The document was put together by Federated Farmers national board member and Gisborne farmer Toby Williams, who noted that Gisborne District Council (GDC), through a lack of resources, had not ensured that some forestry companies had undertaken their harvesting operations in a responsible manner.
For example, in the case of Juken NZ, the GDC had not inspected the forest to ensure Juken was complying with the terms of its consents for at least five years.
“The failure of GDC to monitor and enforce consent conditions is inexplicable,” the submission states.
“While accepting that the GDC is resource-limited, Federated Farmers members, as ratepayers, expect that future monitoring will properly reflect known risk factors with timely, and — similar to all other consent holders — appropriate enforcement where required,” Mr Williams wrote.
“We simply cannot afford to have large amounts of forestry slash left on hillsides following harvesting any more.”
One solution could be a return to the burning of slash, the submission suggests.
This used to take place but is no longer practised due to GDC land use consents.
“While not a preferred practice, is burning slash in sites and situations where all other options to reasonably reduce load catchments upstream of homes, farm infrastructure and public infrastructure have been employed appropriate? A least worst solution?
“A recommendation from this inquiry to align policy and funding initiatives to work to realise the bioenergy potential of the region’s problematic slash resource would bring economic development and potential for environmental harm benefits,” Mr Williams said.
“However, it is recognised removing slash to be turned into biofuels doesn’t stack up financially and care is needed to not expend more energy transporting the slash than can be gained from the slash itself.
The submission notes that slash traps have been used in forestry as an additional risk management measure.
“However, engineering design and performance have been variable, both in structural integrity and a commitment to cleaning up after significant weather events.”
While reducing harm to assets and infrastructure resulting from slash mobilisation is a “near-term imperative”, the submission says, “all parties must refocus on hill country erosion reduction and mitigation”.
“The erosion risk potential of the region is very well understood. Soil conservation work has been a regional focus since at least the 1960s. For some farming families this effort goes back to the 1930s.”
The Feds submission pointed out that erosion control plantings and structures have improved the stability of large areas of farmland and production forests, including those forests where management and harvest practice must improve to avoid and mitigate the slash risk.
“Yet, much remains to be achieved in the region and in the wider North Island hill country. Farms with existing annual soil conservation work programmes must be enabled to continue their efforts and new work programmes progressed for identified risks.
“It is also sensible that high erosion-risk areas of farms and forests should be retired and transitioned to appropriate permanent woody vegetation. This will require difficult decisions to achieve long-term risk reduction.”
The submission notes that soil conservation work programmes were expensive and that taxpayer subsidy assistance was no longer available.
“A long-term commitment to a soil conservation work programme that also brings a commitment to ongoing pest management and maintenance costs is required, well beyond the establishment phase.
“The Crown-funded Horizons Regional Council Sustainable Land Use Initiative (SLUI) and the national Wilding Conifer Control Programme provide a couple of useful templates for such a programme.
“It is important to take into account the significant economic loss and the potential environmental risks for the region associated with funding and operational policies, and/or regulatory requirements that artificially incentivise permanent exotic forestry over production forestry,” Mr Williams said.
“To do so may simply push the forestry debris problem out a few decades as the risks associated with individual fallen trees increases and the risk of total forestry slope collapse increases when the sheer weight of trees exceeds the ability of the soil to hold the trees.
“Incentivising permanent exotic forestry also increases fire, pest and disease risks for forest owners, neighbouring landowners and local communities and the ultimate risk of abandoned forests with no owners (due to company liquidations) or owners unable to meet their obligations including local body rates.
“If the report and recommendations of the inquiry becomes another unactioned chapter of an already large library of programmes and publications dealing with land use in the region, the resources and effort of all who have contributed will be a waste.
“A commitment to action is required. This means full progress towards required soil conservation outcomes identified by the Taylor Report published in 1970. The report, which identified erosion on the East Coast, called for some land areas to be put into forestry.
“Subsequent investigations and funding programmes are beyond the funding reasonably available from the community, including ratepayers.”
