. What else can be done other than the control of possums that threaten them and the leaving of trees with mistletoe? Incident reporting will record whenever a mistletoe has been mistakenly felled. Monitoring and regular review of the frequency of such incidents should be done, but it seems unclear what else can be achieved. Mistletoe would be destroyed by natural tree falls at about the same rate as under forest management anyway.

Professor Craig urges predator control in areas thought to contain South Island kokako. I agree that this would be prudent if kokako are confirmed to be present. Before then I believe the criteria set out in my submission for choice of areas for pest control should take precedence. They are more likely to realise maximum conservation benefits.

The suggestion (p15) that we use distance sampling techniques for monitoring focal species should be considered in detail. However the technique has its own problems and assumptions just as does the 5 minute bird count method. I urge that specific (maybe even new) techniques should be selected only once a sound ecological basis for the choice of the focal species has been found. A more focussed choice of appropriate techniques can follow nomination of the focal species.

Department of Conservation's Submission

DoC's assessment of the high conservation value of the area is shared by the Applicant. Therefore there is no dispute about the high values present and the need to protect them.                                                    

175The correct identification of dying trees is crucial in this regard

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Similarly I concur with DoC's identification of the large-old trees as the critical resource and for this reason support the several ways that they will be retained by the proposed scheme.                                                    

DoC's requirement (p 3) that TWC still needs to demonstrate that their provisions will not reduce the density and proportion of these trees in the "landscape" is unreasonable if it is intended to require such a demonstration first. All new endeavours are a step into the unknown. I believe that the proposal has taken all practical steps to minimise risks. Adaptive management and monitoring provide the safeguards that DoC seeks. The ecological rationale for their request for 80cm DBH upper size limit (p 3) is not stated; and DoC provided no basis for asserting that the proposal has somehow got it wrong by choosing a >90-110cm DBH limit.

Preliminary stages of modelling effects of tree holes as (requested on p 3), have already been commissioned as a precaution. However all preliminary models are unlikely to give accurate predictions176 and are useful mainly to identify the most crucial assumptions to test, and the most important parameters to measure accurately. It will be several years before a sufficiently robust model could be built to closely guide management.

DoC implies (paragraph 3, p3) that habitat modifications from the proposal may impact on threatened species. This misses all the inferences from first principles of ecology and empirical observations by Drs. G. Elliott and C. O'Donnell in Eglinton beech forests that such birds are very unlikely to be threatened by habitat values.

DoC asserts (paragraph 4, p3) that "lack of knowledge of the likely impact on bats frustrates assessment of this application". No specific concerns are raised by DoC of any putative likely negative impacts. Positive impacts from predator control and road creation are likely in my view. Nor are the scientific objectives of the requested prior study stated with explicit links to how they can help predict risks or help instigate any unwanted effects. I see little prospect of studies that could help in this way sufficiently to require it to happen before granting resource consent. Dr. O'Donnell's excellent studies in the Eglinton valley suggest that at least 2-3 years of very intensive and expensive study would be needed to mark sufficient bats to adequately describe populations, their movements and roosting behaviour. This seems an unreasonable delay and expense especially considering the lack of statement of specific and logical research questions to be investigated that could inform of putative risks

176Hamilton & Moller (1995)

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to bats from the proposal. Nevertheless research is always potentially useful, especially for 'Category B' 177 species like long-tailed bats. The more we understand a species the more likely we are to be able to assist it. It is pleasing to note DoC's offer to assist with any such research.

I agree with DoC's identification (paragraph 2, p 6) of rimu as an important food source for birds. However no evidence is given that food is a limiting resource for the birds. Inference from first ecological principles suggest that predation has lowered bird abundance well below the levels sustainable by food and tree holes (if not, why were bird abundances so much higher 120-140 years ago before predatory impacts were fully realised?). There is no evidence to justify the removal of rimu from the harvesting consent.

I agree with DoC's request that predator control should "not be regarded as a mitigation factor per se, but as a package of forest measures" (paragraph 5, p 7). This is a way of adding net conservation benefit. It is the key to a true win:win between economic and ecological interests. There is no tangible evidence of deleterious effects that require mitigation as such.

The unknowns in harvest modelling and subsumation of mortality (paragraphs 7 and 8, p7) have been acknowledged. A precautionary approach has already been taken in several sensible ways. Periodic audits are in place so that a full consent process before 35 years seems unnecessary. The choice of 35 years is logical because it represents two complete felling cycles after an initial build-up phase of ca 5 years. This gives time for broad scale impacts to be assessed.

Paragraph 2, p 8 asserts that TWC reserves are not large enough in themselves to support viable populations of threatened species. I believe that this is probably true for most species (some invertebrates, lizards and small passerines may be exceptions) but wonder why DoC appears to assume them ecologically disjunct from the surrounding harvested areas. No evidence has been presented by DoC or other submitters that any species/populations will be fragmented or depressed by the proposal. The reserves (DoC and TWC) adjacent to harvested areas will receive recruits from harvested areas of forest and vice versa. The latter will predominate if successful and prolonged predator control is achieved in harvested areas.

DoC's request (paragraph 3, p 9) for ongoing addition of reserves to achieve protection is simply a reiteration of their own belief that reservation is the only way to achieve protection                                                

177Molloy et al. (1994).

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and conservation. The main body of evidence sets out many ways that conservation through sustainable use complements reservation and preservation. Each has their role in supporting biodiversity. This DoC submission has given no tangible evidence that the proposal threatens biodiversity and scant recognition to the way it will enhance biodiversity. Nor is there mention of the wider risks to biodiversity from not going ahead with the proposal.

Royal Forest and Bird Society
This submission makes several sweeping and generalisations about lack of178 information provided in the proposal concerning:

--              Logging prescriptions (number and size of stems taken)

--              Management plans

--              Expectation that adverse effects will be minor

--              Wildlife surveys and species at risk

--              Log removal impacts on ecosystem functioning

--              Definition of "significant" vegetation and habitat

--              Minimal impact

These generalisations are simply wrong or unsubstantiated by Forest and Bird. No direct defendable scientific evidence is provided for me to assess the basis of their claims. This lack of substantiation of the Forest and Bird claims makes it difficult to know where to start in response to their submission.

There are other exaggerated claims in the Forest and Bird submission that can be easily demonstrated to be false. Important in this regard is the repeated assertion (e.g. p 6) that there has been no research to substantiate the TWC claim that impacts will be minor. In this report I cite scores of references to ecological research showing just that.

The suggestion that "there is no scientific research which establishes that predator control can compensate for the impacts on wildlife" is technically correct but misleading. This demonstration does not exist because no pest control has been attempted in previously logged

178or the inadequate nature of

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areas. This proposal is new and innovative in that regard. There are scores of scientific papers over the past 30 years demonstrating rapid increase of populations of New Zealand wildlife in response to removal of predators or translocation to predator-free islands. It is exceptionally strained to assert that such restoration effort would not rapidly outweigh any minor alteration of habitat by harvesting.

The claim (p 3) that no research is provided on increased growth rates as a result of competition is again technically correct but misleading. Abundant research exists on such effects and it is a fundamental understanding tested by standard forestry practice for centuries throughout the world. Detail is not provided in the plan because compensatory changes in growth has not been assumed in the models used in the proposal. This exclusion is part of the very precautionary principle advocated by both the proposal and Forest and Bird. Incorporation of growth compensation would lead to predictions of increased yield, so its emission is one of the ways the proposal is conservative in recognition of the Environmental Precautionary Principle.

The 'Landcare Model' referred to on p 4 is flawed and does not represent accurately what the proposer sets out to do. The model is misleading in its assumption that felled trees are chosen at random rather than carefully selected so as to subsume natural mortality.

The statement (paragraph 3, p 4) that "A reduction in habitat is likely to significantly reduce the abilities of [kaka, parakeets, and native bats] to survive" misses all the issues of predator imposed lowered density because of predation and the empirical evidence already available that holes do not limit their populations.

The Forest and Bird statement (line 2, p 4) that human disturbance "on top of natural disturbance" is implying added rather than subsumed mortality. This shows that Forest and Bird either do not understand the process of subsumation or have chosen not to declare it.

Scientific evidence for impacts of roads (paragraph 5, p 4) is lacking. The suggestion that they will fragment the habitat is an exaggeration and contrary to expectations from ecological understanding of the scale of movements of recruits in the wildlife living there.

          Dr H Moller - Evidence for RC 99/75                                                                         Page 79 of 79

Reference to past, undoubtedly unsustainable forestry practices (paragraph 4, p 4) is a non sequitur. It fails to recognise the complete paradigm shift embodied in the proposal.

Shading of streams (p 5) is not a particularly important predictor of native fish abundance (see NIWA evidence regarding the application). In any event very minor changes in shading will be triggered. If natural gap formation is entirely subsumed, no change in shading will occur.

Overall assumptions made in the Forest and Bird submission are that

  1. Reservation/preservation is the only ways of achieving protection according to the stipulations of the RMA
  2. That all risks to biodiversity go against the proposal – there is complete lack of recognition of the risks to biodiversity from not proceeding with the proposal.

The definite benefits to biodiversity from predator, browser and competitor control are not acknowledged.

I conclude that the Forest and Bird submission exaggerates risk and is unbalanced in its risk assessment. I believe that if the Councils decline the application, they would be effectively removing support and enhancement of biodiversity on the TWC estate. This would also deny ecological survey information, research and the development of effective tools for conservation management for application elsewhere in New Zealand.