Chris Perley makes telling points about sustainable management and the need for integration of human needs, ecology / biodiversity needs, and the economy in land management strategies, rather than segregation into discrete entities each with a narrow range of objectives. Mr Perley was, in April 2000, elected to the position of Vice President of the New Zealand Institute of Forestry.




16 June 2000


National Policy Statement - Biodiversity
Ministry for the Environment
PO Box 10 362
Wellington
Nps@mfe.govt.nz


NZ INSTITUTE OF FORESTRY SUBMISSION ON BIO WHAT? -
A PRELIMINARY REPORT OF THE MINISTERIAL ADVISORY COMMITTEE -
ADDRESSING THE EFFECTS OF PRIVATE LAND MANAGEMENT ON
INDIGENOUS BIODIVERSITY


1.         NZ INSTITUTE OF FORESTRY (NZIF)

The New Zealand Institute of Forestry is an organisation with a proud history. It was founded in 1927 to provide a forum where those involved in forest management, utilisation, research and consulting could exchange ideas and information and keep up to date with industry trends. Membership includes foresters, research scientists, and policy makers from a wide range of disciplines across the fields of biological science, social science and resource management.

As well as the stimulus of debate and the fellowship of colleagues, the Institute encourages the highest standards of ethical and professional performance amongst its members. Today this role is even more vital in an industry that has continued to evolve and grow almost beyond recognition since its earliest days.

New Zealand Institute of Forestry membership is an acknowledgement of high levels of competence through education, experience and ability and is evidence of a member's commitment to professional practices and values.

For its part, as an organisation the Institute is committed to serving the practice of forestry and the wider community through education, accountability and its codes of ethics and performance standards. Increasingly it fulfils a quality assurance role, setting the benchmark for professionalism and the quality of advice and practice by which members and others in the profession are measured.



2.        GENERAL COMMENTS ON BIODIVERSITY DEBATE

Before commenting on specific issues relating to the Bio-what? preliminary report, some general comments on the current debate on biodiversity need addressing. These comments relate to the range of scientific and philosophical principles advocated by various parties. It is the Institute's believe that much of the debate must focus on these appropriate premises if any biodiversity strategy is going to achieve the objectives sought. Each is related to the others.



2.1         Segregation v Integration

There are generally two broad approaches to land management strategies applying internationally:

  • either the approach of segregating areas into relatively discrete entities, each with its own narrow range of objectives or purposes (from the idea that nature is a machine, which emphasises the structural, and supposedly largely independent, 'parts');
  • or the integration of purposes or objectives across all or most land (from the idea that nature is a system - which emphasises the functions and processes that interrelate each part - and with human society and economy as an integral part of the environment).
The former emphasises analysis without reference back to the whole and risks failure through a lack of perspective. The latter emphasises synthesis of the parts to a coherent whole. It is the preferred perspective, and is a feature of professional forestry where the social, environmental and economic are each acknowledged as issues in forest management.

Policy in New Zealand currently favours the segregated approach, and seeks to address a narrow range of objectives in discrete land packages. Commercial, social and environmental objectives are seldom integrated. Since 1987 more commercial objectives were segregated from environmental and social objectives, and environmental objectives were segregated from social objectives. Both neo-classical economists and mainstream environmentalists (who tend to focus on preservation) have advocated this segregation from different parts of the spectrum.

This segregation has not addressed our environmental objectives well. Bio-what? appears to be an attempt to address these concerns by attempting an re-integration of these objectives, at least on private lands. The Institute of Forestry is supportive of this general philosophical approach, and is also supportive of a re-integration of these objectives on public lands.

Segregation is usually associated with an attitude that sets humans apart from the environment - which leads on to the second point below.



2.2       Ecological Protection and Human Use - are they Mutually Exclusive?

Those who advocate a segregated (or land allocation) approach also tend to presume that human enterprise (especially extractive enterprise) is mutually exclusive from environmental protection. It is a fact that many land management practices DO harm the environment, but there are also examples where human use is entirely compatible with environmental protection.

The challenge for biodiversity on private land is to encourage the acceptance of management practices that achieve this mutual benefit.

There will, however be many submissions that begin with the premise that human use and environmental protection are mutually exclusive, and will continue to advocate the preservation options - either to DOC or through QE II trust and Nga Whenua Rahui - within private land as the their only perceived solutions. This is not to say that these options are not valuable - they are - but the mistake of the past has been to consider preservation the only solution.

In accordance with this preservationist view, at least one environmental group has passed a remit to the effect that sustainable management of indigenous forestry is not a possibility (the ultimate corollary being rather depressing for humanity). This view stems partly, at least, from a wrong view of nature, and from a lack of appreciation of our species' own environmental history. Many people presume that all environmental change is bad, and therefore that humans who change or disturb the environment are doing "harm". In their eyes the environment is characterised by a static structure, rather than characterised by dynamic processes. A quote from Daniel Botkin's book Discordant Harmonies is relevant.

"Under the old management, management for conservation and management for utilisation (such as harvesting fish and cutting forests for timber) appeared to be different and, in general, incompatible goals. From an old preservationist perspective, nature undisturbed achieved a constancy that was desirable and was disrupted in an undesirable way only by human actions. From an old utilisation perspective, the forest was there to cut, take apart, replace, and put back together as one chose. If nature was like a watch, then one had to choose between the stereotyped preservationist's approach - appreciate the beauty of the watch, and use it to tell time - or the stereotyped engineer's approach - attempt to take the watch apart and improve it, or use the parts for something else.

Under the new management, our role in conservation is active: for example harvesting may serve the interests of conservation as well as utilisation, and the goals of conservation and utilisation can be part of one approach."
(Botkin 1989, p 156)

It should be noted that Botkin is being as critical here of the utilitarian (purely anthropocentric) approach to a nature 'apart' from us, as he is of a preservationist view that also sees nature as 'apart' from humanity.

The Institute of Forestry agrees with Botkin (and Bio-what?) that our role in conservation is active, and that harvesting may serve the interests of conservation as well as utilisation. This is very much in line with the professional forestry paradigm of multiple use. The Institute does not accept the view that use and environmental protection are mutually exclusive. The evidence of example points to the reverse being the case where management is sensitive to environmental objectives.

The implications of Botkin's view are profound for land owners. Maintaining and enhancing biodiversity need NOT be a win-lose game for resource managers. Management decisions can BOTH reduce risk, increase financial returns, while at the same time decrease adverse environmental effects and increase biodiversity. Often those who analyse a land use look at only a narrow range of aspects without any attempt to understand the whole (i.e. analysis without synthesis - segregation rather than integration). An example of a win-win is where a farm manager moves from attempting an increase in 'production' of a single product over a whole farm, to a landscape ecology perspective that permits the consideration of a diversity of land uses, including preservation and indigenous habitat enhancement. Arnold (1983) records the positive influence of a single tree or ditch can have on biodiversity.

As an example of biodiversity being compatible with commercial extraction, plantation forestry generally has positive effects on indigenous biodiversity where it replaces improved pasture land uses. The following references all record the biodiversity within plantation forestry: Allen et al 1995, Clout & Gaze 1984, Clout 1984, Henry 1954, Hutcheson & Jones 1999, Ledgard & Belton 1985, Ledgard 1995, McQueen 1961, Norton 1989, Ogden et al 1997, Tickell 1984.

However, the statement above does not imply that the Institute of Forestry is an advocate for plantation forestry over indigenous forestry. The Institute has an Indigenous Forest Policy which advocates, inter alia, the objectives of sustainable management of all indigenous forests, and the net increase in the total area and improvement in the overall quality (health, diversity and productivity) of indigenous forests.

Integrated farm forestry is perhaps the very best example where biodiversity returns are an unintended consequence of a commercial management decision. If analysed at a net margin instead of a gross margin level, the benefits of removing marginal land from grass production - either to indigenous systems or to production forestry - can far outweigh the losses. Entomological research shows that macroinvertebrates - the insects alone making up about 65% of our indigenous biodiversity (John Hutcheson, pers. comm.) - are major beneficiaries of any forest establishment or regeneration, whether exotic or indigenous. As Arnold (1983) shows, trees - whether indigenous of introduced - are good for biodiversity.

Seeing these win-win possibilities requires a change of perspective to encompass ecosystem processes as well as commercial and social realities. Such a focus on a more sophisticated ecosystem process view of the land was advocated by Blasche et al (1992).

That change in perspective is needed not only from the land managers, but also from the policy makers and shapers. It would be arrogant for the policy makers to believe that it was only the land managers who need to change their values. Unfortunately, that arrogance is almost certain to be reflected in many submissions. This point on top-down arrogance leads on to the third point.



2.3         Top Down or Bottom Up?

Broadly speaking there are two approaches advocated in order to increase the biodiversity on private land;

  • the view that some centralised authority knows best (be it government or some other group) and change must be driven through regulation, and
  • the view that effective change in the long term can only result from a voluntary change in values toward the environment and the way land is managed.
Strictly speaking there is a continuum across this divide, and some form of managed direction is almost inevitable. The Institute of Forestry acknowledges the role of top-down direction with regard to removing disincentives and constraints to change, and providing incentives to change, but it believes that long term change can only come about by the improved knowledge, values and ethics of land managers.

Aldo Leopold (a forester, early conservationist and environmental ethicist) is a major inspiration to many within the forestry profession (Leopold 1949) for his advocacy of a land ethic that encompassed this perspective. Ethics, knowledge and values are best reinforced by communities operating locally, not by the arrogant from on-high. Leopold envisaged that these community reinforced principles determine the rights of land owners.

Central to Leopold's land ethic is that individuals do not have a socially accepted right to harm the environment. Many environmentalists will agree with this statement and interpret it as meaning 'no use'. As discussed above, this is simplistic and an ecological nonsense where humans work within ecological tolerances. One of the issues that this highlights is what are the ecological tolerances in our environment (a lack of information is apparent here, as the report acknowledges).

Importantly, the NZIF does not accept that a bottom-up, voluntary approach is tantamount to an encouragement of continued poor land management practices. To advocate for a largely bottom-up approach should not be interpreted as an advocacy for the right to abuse the environment. The Institute's argument is that the better way to improve knowledge and change values is to work with people rather than against them.

These three general points are highly relevant to the approach apparent in Bio-what? In general, the document champions the view of integration rather than segregation; that use and protection are not mutually exclusive, and that effective change requires a predominantly bottom-up grassroots approach to change in land management.

The Institute of Forestry agrees with these three implicit principles that underpin the Bio-what? report. It is inevitable however, that many submitters will oppose this report because they hold to the opposite three premises. Whatever changes may be made to specifics through the submission process, the Institute believes it would be a backward step for biodiversity protection if any of these principles were abandoned.

Comments on specific details of Bio-What? are below.



3.         ISSUES

The NZIF is generally in agreement with the eight issues identified:

  • A lack of common focus
  • Uncertainty over who is responsible
  • Different perceptions about the nature of 'property rights'
  • A lack of comprehensive or consistent information
  • Particular threats including plant and animal pests
  • Scarce resources
  • A shortfall in tools to do the job
  • Insufficient consultation.
However a number of issues have not been addressed. The first is the lack of acknowledgment by many that a problem actually exists at all. Miller & Andrews (1993; cited in Parminter 1994) state that land owners will not move to correct a problem if they do not perceive they have one. This was in relation to the uptake of soil conservation measures by farmers in Australia, but is just as relevant to the uptake of practices likely to enhance biodiversity. This attitude that 'sustainability' is only a perceived problem in the eyes of some market, officials and environmentalists is not uncommon, especially among some farmers.

It is the opinion of the NZIF that forestry is more aware of the biodiversity and general sustainability issues. This is evidenced by the publication of the NZ Forest Code of Practice (Vaughan 1990, revised 1993), the improvement in plantation forestry operational practices since the 1970s, the professional understanding in ecology required as part of a forester's education, and the many initiatives undertaken by the forestry sector toward improving management and providing information. It is also evidenced in the interest in environmental research by forestry concerns in both the planted and indigenous estates.

The second issue that has not been considered is the lack of political will to solve the problem through an objective policy making process. The temptation for both political parties and environmental groups is to succumb to the opportunities biodiversity offers as a political football - either for votes or membership. It is unfortunate that those environmental groups doing some of the best work toward environmental solutions are the most marginalised because they do not relate to the more adversarial and populist mainstream of environmentalism.

This general lack of objectivity is a major concern for many in the Institute. The track record of the current Government has been very poor to date, and this ought to be acknowledged. The forestry policy decisions by Government as they affected the West Coast are relevant to a number of the issues above besides this one. Timberlands was not only aware of biodiversity issues; it was also financing considerable research into ecological research, biodiversity protection, environmental monitoring, ecosystem-based management principles, environmental management systems, and low impact operational management practices which were of relevance outside their estate, and even outside the forestry sector. It is this sort of research and commitment that gives us an understanding of ecological tolerances. It had the resources, the expertise, and the will to undertake such research. That they were not permitted to continue reflects the poor focus to which the report refers. It has also set back much needed work if a change in land management practices is to be achieved.

The third issue that needs to be addressed is some identification of specific problems and key constraints (economic, environmental and social), and their prioritisation for action.



3.1         NZIF Contribution to biodiversity (Question p 23)

The Institute of Forestry contributes to the halt in biodiversity decline by providing for the dissemination of information on the issues, and through the provision of debate through the journal (NZ Forestry, since November 1998 renamed back to NZ Journal of Forestry), conferences, workshops and considered policies. The debate has included views from outside the profession (Hughes 1994, Moller 1998, Potton 1994, Rosoman 1995, Sage 1998, Salmon 1998, Thies 1994, Turner 1993) as well as commentaries and scientific articles from inside the profession (e.g. Benecke 1996, Bigsby 1994, Carson 1997, Dyck 1997, Griffiths 1998, Hosking 1997, James 1998, Norton 1998, Ogden 1997, O'Loughlin, C. 1995, Perley 1994, Perley 1997, Perley 1998, Purey-Cust 1996, Richards 1994, Shaw 1997, Smale et al 1998, Spellerberg & Sawyer 1995, Spellerberg 1996, Stewart et al 1998, Sutton 1995, Treeby 1997, Whyte 1996). The debate has been exceedingly robust by anyone's definition.

The Institute has, inter alia, an environmental working group and an indigenous working group, and has established a number of policies relating to environmental management, including biodiversity. Its members have been involved in the development of many policies relating to the environment, from the central and local government initiatives where their expertise is required, the West Coast Accord, NZ Forest Accord, and Principles for Commercial Plantation Forest Management in New Zealand (though it is not a signatory to these), through to international agreements such as the Montreal Process Criteria and Indicators for sustainable forestry management. The inclusion of a land ethic in our code of ethics has been considered before, and has recently been raised again as an issue for debate.

The conclusion can only be that the Institute's membership is very well informed about biodiversity and other environmental issues, and as our indigenous forest policy states, wants to see improvements in quantity and quality of habitat for indigenous species (c.f. Question 2 p 23). With that desire comes an acknowledgment that introduced species often play a beneficial role in providing for indigenous biodiversity. A purist focus on indigenous biodiversity in isolation from introduced species cannot work within private land.

In terms of priorities for the issues identified (p 23), the Institute believes that information remains the key priority, especially its dissemination and uptake by land managers. The other key considerations are the two mentioned above (recognition of a problem, and government meddling with any programme for political reasons) as well as the scarce resources available to both land managers and regional councils who are best situated to act as information disseminators and organisers.



4.         Principles

The principles are supported by the Institute of Forestry. It is apparent that the advisory committee has come at this issue with an understanding of the human constraints involved. Many of the social constraints to the achievement of biodiversity improvements are addressed here.

5.         Proposed Approach

The Institute is generally in agreement with the proposed approach. The approach acknowledges some necessity for top down provision of direction and information (including regulations where necessary), but acknowledges the need for consciousness changes to come from the grass roots. It is important to recognise that information flows both ways, and that the grass roots should not be assumed to all be poorly informed. The Institutes contention is that its members, and many members of the farm forestry community can provide much information of value, especially for how economy, society and environment can co-exist.

Farm forestry has a special role because of the environmental and economic opportunities it offers to famers. There has been slow recognition of these environmental synergies in the past, partly because of the New Zealand policy approach of looking at land uses as segregated from each other.



5.1         National Goal

The biodiversity strategy goal is largely consistent with the Institute of Forestry's policy on indigenous forestry. The focus in the NZIF policy is on a net improvement in quantity and quality.

The NZIF does not agree in principle with the alternative goal suggested on page 32 because its focus on "protecting" all indigenous areas is incompatible with the natural dynamics of the environment, as well as community. An example is relevant. This alternative goal presents a flexibility problem which was highlighted by the NZ Forest Accord being used against a non-signatory Maori community on the East Coast. They were looking at an economic option of forestry on former farmland that had reverted to manuka. There was considerable debate amongst Accord parties about whether this regrowth constituted a forest, notwithstanding that many reserves of manuka (those of older age with indigenous understory present) were proposed. The project was abandoned although it was probable that the net biodiversity gains would have been better had it proceeded. The Maori community then looked at other options which involved parties not under any Accord obligations. This example of inflexibility was one reason why many members of the Institute were strongly opposed to ratifying the NZ Forest Accord when such an action was proposed.



5.2         Roles and responsibilities

The Institute agrees that clarification of the roles of central government, local government and individuals is vital. The land management is obviously the role of individuals and managers. Immediate liaison and support to them is best administered by the regional councils, perhaps through a better funded extension and support arm which can also act in a duel role as RM Act monitors. Extension to smaller land owners is a fact of life overseas, and New Zealand curiously did away with it in the 1980s.

The Institute does not believe we should return to those old extension methods, many of which arguably worked against biodiversity and sound environmental management through a production focus. What is needed is a more integrated extension arm with a fundamental understanding of the environment and how it relates to land management. It needs to work with people rather than against them.

The view of the Institute is that DOC has an important role in working with land managers, but it is handicapped by its own legislation and culture. It has considerable knowledge of the environment, but less understanding of land management and social realities. The legislation under which it operates does not require this knowledge. The result is that, too often, solutions to environmental problems have been addressed by DOC advocating the single solution of preservation (the removal of any commercial use, usually involving a cost to the land owner), rather than attempting to bring land managers along with them. Their focus has tended to be on increasing the size of the preserved estate rather than in improving environmental management. This parallels the approach of certain environmental groups, though not all.

The result of a generally adversarial approach (particular individuals from within DOC and certain conservancies have better reputations in the rural community than others) works against the encouragement of a better ethic toward the land. At the basis of this conflict is the commonly held view within many of our environmental movements (and including DOC) that use and protection are somehow mutually exclusive. As noted in the general comments at the start of this submission, this view is very damaging. The example of Conservation and Land Management in West Australia is in contrast to DOC. They appear to recognise that humans can live within indigenous environments, and seek to improve land management practices.

Notwithstanding these comments, DOC, in combination with regional councils, could be an influential force for biodiversity improvements provided some cultural changes were encouraged within DOC. At the moment the organisations most suited to a liaison role with landowners remains the regional councils.

Central government departments such as Environment and especially Agriculture and Forestry have key roles in information provision, policy making, and coordinating a consistent response. Funding is also an issue that must be addressed from a national level. Resources in some areas may not be sufficient to provide for solutions.



5.3         Guidance, Support and Flexibility for local Solutions

The Institute agrees in the main with the voluntary, or bottom-up, emphasis. As discussed in the general comments (section 2) to this submission, consciousness changing requires a voluntary change of heart from individuals. In saying that, a "sit back and leave it to individuals approach" is insufficient. As noted, many of those who operate on the land are not necessarily aware the environmental effects of their actions, and many do not recognise that a problem exists. Change requires a recognition of a problem, information, and the provision of options for land management. That has to come from within some organised framework.

It may also require a large stick of regulation being applied where progress warranted such an approach. Perhaps the best approach to the whole environmental management issue is to follow the Roosevelt philosophy of walking softly (proving information, incentives, encouragement, removal of constraints, working in partnership) and carry a big stick (let it be known that environmental performance MUST improve, and that the regulatory options are still available).

An emphasis on the bottom-up approach is also beneficial to the environment in other ways. It allows for the flexibility for an informed and motivated land manager to make management improvements on particular sites where a regulation may provide the opposite incentive. An example is a rule based on ploughing operations within so many metres of a water course. Rules must be general across the landscape. A rule based on some arbitrary operation, or distance, rather than an effect, may actually allow an operator to plough within say five metres where it is inappropriate to do so. It may disallow an operator to plough closer where certain situations make that entirely reasonable.

Strict and poorly thought out regulations can therefore disallow a sustainable operation, and allow an unsustainable option. They can also provide an encouragement for land managers to "work to rule" without any encouragement to develop a wider understanding of their management effects on the environment. The best of all possible worlds is where informed and motivated managers are able to make their own decisions, and develop their own ongoing learning and improvements.

Forestry is perhaps more fortunate than the farming community in that managers have backgrounds in tertiary education, there are strong sector institutions which support professional development, and there is a strong thrust to training of operational contractors. Such an industry structure has lead to some of the initiatives already mentioned - accords, industry principles and policy statements, the NZIF Handbook (now in its third edition), the NZ Forest Code of Practice, and the rise in FITEC-arranged training of workers - as well as recent initiatives in environmental certification. The farm forestry community has also benefited from these initiatives through their many links to the greater forestry sector.

There needs to be an acknowledgment of situations where sectors have performed well, and continue to improve their management. Any programme of incentives and disincentives should acknowledge that performance.

Incentives to landowners do not necessarily need to be monetary. Aldo Leopold encouraged the provision of wildlife habitat simply by tapping in to the desire of land owners in America to hunt. Fish and Game is an example of that incentive in practice. Other incentives are aesthetics and enjoyment of life - the sight of trees, the sights and sounds of birds, shelter, colour, smells and shade, the love of watching something grow from a planted seedling, or a landscape being transformed.

The biggest incentive for farm foresters in planting trees is not investment returns at all. Shelter almost always comes first, followed by ideas of land use such as soil erosion or weed control, with aesthetics always high on the list. Landcare groups, the Farm Forestry Association, the Tree Crops Association, LOCAL Forest and Bird branches (which the Institute differentiates from the promotional and policy making roles of their national leadership) and Fish & Game councils are all organisations that tap into these emotional and practical triggers.

Any programme of incentives should start first at an understanding of what motivates land managers in their land management (obviously financial return is one key motivator, as probably is lower costs, and more returns for effort spent). But an environmental incentives programme should look very closely at these community-based organisations. They are often constrained by lack of capital, and are all positive agents for land management change. There will be others, but the ones above are particularly important.



6.         Specific Measures

6.1         Accords

The Institute is pleased that national accords are differentiated from local accords. Accords require trust, and while this perhaps was evident in the past at a national level, recent events involving the West Coast Accord have badly undermined that trust. This is also perhaps a phenomenon related to the general drop in the trust of government to just 23% record in mid 1999. Top-down, and often questionable policy making for the last 20 years has done great damage to the faith in central government.

[Below is additional to that e-mailed through on 16 June]

BESIDES THE GOVERNMENT ACTIONS OVER THE WEST COAST ACCORD, ANOTHER DISTURBING DEVELOPMENT IS THE INCLUSION IN THE BIODIVERSITY STRATEGY OF TWO NEW ACTIONS RECORDED UNDER OBJECTIVE 1.1 (PAGE 42) WHEN COMPARED WITH THE DRAFT.

ACTION (I) IS "END UNSUSTAINABLE LOGGING OF INDIGENOUS FOREST ON CROWN-MANAGED LAND AS SOON AS PRACTICABLE".

THE INSTITUTE HAS NO PROBLEM WITH THIS ACTION AS IT IS CONSISTENT WITH OUR OWN POLICIES, AND ENDING UNSUSTAINABILITY IS CONSISTENT WITH OBJECTIVE 1.1 (A) "ENHANCE THE EXISTING NETWORK OF PROTECTED AREAS TO SECURE A FULL RANGE OF REMAINING INDIGENOUS HABITATS AND ECOSYSTEMS", AND (B) "PROMOTE AND ENCOURAGE INITIATIVES TO PROTECT, MAINTAIN AND RESTORE HABITATS AND ECOSYSTEMS THAT ARE IMPORTANT FOR INDIGENOUS BIODIVERSITY ON LAND OUTSIDE OF PROTECTED AREAS".

HOWEVER, ACTION (J) READS "REVIEW AND PHASE OUT INDIGENOUS FOREST LOGGING ON CROWN-MANAGED LAND AS SOON AS IS PRACTICABLE".

THIS IS AN ADDITION TO THE DRAFT STRATEGY WITHOUT ANY BASIS IN CONSIDERED SCIENCE, AND IS A POLITICAL AND IDEOLOGICAL INTERFERENCE IN THE PUBLIC CONSULTANT AND OBJECTIVE POLICY-MAKING PROCESS WHICH WAS A FEATURE OF THE BIODIVERSITY STRATEGY FROM ITS BEGINNING IN 1997.

IT WORKS AGAINST THE VERY OBJECTIVE TO WHICH IT IS SUPPOSED TO CONTRIBUTE.

TIMBERLANDS' EXAMPLE AND CRITICAL MASS OF RESEARCH AND MARKETING WOULD HAVE BEEN BENEFICIAL TO THE DEVELOPMENT OF A BETTER LAND ETHIC THROUGHOUT THE PRIVATE ESTATE. ITS MANAGEMENT IS CONSISTENT WITH AN IMPROVEMENT OF BIODIVERSITY, NOT THE REVERSE.

THAT IT WAS CONSIDERED DETRIMENTAL GOES BACK TO THE THREE PREMISES IN THE GENERAL COMMENTS (SECTION 2), PARTICULARLY THE IDEOLOGICAL CATECHISM OF CERTAIN ENVIRONMENTALISTS THAT USE IS INCOMPATIBLE WITH THE PROTECTION OF THE ENVIRONMENT IN ITS NATURAL STATE.

THE EVIDENCE THAT WAS NOT HEARD BECAUSE OF THE GOVERNMENT'S CANCELLING OF THE TIMBERLANDS RESOURCE CONSENTS HEARING WOULD HAVE PROVIDED MORE EVIDENCE FOR WHY THIS SORT OF AD-HOC POLICY MAKING IS A MISTAKE.

IT IS DIFFICULT TO TRUST CENTRAL GOVERNMENT PROCESSES WHEN THIS CAPTURE BY POLICY EXTREMES REMAINS A FEATURE.

IT IS PARTICULARLY SO WHEN THE VOICE THAT GOVERNMENT APPARENTLY LISTENS TO IS THAT MOST OPPOSED TO THE VIEWS OF PEOPLE WHO LIVE AND WORK WITHIN THEIR RURAL ENVIRONMENTS.


That being said, in principle accords may be a useful vehicle - where trust exists, and where there is a willingness for all parties to consider issues from a broad perspective encompassing environment and people. These prerequisites are more likely to be evident where people live and work in a local community. Neither central governments nor Wellington-based environmental executives do this, but local governments, and local environmental branches do, and are more likely to see beyond the myopic focus. Local accords might cover a region, a district, or even a local community. Signatories ought to encompass a breadth of concerns - as did the West Coast Accord - including environment, local people, workers, industry, and local government. Central government is obviously desirable where they are contributing something or requiring something, but their inclusion may at times reduce the chances of any consensus.

Accords may also be between a narrower number of parties, as was the NZ Forest Accord (environmental groups and forestry interests). This is a model that may also be relevant in certain circumstances and should not be overlooked.



6.2         National Policy Statements

On the face of it a National Policy Statement has the advantage of creating some consistency of approach to local government, gaining much needed information in a coordinated way, and raising the profile of the issue of biodiversity and general environmental management.

However, the concern comes in exactly what such a statement would propose. If it were to prescribe a policy approach based on the currently dominant paradigm - of narrow analysis centred on the environment without reference back to broader issues covering social and economic factors; of a belief that use and protection are incompatible on the same land; and the attitude that communication ends with the claim that "mother knows best" - then the Institute would be very opposed. Such a Policy Statement would have to allow for local flexibility, a range of methods and philosophies, and can not entrench the dominant (some would say "urban myth") views of the human-nature interrelationship that currently hold sway (see section 2 for the relevant discussion). Stewardship is an idea that has to include human activity as well as the environment.

Much of the disquiet over national policy statements relate to the comments made about national accords. Credibility and trust is an issue.



6.3         Non-Statutory Guidelines

The Institute supports this initiative, which is important to achieving consistency and the consideration of the full range of options by local councils. Naturally, the councils will have many of the ideas already, and it is a matter of tapping in to that knowledge as well as the knowledge held by central government.



6.4         Additional Actions by Public Agencies

The Institute agrees with the four areas of work identified for immediate work: address information shortfalls; pest management on private land; funding and targeting of incentives; legislative review.

Incentives should not be considered in isolation from disincentives. It is at least as important to remove constraints (disincentives) as it is to provide incentives. The provision of incentives should also ensure that human motivators are considered. It is common for policy makers to assume a rational economic man approach. Maslow's hierarchy or even Hertzberg's motivators may be better models to use in approaching this issue, especially as so many of the reasons why people practice environmental management come down to personal decisions that may be unrelated to financial return.

The work on incentives also requires the examination of practices that lead to win-win situations. As discussed in the preamble above, trees and scrub planted or allowed to regenerate on marginal, erosion prone, farmland may actually be of benefit to the overall farm business, if only a systems perspective was applied instead of the sometimes single issue (agricultural production) emphasis that is still prevalent. This may mean re-educating the advisors.

The legislation suggested for review includes the RMA, Forests Act and Biosecurity Act. The Institute suggests that the Conservation Act is also relevant, in reference to the discussion on that departments tendency to work against the community. Often the result is poorer environmental outcomes than a more inclusive and broader-minded consideration might produce.

The relationship between the Forests Act and the Resource Management Act needs to be considered. The Institute's indigenous forests policy is to encourage ecosystem management, with disturbance at or near natural patterns and processes. This is a sophisticated approach to forest management designed to ensure maximum diversity.

The level of sophistication requires some specialist knowledge by resource planners. On the one hand the Institute believes that forest managers should only have to go through one set of requirements for resource consent approval. On the other hand, knowledge of forest ecosystem management applications requires expertise and monitoring, and the Indigenous Forestry Unit is itself not well funded to undertake its tasks. It is doubtful whether any councils have this expertise. If the Forests Act provisions were to be replaced with RMA provisions, then the latter concern of relevant expertise would have to be addressed. Despite what some may presume, indigenous forestry management requires considerable expertise.

Thank you for the opportunity to submit on this issue.



Chris J K Perley
Indigenous Working Group
New Zealand Institute of Forestry

References

Allen, R., K. Platt., S. Wiser, 1995: Biodiversity in New Zealand plantations.
NZ Forestry 39 (4): 26-29

Arnold, G.W. 1983: The influence of ditch and hedgerow structure, length of hedgerow, and area of woodland and garden on bird numbers on farmland
J Applied Ecology 20: 731-750

Benecke, U. 1996. Ecological silviculture: the application of age old methods
NZ Forestry 41(2): 27-33

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