Forestry a permitted activity?
Barry Gilliland, New Zealand Tree Grower August 2014.
Forestry is a ‘permitted activity’ in the Manawatu - Whanganui region now that the rule has been approved by the Environment Court. But how can forestry be a permitted activity? Those who ask me this question doubt it will work out well in practice.
The answer is that forestry interests convinced everyone that the industry could be trusted to use good practice and operate without significant adverse environmental effects. It is now time for the industry to prove that in practice.
The permitted activity rule covers forestry and any ancillary disturbance of the bed of a river or lake, diversion of water on to land, and discharge of sediment into water or on to land which may enter water, provided that 17 permitted activity standards are met.
It seems that people hear the words permitted activity and think they can do what they like. That is potentially a costly mistake. There are 17 standards to meet before the activity is permitted and these cover managing earthworks, harvesting and re-vegetation after harvesting. Forestry interests played a major role in drafting the standards so they should be achievable. The purpose of the standards is to −
- Minimise sediment and debris discharges
- Minimise damage to watercourses and their margins
- Avoid damage to indigenous biodiversity habitats.
If it is not practical to meet the activity standards, forestry is not a permitted activity but can still be pursued under a resource consent.
Successful implementation depends on a number of factors. The first is the development and use of an erosion and sediment control plan which describes how the permitted activity standards will be met. It can be tailored to the scale, complexity and environmental risks of the site. At a basic level it will contain the harvest plan, an erosion and sediment loss risk assessment and specify the best practice methods to manage those risks.
The second factor is the use of industry best practice. The industry has developed guidelines and it is expected they will be used to meet activity standards. When industry best practice is used to meet these standards it is expected that the environmental effects of forestry activities will be minor.
It is also important to have early communication with Horizons’ land management officers. It is a rule requirement that the Horizons Regional Council be notified at least 48 hours before the activity begins. Land management officers are the first point of contact and can help with information about erosion risks and the status of waterways under the plan.
Horizons will work with the forestry industry to successfully implement the permitted activity rule for 12 months. This is seen as an appropriate transitional period to ensure the permitted activity is bedded in and achieving its purpose. We also need to be confident, and able to demonstrate to others, that the industry can comply with the activity standards. In the short term this means erosion and sediment control plans will be requested more often than not, and operations adjacent to watercourses will be routinely monitored.We intend to reduce this once everything is running smoothly.
Small-scale forestry improvement
It appears that the large corporate forestry companies are well positioned to fulfil the requirements of the permitted activity. The problem for the Manawatu - Whanganui region is that harvesting is dominated by smaller harvesting and marketing companies. These companies are more entrepreneurial in nature, deal with smaller forest blocks, and are subject to more delicate balances of profit and loss. It is these smaller companies whose performance has been patchy.
The most obvious room for improvement is notifying the council 48 hours before activities begin and have an erosion and sediment control plan available. These are basic requirements for the permitted activity and leave harvesting operations vulnerable when not met. For example, if Horizons is not notified 48 hours before harvesting starts, in theory the activity is not a permitted activity and a discretionary consent is required. I do not expect that anyone wants to go down that track.
These are early impressions and it is unfair to be too critical of performance. The Council intends to give the industry every chance to make the permitted activity work and is keen to provide whatever support is needed to do that. You can contact Horizons Regional Council on 0508 800 800 or email email@example.com.
Barry Gilliland is a PolicyTeam Member at the Horizons Regional Council.