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Does the NES-PF adequately regulate forestry on orange (high) ESC land? An opinion

Authors: , Mark Bloomberg
Publication: New Zealand Journal of Forestry, Volume N.Z.J.For. 2022, Issue N.Z.J.For. 67(3) 2022, pp 20-25, Nov 2022

Abstract: The National Environmental Standards for Plantation Forestry (NES-PF) has largely achieved its goal of nationally consistent Resource Management Act 1991 (RMA) planning and compliance requirements. However, no system is perfect and it has become clear that the NES-PF has three shortcomings. First, the NES-PF allows clearfell harvesting, and in some cases earthworks, to be a permitted activity on land zoned as high (orange) in its Erosion Susceptibility Classification (ESC). Controlled activity status should be the default minimum for earthworks and clearfell harvesting on orange ESC land, as these activities may not meet the threshold for permitted activity status on land highly susceptible to erosion. Secondly, the NESPF and guidance documents do not adequately address problems with the scale and accuracy of mapping for the ESC and the need for landslide hazard mapping by qualified geoscience professionals. Finally, the NES-PF lacks a formal landslide and erosion risk management framework. The NES-PF and published guidelines conflate erosion susceptibility, landslide hazard and landslide risk, which are distinctly different concepts.