The Resource Management Act and Forest Amendment Act - Barriers to Planting and Harvesting
- "The process of applying for a Sustainable Management Plan (SMP) or Permit is a positive process that encourages forest owners to consider all aspects of sustainable management in the spirit of the Resource Management Act (RMA) and Forest Amendment Act (FAA). The issues of costs, uncertainties and time delays however need to be addressed.
- The processes for developing plans are extremely costly (some of our members paying in the order of $20,000 plus) with high levels of uncertainty in regards to outcome. The criteria against which an indigenous forest is assessed, to establish whether a management plan is appropriate, can appear to an applicant ad hoc and inconsistent. As a result a landowner is unable to establish whether a management plan is likely to be approved without actually going through the costly process.
- Further the time and cost to obtain a plan mean that large amounts of timber must be available to make it economically viable. This both precludes many small woodlot owners from seeking SMPs, and encourages forest owners to harvest a greater amount of timber than would initially be necessary.
- There is no clear association between the SMPs and the RMA. Whilst the FAA provides that any plan or permit is subject to the relevant planning provisions of the RMA, local authorities have not been consistent in their approach to SMPs. Some local authorities have adopted the requirements of a permitted activity under the RMA, while others require resource consent. This appears to suggest it is not clear whether a SMP fully meets the requirements of the RMA, and creates a duplication of unnecessary cost and uncertainty of outcome.
- We believe that SMPs should be a permitted activity under local authority plans.
- SMPs are subject to an extremely rigorous process that requires specialist knowledge. While the plan or permit is not subject to public input under the FAA it nevertheless is subject to scrutiny from DoC who may recommend areas for protection. The process must also take into account areas set aside by local authority plans for issues such as landscape, significant natural areas and riparian margins. Public input requirements create uncertainty for the SMP applicant and generate considerable financial risk for the applicant.
- An assessment of an indigenous forest for a harvesting plan or permit should be inclusive of meeting all legislative requirements, including the RMA.
- We advocate that MAF should continue to process, manage, audit and enforce the FAA provisions to ensure the sustainable management of indigenous forests and potential forest sinks in New Zealand. Increased staff resources and training will allow more efficient processing of applications and reduce time delays.
- We support removing the barriers to the planting and harvesting of indigenous forestry to increase confidence for those who wish to harvest and those who have concerns regarding the protection of conservation values."
Contact for Enquiries
MAF Information Services
Pastoral House
25 The Terrace
PO Box 2526
Wellington, NEW ZEALAND
Fax: +64 4 894 0721
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