National Environmental Standards for Plantation Forestry

The MPI has been consulting on proposed National Environmental Standards for Plantation Forestry.

The consolation document is enclosed:


The Association’s response to the consolation is given below:

PUA NES-PF submission

In summary the response stated:

“The aim of the standards does not seem to be to achieve a national environmental bottom line for forestry effects, but rather to eliminate “uncertainty” in planning rules to facilitate forestry. It does not seem concerned with whether the environmental outcomes are appropriate or fulfil sustainable management principles, but simply whether they are predictable.

Further problems regarding forestry were highlighted. There are issues of noise and dust, plus the impact of logging transport. There needs to be consideration of local conditions when dealing with these factors.

Whilst it is understandable that national rules would simplify matters for the forestry industry there are many differing environments within New Zealand and it would seem reasonable that local communities that understand the local environment should wish to contribute the planning and control of this environment.

It was not thought that the new proposals would deal with vrainces of logging sites. The harvesting rules do not sufficiently prohibit harvesting into and around waterways. While operators are to “fell away” from water ways, they are not required to do so when “unsafe or impractical”. A better condition that would promote waterway management would be a larger minimum horizontal set back from a river or stream, to provide for felling space well back from the river. A zone the size of the harvest height of the planted species plus two meters would be sensible. It appears that the requirements for roading earthworks do not allow the relevant authority to approve or reject the Erosion & Sediment Control Plan. It also appears that the operator can make signifigant amendments to the plan, without notifying the authority or seeking their approval prior to the amendment.

It is not clear how the coastal marine area is to be applied to forests that have a coastal boundary but are largely inland, as opposed to forests that are entirely coastal (i.e. Malborough Sounds). It is not clear what areas permitted activity conditions the local authority is allowed to be stricter on. The need to exempt costal marine areas is an example of why a national standard for permitted activity conditions, rather than base line environmental effects, is inappropriate.

The the Port Underwood Association does not feel that a permitted activity status for plantation forestry is approriate unless reasonable and valid control conditions can be set and enforced. The effects of plantation forestry carry far beyond the boundaries of the property on which the planting and harvesting takes place and can thus impact on local communities. These effects can include signfigant costs for instance increased maintence of country roads worn down by heavy logging trucks.

Given that, it is fair that local authorities representing those communities should retain the bulk of the authority and control over forestry.

It is our opinion that this document does not provide the means to establish and enforce the required controls that will minimise the adverse environmental effects of plantation forestry. The plan is:

  • Inadequate in avoiding land subsidence, setimentation and pollution of the coastal marine area of the Marlborough Sounds.
  • Inadequate in addressing the possibilities of affecting the visual amenities of the local area.
  • Inadequate in addressing the effects on public roads, such as, deterioration of the road surface by heavy vehicles, reduced safety to the public of large, heavy vehicles on small winding roads, and the noise of large vehicles traveling at inappropriate times of the night.”


The MDC has also submitted a response. This was:

MDC Draft Submission on MfE and MPI consultation document-August 2015

Subsequent to this the MPI has replied with an email on the proposed National Environmental Standard for Plantation Forestry (NES-PF) earlier this year.

Progress since consultation

Since consultation ended, the Ministry for Primary Industries (MPI) has been analysing the submissions made on the proposed NES-PF. We are working through the issues identified by submitters to revise the proposal. This involves working with key stakeholders, including councils, to test solutions for the revised proposal. We expect to provide a formal report back and recommendations on how to proceed to Ministers in mid-2016. More detail on the progress to date and next steps is available on the MPI website:

Release of submissions

In the New Year, MPI will release submissions on the proposed NES-PF on the MPI website. This will include the submission on the proposal that you or a member of your company/organisation sent to MPI.

As noted in the consultation documents and consultation page on the MPI website, all submissions are subject to the Official Information Act 1982 (OIA) and may be released (along with the personal details of the submitter) under the Act. This material requested that, if you have specific reasons for wanting to have your submission or personal details withheld, to set out these reasons in your submission.

All contact details, such as addresses, phone numbers and email addresses, will be removed from submissions prior to release using the grounds in the Official Information Act 1982 (OIA). In addition, if your submission requested that any other details be withheld under the OIA, then these have also been removed.

Please let me know by 5pm 11 January 2016 if you have any concerns about the release of this information. MPI will consider your views but may still decide to release the information.

Thank you for your contribution to this process. The issues raised during consultation have proven very useful to refine the proposal and ensure that the NES-PF will deliver its intended outcomes.