Promoting excellence in science and technology
Submission on Timberlands West Coast beech management proposals by the Academy Council of the Royal Society of New Zealand
5 November 1998
Part 2. This document is divided into 2 parts; part 1 is here
3.4.15 Specific points of criticism
Monitoring should include soil conditions, bearing in mind low fertility and proneness to erosion on the slopes and impedance of drainage on flats.
Nutrient removal is one aspect of wood extraction and sustainable management. Assuming a total harvest of 3m3 ha-1 (which is half the gross increment) there will 45 m3 ha-1 every 15 years. Assuming a total above-ground biomass of 270 m3ha-1, the harvest would remove one-sixth of the total biomass which, in nutrient terms, is approximately: 150 kg N; 25 kg P; 83 kg K; 130 kg Ca; 17 kg Mg (Miller 1963, Nordmeyer 1993). These amount of nutrients are not large. For example, the P loss is the same as that contained in 250 kg ha-1 of superphosphate which is a standard annual topdressing rate for a lowland farm. Nevertheless, the nutrient loss is significant because of the low nutrient status of most of the soils, many of which are podzolised (Mew 1980). It cannot therefore be assumed that P and cations will be supplied indefinitely at the above rates by weathering processes. A fertiliser policy to restore nutrient levels appears to be required.
Pinhole; monitoring and some preventive measures are proposed, although there seems to be an expectation that severe problems will not be encountered. But what if they are? The same may apply to Inglesia. The seeming lack of contingency plans for possible biological catastrophes contrasts with the contingency procedures for blow-downs.
Training for Indigenous Forest Management: does the Logging and Forestry Industry Training Board carry this out themselves? If so, it seems a bit too in-house. What level of qualification will be achieved? Are the tertiary institutions involved?
The acceptability of the scheme will rest partly on how well research and pest control match the management aims. We feel there is too often a tenor of 'will be encouraged' as opposed to 'will be carried out'; e.g. in relation to research on impacts of management, predator and wild animal control, and wasp control. At least, there should be an assurance that research being done somewhere is providing applicable results. Animal control proposals seem naively passive, relying on private operators depending on recreation or profit, though extra efforts would be initiated for goats. Wasps receive minimal mention, considering that they may be the most serious predator of all for native biota.
These are public lands, and we believe that in respect of 'research into silvicultural systems', the "availability of data open to negotiation" is an unacceptable constraint on the public's right to know.
3.4.16 Merits of the Proposals
Vegetation
Beech forests are extremely resilient, and have a history of recovering from natural and man-made disturbances far greater than those proposed under the scheme. We believe that adoption of the scheme would allow survival of plant communities and vegetation patterns similar to those existing at present, though there will need to be control of introduced plants establishing along roads and on landings. Note, however, that improvement of tree quality and productivity as envisaged in the scheme refer to silvicultural, not ecological criteria; but to err in this direction is certainly better than risking a drift towards 'deterioration'. Note also that the supremacy of mining regulations remains a threat, as elsewhere.
Fauna
A more contentious question is whether, and to what extent, native fauna would be at risk. One argument that might be used in opposition to the scheme is that some animals, e.g. kaka and bats, have a very tenuous future, and the status quo may be a safer option than even a minimal logging proposal. There is evidence that many, if not most, of our endangered animal species have shown themselves capable of adapting to quite drastically modified vegetation. Predation and competition from introduced animals are the serious problems, posing threats that are orders of magnitude greater than those posed by the scheme. We suggest that the acceptability of the scheme, as far as fauna are concerned, will depend on effectiveness of control of introduced predators and competitors.
3.4.17 Forestry management techniques
The proposed indigenous forestry techniques are a considerable improvement on most methods previously used in the area. However, practicability, supporting evidence and auditability all give rise to concerns.
The aim to approximate natural gaps is commendable, and the report cites good independent and published work on gap characteristics in the area. It is not so clear how artificial gap formation would work in practice. It is hard to envisage exact calculation of areas from the ellipse formula on Maruia (page 46). It is easy to imagine that the prescription about taking accidentally-damaged trees would often increase the area of the artificial gap. One reason for natural multi-tree gaps is that opening of the canopy causes further mortality; this will occur with the artificial gaps too, often increasing the gap area. It seems likely that mean gap size would end up being larger than prescribed, though this may not be a major problem. This matter can be addressed in audits.
The tree removals are said to possibly lead to a situation that does "not deviate too significantly from the number of natural gaps". However, the coupes will be largely in addition to natural gaps.
Some of the prescriptions are specific enough to be monitored, but there are several vague ones, e.g.: "Trees will not often be felled on slopes steeper than 30 degrees" (e.g. Grey page 64): how often is "not often". Recommendation: The prescriptions should be made specific enough to be auditable.
It would seem sensible, rather than discuss the possible practicability and impact of the proposed logging technique, to try it on an experimental basis. It is claimed that there have been some "Detailed studies of the forests" (Overview page 94), including trials of "selection harvesting and careful felling". There is just one yellow area on the Maruia map (page 98) indicating a "logging coupe". However, results are not reported even for this. We are assured (Maruia page 57) that "TWC has made great progress with its podocarp management", but there is no reference or documentation. Recommendations:
1. Results to date from coupe-logging trials should be published.
2. Further trials should be initiated. The main logging should commence only when and if successful results are available for independent scientific assessment from such trials.
The report does not indicate the procedure to be adopted if its assumptions turn out to be incorrect. For example, suppose helicopter recovery turns out to be impracticable or uneconomic in this landscape: will the scheme revert to damaging overland extraction, or will logging be abandoned? Suppose tree growth is less than expected: will less timber be removed, or will less be left? Recommendation: The report should indicate the decision-making procedures to be used should it become clear that the prescriptions cannot be practicably implemented or achieved with an acceptable economic return.
3.4.18 The forest yield matrix model
The steady-state Leslie Matrix (or Usher) yield model is employed as a first approximation to deciding what quantity of resource (overall) can be harvested. TWC admit that they do not have key data on some inputs for the model (eg fecundity and mortality) and have employed approximations. However, these data are crucial to the use of the model for sustainable yield forecasting. We need to see the data and worked examples of its application in the model. Mortality, fecundity and growth rate data are needed for all size classes (including those currently below loggable size, because these rates determine recruitment into loggable sizes in future). We also need complete initial stage distribution data - while some approximations can be permitted in a research by management situation, TWC need to establish that their proposed cut levels are sustainable in the long term and this has not been been done. A problem with the model which is well recognised in the literature, but not addressed by TWC, is that it does not (in its simplest form) include any allowance for density dependent shifts in growth, survivorship and fecundity. As such changes are known to occur during logging how this weakness will be addressed should be discussed [we note that these models (and similar simplified approaches) were applied in New Zealand beech forests decades ago, and demonstrated that apparently 'dying' red beech forest was in fact self-sustaining. (Enright & Ogden, 1979; June & Ogden, 1978) ].
It is also not clear how gross increment was derived from the model (p147 SMP) - apparently this was a function of iteration of the model over 50 years. What is the significance of this period? How will the model output (in terms of proportions of trees in particular size classes) be translated into the actual selection of trees on the ground over a limited area?
Need for multi-species approach
The Leslie Matrix model is normally expressed as a single species population model, so that it will presumably be applied separately for the different beech species. Consequently the model cannot address the changing proportions of species in individual stands - a full transition matrix model is required for that. No doubt such "refinements" can be built in as data become available, but this simple approach must also be integrated somehow with a spatial model, and incorporate periodic destruction and density dependent changes to model parameters.
The "Usher model" (Maruia p. 75 ff; Grey p. 109 ff) is a standard stage-based projection matrix.
However, the parameterisation of the model is inadequate:
a. Progression between stages is based on data from tree rings. This is acceptable. However, there are some problems: (i) Historical effects and environmental changes are partly confounded with age. (ii) The survivor trees are measured, and not trees that die. (iii) Missing rings are not accounted for. The cited Norton papers, which established chronologies, used cross-dating to cope with missing and false rings; the present work apparently did not. (iv) The real values will differ between sites. (v) The data come from an unpublished report, which has not been peer-reviewed and therefore is not scientifically acceptable.
b. No attempt is made to estimate the stage-related fecundities that the model requires. Instead, a constant rate of recruitment is apparently used, and that based on arbitrary survival rates.
c. Mortality rates are apparently not estimated at all, or (it is unclear) are set to give a certain result.
Because of 'b' and 'c', the model given is not in effect used. The model indicates a willingness to use a scientific approach, but as it stands it has no value.
This, however, is irrelevant because a greater problem with the model is that it contains no density dependence, and is therefore inappropriate for the use to which it is put. As the report says (Overview p.141) it can be assumed that the present forests are in approximate steady state (i.e. intrinsic population growth rate, lambda ~ 1.0). Therefore, under the model any removal of trees will cause lambda to fall below 1.0, and the population to disappear. In practice, density-dependent effects will prevent this: growth rates will increase with more light, and mortality (which is unknown anyway) may be reduced. However, the model has no contribution on this.
In an equilibrium forest, growth is approximately balanced by mortality. The justification for using the model (Overview p.151) seems to be that harvesting can replace mortality. This is only partly true; natural mortality will occur in addition to harvesting, especially since large trees will be left, and only some of the natural mortality will be salvageable. Greater growth following tree removal will help fill the biomass gap. Mortality might be higher or lower with harvesting.
Ecologically, there is little doubt that the existence of a beech canopy will be regained some decades after tree removal (reports of recovery from clear felling support this), at least so long as exotic weeds do not intervene. Economically, the model (or another) might indicate the sustainable level of removal, but only with additional and density-related data.
Recommendation: The model should be disregarded in evaluating the proposal. The proposal should clarify what changes will be made if the projected timber yield proves to be unattainable, i.e. a reduced yield renders the project uneconomic.
Data records and model updates
TWC clearly regard their existing model an a working hypothesis which will be modified as additional data become available. The intention to select all trees before harvest, and to tag and record stumps on GPS for yield reconciliation is applauded. However there is a need to ensure that the data collected, and the model inputs are available to independent researchers. Acceptance of a sustainable logging regime is strongly dependent upon its independent validation.
3.4.19 Impacts on the biota and the environment
There are proposals for minimising Platypus populations. Unfortunately, they are based on McCracken (1994), which is unpublished. It is therefore not possible to judge how effective they might be. Likewise, the recommendations for minimising impact on fish and the lack of measures for reptiles (Ryan 1997 and Whitaker 1997) are based on unpublished reports (the status of Whitaker 1997 is not even indicated). The suggestions on invertebrates are based on "Evans, Keesing & Frampton (1996)", which is not in the bibliography. It is impossible to make a scientific evaluation of work that is not publicly available. Since these documents are dated 1994 to 1997, it would probably have been possible, if the work is of good quality, for it to have been published by now in a refereed journal. Recommendation: The scientific work on which the prescriptions are based should be published in independent, peer-refereed journals. No decisions of major significance should be based on this work until it is published.
There is a recognition of the need to maintain the stock of large trees and of dead trees. However, tree removal (including salvage) must reduce both of these in the long-term. Recommendation: The report should address this issue.
"Improvement" felling (e.g. Grey p. 97) will improve timber quality. However, it is possible that the trees to be removed, probably with low branching, may be especially valuable for epiphytic and animal wildlife. No evidence is offered on this. Recommendation: This issue should be investigated before Improvement felling occurs.
The intention to retain old trees as faunal habitat is commendable. The need sometimes to remove them for safety reasons (Overview page 83) is also understandable. Unfortunately, the latter will be overriding which means that they might all be removed, so that the ecological safeguard is removed. It means that retention of old trees cannot be guaranteed and thus audited. Recommendation: The report should indicate what will be done if its proposals regarding old trees prove impracticable.
3.4.20 Pest management
Despite the cautious sustainable forestry management regime proposed by TWC, there will inevitably be some negative consequences. However, if the regime is coupled with some determined mammalian pest control, the biodiversity of the native community may actually be enhanced. This would be the best outcome for all parties with an interest in the forests, given that sustainable harvesting is permitted. At present, the Plans fall short of definitive statements about devoting resources to control mammalian pests. Rather they refer to encouraging research into predator control as well as recreational and commercial hunting. The Plans should incorporate a commitment to actual predator and mammalian pest control.
It is stated that "eradication of goats and possums will be encouraged" (e.g. Maruia p. 102, Grey p. 142). However, there are no stated mechanisms for achieving or monitoring this, beyond "encouraging" commercial culling (which implies an interest in maintaining a population), and the possibility of "active management" (Maruia p. 72). There is no auditable target for animal pest control.
The problem of weeds is taken seriously. The dangers seem to be weed seeds taken in on machinery, tools and clothing, and spread along roads (new roads seem to be minimal in the Grey Valley). Only the latter is mentioned. The solution is 'regular roadside spraying' (Maruia p. 72; Grey p. 105). It is not clear that weed control is practicable by this method. There is no performance target in terms of weed control or impact that is capable of being monitored.
Recommendation: There should be auditable targets for animal and plant pest control.
The increased roading in the forests can be expected to enhance the likelihood of spread of weeds through the forest and into gaps. Although it is undesirable to restrict recreational access, it will be prudent for new roads to be gated and locked and regularly treated for exotic weed control.
3.4.21 Riparian management and roading control for stream health
Intact riparian forest is of great significance for the health of streams and wetlands and harvesting can have profound consequences. TWC sets out protocols for protection of riparian trees that are graded for three classes of streams. High priority streams (generally greater than 3m wide) will have a Streamside Management Zone of 20m on each side (no removing of trees within 5m of the banks), medium priority streams (generally 1-3m wide) will have a zone of 10m on each side (no removing of trees from stream banks) while logging will be permitted right up to low priority streams (generally less than 1m wide, often temporary streams). These protocols can be expected to provide some protection for stream health, particularly in maintaining natural temperature and light levels. However, there is a strong possibility of cross-ground flow of fine sediment and organic matter from extraction sites into the streams, particularly where riparian forest consists of large trees with little ground layer vegetation. The Streamside Management Zones must be considered minimal in extent (for example, best practice in the United States for what TWC call medium and high priority streams would be 300ft limited cut zones and and 75ft no cut zones on each side of the stream). The scale of potential inputs of nutrients, sediment and organic matter from small temporary streams is unknown but it is unwise to assume there will be no effect, as TWC (and US protocols) do.
TWC seems to be of the opinion that the geomorphology of stream catchments in the forests is generally such that because the streams rise quickly and flow fast they will carry away any augmented nutrients, organic matter and fine sediment. However, even in high-energy streams, pools may tend to fill with organic debris, leading to locally anoxic conditions (if only for part of the year) and the streams may not have the capacity to transport all the sediment. This may be particularly important where there is an appreciable hyporheic zone (organisms living within the sediments beneath the stream bed which can provide a significant proportion of fish food) if fine sediment leads to clogging of the interstices. The Plans mention areas where topography is very flat with poorly defined drainage - streams in such terrain will be much more prone to accumulation of fine sediments and organic matter from nearby harvesting. All these possibilities need to be tested by research and the results incorporated adaptively into protocols as necessary (for example, by having larger Streamside Management Zones in all or certain categories of medium and high priority streams and by incorporating such zones around low priority streams).
There is serious concern about the fate of small streams, a concern that permates the whole of the Timberlands report. Specifically, the report to Timberlands by Ryan on impacts of forest management on native fish discusses low, medium and high priority streams, amongst which low "can have a flowing channel of up to 1 metre during low flow conditions". Ryan comments that such streams "cover such a large percentage of every catchment that were riparian strips to be left ten metres each side of them, there would be little catchment left to harvest." That may be so, but given that these small streams are the sources of the water in all of the larger, medium and high priority streams then the potential for damage to "low priority streams" to cumulatively affect streams of higher priority is manifest and seriously threatens their viability. The concept of only protecting the riparian area adjacent to higher priority streams is therefore unacceptable if Timberlands is to meet its own management criteria for maintenance of aquatic values.
Furthermore (and here the Ryan report, and material derived from it in the Timberlands document, totally misses the point), such small streams are crucial habitats for some native fish, especially banded kokopu, possibly also lamprey spawning, plus a variety of others such as redfin bullies, longfin eels, etc. Hence there is concern about the proposal to allow felling to the margins of such streams, particularly as the Timberlands document explicitly states that felling will be allowed to the margins of low priority streams. It is not accepted that this can or should be allowed if Timberlands is to meet its own "biodiversity" commitments.
Neither the Ryan report nor the Timberlands document give any mention of the role of terrestrial (forest-sourced) invertebrates in the diets of many native fish, and evidence is accumulating that this is a very important role indeed (see: McDowall, 1990; McDowall, 1996; McDowall et al., 1996a; McDowall et al., 1996b; McDowall, 1997). Thus there is plenty of easily accessible information on this issue, reviewed up to the late 1980s in McDowall (1990), and added to since, that Ryan has not addressed. Overall, it is also suspected that integrity of forest cover may have high importance for some native fish, especially shortjaw kokopu (McDowall et al., 1996).
Ryan's report, upon which so much is based, makes not one mention of any species of bully (Gobiomorphus), and it is difficult to believe that there are none in the forest management area. Also, there is no mention of lampreys To that extent the report has glaring gaps.
The Timberlands report encouragingly talks of protecting the spawning habitats of fish by its management practices. While this may seem impressive and reassuring, the spawning sites of many species are as yet undiscovered, making it impossible to provide focussed protection of the appropriate habitats.
The Ryan report argues that "by definition, all the streams containing important native fish populations are considered high priority streams" but this is patently untrue, given that 1st and 2nd order streams which tend to be low priority streams by Timberlands classification have high importance for native fish. Moreover, there are relatively few sites where the fish faunas are really known, anyway.
The Ryan report accepts a criticism from DOC that surveys were not undertaken to assess the presence/absence or abundance of fish species within affected areas, by remarking "A valid point. They weren't, which is why the present report was commissioned". However, the Ryan report itself was based entirely on historic information available to DOC when it made that criticism (mostly from the NIWA NZ Freshwater Fish Database), so the point that was agreed to be valid by Ryan, remains just as valid. It remains true that no surveys of native fish have been undertaken in the Timberlands forest management area. All that is available is Ryan's incomplete and rather flawed analysis of someone else's data.
Timberlands' statement (3.2.2.2) that "The vulnerability of fish species in timber production forests almost universally relates to matters of water quality, sedimentation and temperature" is manifestly untrue. There are also issues of: Shade as a form of cover; Bank stability and instream woody debris as forms of instream cover; and terrestrial invertebrates as food, none of which get any or much consideration. Also there are changes in flow patterns, including greater flow fluctuations leading to higher peak flows and lower minimal flows following forest removal.
The absence of any mention of trout, and their habitat requirements is quite astonishing. Trout may be introduced, and predators that affect indigenous fishes, but they are also a resource that is highly valued by anglers and deserve some consideration. Moreover, the Resource Management Act specifically makes provision for protection of trout habitat.
In its prescription for forest harvesting practices, no detailed instructions or performance standards are give that provide for the facilitation of fish passage when structures are inserted into streams, such as flumes, culverts, bridges, and perhaps also for gauging weirs. This is essential and requires informed technical input.
Roading plans are generally acceptable in terms of minimising impacts on aquatic ecosystems except that ideally all stream crossings should have a culvert or bridge to prevent input of fine sediments, crushed gravels and nutrients.
3.4.22 Auditing/Accountability
The proposed monitoring programme seems flawed - e.g. there is no mention of aquatic ecologists being involved in that programme; moreover who chooses the monitoring team to ensure that the monitoring process is transparent and open?
Under the plan, the auditor is to be appointed by the Government, without any independent vetting. Recommendation: the auditor should be appointed jointly by the Government and an independent body such as the Royal Society of N.Z.
Under the plan, the auditor is required to have only forestry expertise. Recommendation: The auditor should have broad ecological (including aquatic), as well as forestry expertise.
The auditor has to report on whether the prescriptions are being followed. The prescriptions are intended to cover both forestry and environmental considerations. It may turn out that the prescriptions do not produce the intended results. The auditor is able to comment on whether the forestry aims are being met, but apparently not on whether the environmental aims (i.e. ecological sustainability) are being met (Maruia p. 14; Grey p. 17). This is especially a concern since the prescriptions are based on unpublished work. Recommendation: That the environmental/ ecological aims (achieving ecological sustainability) of the Prescriptions are being met" be added to the terms of reference of the audit.
"Forestry professionals" are to be used (e.g. Grey p. 91). However, the criteria for such persons are loose; they need only "be undergoing relevant training" (Overview p.115). Recommendation: The audit should include the quality of the "forestry professionals".
By our interpretation, TWC seem responsible for costs of aspects like animal control, much of which will be needed anyway as part of the regional management of the conservation estate (which seem to be seriously underfunded). These and other issues raise the question as to what might happen to the land if TWC decided that the scheme is not economically viable? Who will then assume responsibility for the basic wildland management? While recreational hunting and commercial trapping are to be encouraged there will almost certainly be other animal control needs, particularly as the market for possums skins is highly volatile.
We believe that the bottom line is the question of how effectively is the government going to (or can be forced to) underwrite these aspects of management.
If, for instance, there was a major earthquake, would the government have anything in place to assure rapid repair of ecologically threatening damage to roads installed in connection with this scheme,
It also raises questions as to what safeguards there might be in place if a privatisation deal is made.
While it is declared that research results should be in the public domain, there is the all-too-common qualifier of commercial sensitivity, which can easily be abused. Given that TWC may effectively have something of a monopoly, the need for this qualifier is doubtful.
3.5 Economic Aspects
Economic aspects of the TWC proposals, to comply with the Resource Management Act 1991, must fulfill the criteria of S5; "…..managing the use, development and protection of natural and physical resources in a way or at a rate which enables people and communities to provide for their social, economic and cultural well-being, and for their safety and health, while……."
The information released so far has very little economic content. However, what is said about "The Need for West Coast Production" in the Beech Management Information Pack is sensible enough. There is material on the total supply of commercial wood in "3.4 Commercial Resource" of the Overview Document and in s. 3.3. of the Beech Plan for each of the Maruia and Grey Working Circles. This information appears to be sensible enough but it does not provide the basis for an economic evaluation
Whether this proposal is economically sound depends on the
costs of milling and transport to road, rail head, or port and
of course on where the timber is marketed and in what volumes
and prices. There is little information on any of these questions
in the report.
Indeed, the material released by TWC is not sufficient to be the basis of an economic analysis. This is perhaps hardly surprising — TWC is a commercial operation although owned by the Crown and the management would normally discuss its economic plans only in general terms and would release even less information to the public. It would not expect to be the subject of economic evaluation by others.
Timberlands West Coast Ltd is in an unusual position because of the public interest in the West Coast beech forest options. It is committed to show compliance with the principles of sustainable management. Even so, it does not have to demonstrate to the public that the economic aspects of sustainable management are more than plausible. It does not have to satisfy anybody but its owner that it has a sensible business plan. We would not expect TWC to release any more economic information unless the Minister chooses to do so and persuades it that such a release will not be commercially costly or disadvantageous.
We believe that the public consultation is essentially on the basis that, given that TWC and its owner (the Crown) are satisfied that they plan a sensible economic use of the company's resources, can we (the interested/concerned public) be sure that this objective is being achieved within the principles of sustainable management.
The main concern with the economic aspects of the proposal is clearly in regard to market prospects. There has always been an impression that the markets for beech were relatively limited. This impression, if not in error, is certainly put in doubt by the statement on page 6 of the Information Pack, where it is stated that " .... beech is capable of producing a range of high quality wood products." However, this sole reference to markets in all the documents is scant evidence indeed.
There are opinions that there is no dearth of private entrepreneurs keen to get a slice of the action. Some people would say that from this we could safely assume that good potential markets exist. We presumably must assume that Timberlands have thoroughly explored and researched potential domestic or overseas markets to their satisfaction, and moreover, that such information, if it exists, is probably confidential to Timberlands. Even though it is an SOE and thus responsible to taxpayers, it would be commercially unwise for it to release the fine detail as to marketability. However, some broad brush views about markets could have been reasonably expected.
Questions of economic viability arise for several reasons but notably in the knowledge that the product will be very largely hard beech. The economic figures on p. xiii of the Overview Plan (which are very sketchy in themselves and unsupported by any reference) could be viewed as decidedly optimistic, particularly in the light of questions about the proportion of high-quality product. By contrast, rimu is a well-established timber in the marketplace, it is inherently well-behaved in processing, and has now acquired a scarcity value, but we still wonder about whether the beeches will be worth enough to sustain the cost structure that is likely to be entailed. There is the problem, until a timber is really well established in the marketplace: one cannot get a market until one has an assured adequate supply, and one will not get the supply until one has the market.
Looking at what is proposed, the physical procedures and the prescribed documentation and audit seem very intricate, raising serious questions as to whether they can really be adequately covered by the returns. Essentially nothing is said about this aspect. Operations such as manual clearing of understorey fern, treatment of stumps with urea, cutting up of defective trees that are felled, and the logistics of getting highly skilled crews into the scattered logging gaps at various stages, not to mention the detailed documentation itself, would all seem very expensive in relation to what would be extracted in the way of good logs. And while the network of roads required would be sparse, with no need for major logging decks, the roads and culverts etc. would still need to be up to logging truck standards while getting very little such use. As prescribed, the operations, as distinct from the level of exploitation and physical intervention, will not only be intensive of manpower, but of professional manpower.
For the scheme to be acceptable, some critical aspects of the proposals have to be taken on trust; in particular, there must be assurance that the constraints set will be adhered to, and even tightened if future events indicate such a need. However, we note an obligation to achieve 'commercially appropriate rates of return'. The various requirements of the scheme, including commitment to aerial logging, low rates of extraction, training of people, very detailed monitoring, and environmental protection, seem be quite onerous for a relatively modest venture. In the event of disappointing commercial returns, which of these requirements would be at risk of being diluted or sacrificed altogether? This is not clear in any of the several reports.
There is also the aspect of the supporting research, which will not come cheap. It appears that the Public Good Science Fund is being looked to, which raises some interesting accounting issues (which will be addressed later). In the Grey Valley document (on p.133, para. 2) we note reference in effect to hoping for university research "at low cost", which would hardly be calculated as realistic under current conditions.
On the credit side, some of the management inputs could be viewed as marginal to significant costs that would need to be incurred anyway, e.g. on regional control of noxious animals (including wasps). There would also be the aspect that the land would probably command no value for any permissible alternative use, such that land value would hardly belong as a capital charge against the enterprise.
While the breakup of the Forest Service for the most part created a 'clean' accounting situation, whereby costs could be sheeted home to narrow sets of closely defined objectives, we are looking at a residual, 'hard-core' area where no such simplistic solution is available. As mentioned earlier, there will presumably be some important management costs (e.g. on noxious animal control) that should be incurred regardless of the commercial exploitation. The same might be said of part of the monitoring costs.
When it comes to research costs things get very clouded indeed. In principle, one could identify costs of studies that pertain to the exploitation option, but in practice that will not be at all easy. It is said on p.18 of the Discussion Paper that "there is no clear distinction between research and management". Perhaps "demarcation" is a better word here than "distinction", and it could equally be applied to the various categories of associated research. Some at least of the research to be done would serve the regional conservation management, and some could be justified as basic research into our native biota, bearing in mind that it will carry opportunity costs in relation to other possible areas of research.
Despite the present emphasis on user-pays there is no doubt that the state still does a lot in the way of funding research of significant risk, and in building up and maintaining infrastructures. In an ideal democratic society the rationale and criteria for such decisions and the mechanisms for implementing them should be enunciated as clearly as possible. At the best of times, even when one knows just what fits where into the economic scheme, there are plenty of ways of fudging the issues. We do not know, for instance, what financial performance goals are being set for TWC and how the government would respond if those goals are not met.
3.6 Socio-economic considerations
The socio-economic rationale for the scheme (p. x SMP) is weak. The benefits of the proposals relative to plantation forestry and enhanced tourism are not adequately covered.
- The links between the existing forest landscape and tourism are not explored. There is an implicit assumption that tourists are concerned only with long-distance views which will be largely unaffected. As tourism currently employs more people, and earns more revenue (p. xi) than forestry on the West Coast, these interactions are a crucial component of the socio-economic justification for the scheme. Even the projected figures for the forest industry for the year 2006 indicate that it will remain below the current $ value and employment number of the tourist industry (cf. figures on p. xi and xiii, SMP). The two industries currently project strongly contrasting international images of New Zealand in tourist markets.
- A key socio-economic aspect is the time frame of the logging operation. Kit Richards is on public record as stating that Timberlands will remain in the business of indigenous logging only so long as it is profitable. This is not a sound basis for commencing a 'sustainable' logging operation. Moreover, this attitude does not suggest a long-term sustainable approach towards the well-being of local communities on the West Coast. Under "Present Industry Status" it is made clear that forestry is presently at the lowest point of a transition from unsustainable exploitation of native forest to plantation radiata, and that it will be unable to expand until "increased volumes of resource become available early next century". The implication is that the beech scheme will act as an interim measure.
- The aim of the scheme is to position the West Coat forest industry to take advantage of the high value of fine quality wood products (rather than timber) in a niche market. However, the entire beech resource base discussed in the scheme would account for only 20% of the total West Coast wood volume (p. xii, 3, SMP). It is thus a relatively small percentage of the total operation and presumably vulnerable to shifts in the economics of the other 80%.
- The TWC proposals involve the progressive conversion of large areas of undisturbed indigenous forest ecosystems into managed forests. People generally are aware of the fact that New Zealand has a history of forest exploitation, and that relatively little that can be called 'natural' remains. Although the proposals under consideration would not destroy the forest, and might even enhance it as habitat for certain endangered birds, they would certainly change its character from something approaching natural, to a managed system., in which (ultimately) every tree of loggable size will be numbered, and a decision made on if, and when, to fell it.
Posing the general question: "Do we need this scheme?" in the short term, we have to balance providing employment and economic opportunities for local communities against the wish of many New Zealanders to retain our surviving natural landscapes and particularly indigenous lowland rain forests, as near as possible to a pristine condition. If New Zealand were to adopt a policy of aiming for a stable population and economy, the decision could be made on these issues alone.
But there are considerations that apply over a longer term. Politically, New Zealand is currently committed to growth in population and economic activity. Ultimately, it will prove difficult to hold the line for absolute protection of natural landscapes where we have drawn it at the moment- just as it will be difficult to draw the line in other areas, such as hydroelectric development. From this perspective, allowing proposals that combine economic activity with protection of essential natural values may avoid pressures that currently threaten natural areas in many other countries.
3.7 Public participation in the scheme, and public perceptions
Despite the strong protestations of the protagonists of this scheme that they have paid attention to providing opportunities for comment and contact we do not believe this is the case at a national level. The difficulty of obtaining reports and numerical information, available only in the Timberlands Library, was one of the reasons why a group of concerned professional ecologists wrote to the minister at an earlier stage, questioning the sustainability of the scheme. Data crucial to the yield models, such as the growth increment data (W. McClunie 1997), have not been published; indeed of the 29 scientific studies commissioned by TWC since 1994 only two appear to have been published. Current documentation on the scheme is voluminous, repetitive and expensive. "Publication" on the internet does not automatically make it available to all concerned. Moreover, without access to colour printing facilities, it is impossible to obtain a meaningful hard copy to work on, as many of the diagrams rely on colour. Finally, the time frame for comment is unrealistic for national organisations relying on voluntary input by busy people employed in diverse capacities throughout the country (e.g. NZ Ecological Society, Royal Society of New Zealand!), given the detail and volume of the documentation, its very long gestation and significance to the national welfare, image and reputation. We endorse the PCE's request for an extension of time for submissions.
The TWC proposals tend to generate certain questions with many people. These include:
1. Is there a market for the timber? If not, why create one?
2. Why not use the large area of marginal farmland (currently under water and silt!) on the West Coast to grow trees? Eucalyptus and Cupressus, which have high quality timber can grow very well in that environment.
3. How many jobs will the proposal really create? How does this compare with the potential for tourism if this was equally supported by government subsidies?
4. It is often claimed (eg on p xi SMP, that being distant from ports, the local forest industry will never achieve low cost economies of scale achievable elsewhere. This applies equally to the beech scheme, so what is its justification?
These questions are not adequately addressed in the documentation provided by TWC for the beech scheme.
3.8 Conclusions and Recommendations
We appreciate the aims of the report. The proposed logging technique is an improvement over that used in virtually any previous logging of native forests in New Zealand. Many issues of ecological sustainability have been considered. However, we have considerable concerns. The case that the proposals, as prescribed, are both ecologically sustainable and economically viable at that, has not yet been adequately made.
3.8.1 Scientific evidence
All management decisions with ecological implications should be based on published scientific studies, (i.e. freely available in major libraries). The norm should be publication in peer-refereed journals.
3.8.2 Logging
Sustainability of logging, and the Forest Growth Model
We are not convinced, from the information presented, that the proposed logging rate of 10% every 15 years is sustainable. If the model is to be used to justify the proposed logging regime, it must be modified to include density-dependent effects, and inter-specific interactions.
Data must be obtained on:
a. stage-specific fecundity,
b. stage-specific mortality.
No plans or management decisions should be based on the model until this is done.
Logging practice
Results so far from coupe-logging trials should be published.
Further trials should be initiated. The main logging should commence only when and if successful results are publicly available from such trials.
The prescriptions must include installation of permanent plots before, or at least when, logging commences.
Forestry professionals
The prescriptions must specify training levels for forestry professionals, and who will do it.
The audit should include the quality of the "forestry professionals".
3.8.2 Conservation of ecological values
Inevitable loss of natural values
Once logging has commenced, the value of the forests as natural ecosystems will be irretrievably lost. The overall ecological impact will certainly be negative. The plans must make it clear that even with 'ecologically sustainable' logging there will be a definite loss of natural values, which need to be balanced against any economic gain.
Old trees
The prescriptions must include a model of how a reasonable stock of large, old trees (alive and dead) will be maintained.
The prescriptions must indicate what will be done if its proposals regarding old trees prove impracticable.
Nutrient budgets
The prescriptions must include mechanisms for assessing nutrient budgets, and for redressing any significant loss of nutrients from the ecosystems.
Streams
Issues of stream conservation are not adequately addressed, especially for small streams.
The prescriptions must be modified to give more protection to small streams.
Research must be initiated into the present biodiversity of streams (especially small ones), and into the measures necessary to preserve that biodiversity. Allowance must be made for the prescriptions to be modified in the light of that research, to give more protection if that turns out to be necessary to protect stream biodiversity.
3.8.3 Pest control
The prescriptions must incorporate:
- a commitment to actual animal pest control,
- contingency plans for pest outbreaks,
- more emphasis on wasp control,
- details of how weed invasion will be minimised,
- auditable target levels of plant and animal pest control.
3.8.4 Economic justification and contingencies
The proposal should justify its assumption that there will be a market for the timber produced, especially for hard beech, for which there has never been a market.
The proposal must clarify the decision-making process that will be used if:
a. the logging technique proves impracticable or uneconomic, or
b. the ecological measures to achieve sustainable management prove to be impracticable or uneconomic.
The prescriptions must indicate, should logging stop for economic or other reasons, who will be responsible for maintenance and restoration of the ecological values of the forests (especially pest control), and who will pay for this. They must indicate how plans for this contingency will be safeguarded should TWC be privatised.
3.8.5 Auditing arrangements
The auditor(s) should be demonstrably independent. To this end, the selection must be subject to approval by TWC, the government, and an independent body, such as the Royal Society of New Zealand.
The auditor(s) should have (or have available) ecological (terrestrial and freshwater) as well as forestry expertise.
The auditor(s) should report annually at least for the first two years.
The terms of reference for the auditor(s) should include auditing of "whether ecological sustainability is being achieved".
All prescriptions should be made specific enough to be auditable.
The results of the audit should be publicly notified and publicly available.
3.9 References
There are numerous papers on the application of transition matrices in forest dynamics, and at least two books on the subject.
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