The forestry sector is important to Otago's economy. However, forestry can harm our environment, especially water quality.
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There is over 125,000 ha of plantation forestry which supports forestry personnel or contractors, seed and nursery suppliers, downstream sawmilling and manufacturing industries plus the export ports at Port Chalmers and Bluff. A majorityof this area is in pine plantations.
The forest industry consists of large companies such as Ernslaw One, Wenita, City Forests , Rayonier Matariki Forests, and Port Blakely plus numerous smaller owners and farmers who have forestry blocks within their farms.
As well as contributing to the Otago economy, Forestry has been viewed as having a positive effect on the environment by capturing carbon, reducing erosion on hill country as well as having moderating effects on water flows and providing amenity and biodiversity values.
However, all forests must be well-managed to ensure any adverse effects on the environment are managed. For example, assessing wilding conifer risk, establishing setbacks from roads, dwellings and waterways, and managing harvests. Harvesting presents challenges such as sediment affecting water quality from clear felling and the roading networks created.
It is important to understand how a forest and associated forestry activities are defined, as these will determine which rules and regulations apply. The following definitions meet the criteria of the NES-CF Regulations.
Commercial/Plantation forestry refers to any forest that has been deliberately established for commercial purposes which has been or will be harvested or replanted. This applies to all continuous forest cover of forest species larger than 1 ha in area and includes all associated forestry infrastructure.
It does not include:
- a shelter belt of forest species, where the tree crown cover has, or is likely to have, an average width of less than 30m
- forest species in urban areas
- nurseries and seed orchards
- trees grown for fruit or nuts
- long-term ecological restoration planting of forest species
- willows and poplars space planted for soil conservation purposes.
An exotic continuous-cover forest is one that’s deliberately established for commercial purposes. It is at least one hectare of continuous forest cover of exotic forest species that has been planted and:
- will not be harvested or replanted
- is intended to be used for low intensity harvesting or replanted
- includes all associated forestry infrastructure.
It does not include:
- a shelter belt of forest species, where the tree crown cover has, or is likely to have, an average width of less than 30m
- forest species in urban areas
- nurseries and seed orchards
- trees grown for fruit or nuts
- long-term ecological restoration planting of indigenous forest species
- willows and poplars space-planted for soil conservation purposes.
Exotic continuous-cover forestry is subject to all of the regulations that apply to plantation forestry. Indigenous continuous-cover forestry is not subject to the regulations.
| Term | Definition |
|---|---|
| Afforestation | Means planting and growing commercial forestry trees on land where there is no commercial forestry and where commercial forestry harvesting has not occurred within the last 5 years. It does not include vegetation clearance from the land before planting. |
| Earthworks | Means disturbance of the surface of the land by the movement, deposition, or removal of earth (or any other matter constituting the land, such as soil, clay, sand, or rock) in relation to commercial forestry, including:
|
| Forestry Quarrying | Means the extraction of rock, sand, or gravel for the formation of forestry roads and construction of other commercial forestry infrastructure, including landings, river crossing approaches, abutments, and forestry tracks. This includes the extraction of alluvial gravels outside the bed of a river, extraction of minerals from borrow pits, and the processing and stockpiling of material at the forest quarry site. It does not include earthworks, mechanical land preparation, or gravel extraction from the bed of a river, lake, or other water body. This applies to quarrying located within a commercial forest, or on adjacent land owned or managed by the owner of the commercial forest. |
| Harvesting | Means felling trees, extracting trees, thinning tree stems and extraction for sale or use (production thinning), processing trees into logs, or loading logs onto trucks for delivery to processing plants. It does not include milling and processing of timber, or clearance of vegetation that is not commercial forest trees. |
| Replanting | Means the planting and growing of commercial forestry trees on land less than 5 years after commercial forestry harvesting has occurred. |
| River Crossing | Means a structure that is required for the operation of a commercial forest and provides for vehicles or machinery to cross over a water body. This includes a ford, an apron and other structures and materials necessary to complete a river crossing. It does not include a stormwater culvert or a culvert under a forestry road or forestry track. |
The National Environmental Standards for Plantation Forestry (NES-PF) came into effect on 1 May 2018. This was amended to the National Environmental Standard for Commercial Forestry (NES-CF) on 3 November 2023, adding exotic continuous-cover forests (carbon forests) to its scope.
The Regional Water Plan also applies in some instances where a regional rule is more stringent than a national rule (the NES-CF), listed within Schedule 17. These stringent rules relate to sediment discharges and bed disturbance to protect threatened indigenous fish (i.e galaxiid species), many of which are found only in Otago.
If the intended forestry activity does not meet the criteria of ‘commercial forestry’ or ‘exotic continuous-cover forestry’ (i.e the harvesting of wilding pines), NES-CF regulations do not apply. However, existing district and regional plan rules will apply to the activities and effects outside the scope of the NES-CF. For further assistance, refer to the flowchart.
The NES-CF regulations aims to:
- Set out technical standards, methods or requirements relating to matters under the RMA; and
- Provide consistent rules across the country by setting planning requirements for certain specified activities.
Activities:
These regulations cover eight commercial forestry activities:
- afforestation*
- pruning and thinning to waste
- earthworks*
- river crossings
- forest quarrying *
- harvesting*
- mechanical land preparation
- replanting*
Notification:
Before some of these activities can take place, notice must be provided to regional council (and in some cases district council). Notifiable activities are defined above within ‘Forestry Definitions.’ Some activities may also require the submission of additional information, such as ‘Wilding Tree Risk’ calculations.
Planning:
A management plan is required for certain activities (indicated with an asterisk above) before commencing work. These plans must be in accordance with schedules 3–6 of the NES-CF, depending on what activity you are undertaking.
MPI have developed several risk assessment tools to assist in planning activities. These are found within schedule 2 of the NES-CF, including:
- Erosion Susceptibility Classification
- Fish Spawning Indicator
- Wilding Tree Risk Calculator
Most forestry activities are permitted by the NES-CF so long as foresters meet specific conditions designed to protect the environment. If foresters can’t meet these conditions, they need to apply for a resource consent.
The Regional Water Plan holds more stringent sediment discharge rules to the NES-CF and requires that you obtain a resource consent for any river bed disturbance activity (excluding river crossings), such as cable hauling through ephemeral waterways. If foresters can’t meet these conditions, they need to apply for a resource consent.
| National Environmental Standards for Plantation Forestry (Part 2) | Regional Plan: Water for Otago |
|---|---|
| Subpart 1 – Afforestation All regulations apply |
Not applicable. |
| Subpart 8 – Replanting All regulations apply |
|
| Subpart 2 – Pruning and thinning to waste All regulations apply |
Chapter 12: Rules Water Take, Use & Management 12.C Other discharges
|
| Subpart 3 – Earthworks All regulations apply, except 26 replaced (see opposite and 13.5 rules below in relation to ephemeral rivers) |
|
| Subpart 5 – Forest quarrying All regulations apply, except 56 (1) replaced (see opposite) |
|
| Subpart 6 – Harvesting All regulations apply, except 65 replaced (see opposite) |
|
| Subpart 7 – Mechanical land preparation All regulations apply, except 74 (6) replaced (see opposite) |
|
| Subpart 9 – Ancillary activities All regulations apply, except 90 replaced (see opposite) |
| National Environmental Standards for Plantation Forestry (Part 2) | Regional Plan: Water for Otago |
|---|---|
| Subpart 3 – Earthworks All regulations apply (except 26 replaced, see above). In addition to 28(2), 13.5.3.1 rule opposite also applies for ephemeral flow paths |
Chapter 13: Rules: Land Use on Lake or River Beds or Regionally Significant Wetlands 13.5 Alteration of the bed of a lake or river, or of a Regionally Significant Wetland
|
| Subpart 4 – River Crossings All regulations apply. In addition to 44, 13.5.1.1(g) rule opposite applies, if this rule cannot be met then 13.5.3.1 applies. |
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| Subpart 6 – Harvesting All regulations apply. In addition to 68(3), rule 13.5.3.1 opposite applies if logs are to be dragged through streams less than 3 metres wide. |
|
| Subpart 9 – Ancillary activities All regulations apply. In addition to 89, 13.5.1.1(g) rule opposite applies, if this rule cannot be met then 13.5.3.1 applies. |
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| Subpart 10 – General provisions All regulations apply. In addition to 97, rule 13.5.3.1 opposite also applies to any bed disturbance outside fish spawning seasons as defined by the Fish Spawning Indicator. |
If you are undertaking certain commercial forestry activities, notification must be provided to regional council (and in some cases district council). You can notify us via the web portal below.
| Regulation and Activity | Written Notice of | Timeframes |
|---|---|---|
| Regulation 10 – Afforestation |
|
Notice must be given at least 20 working days and no more than 8 months before the date on which the afforestation is planned to begin. |
| Regulation 25 – Earthworks | If earthworks involve more than 500m² of soil disturbance in any 3-month period, the relevant regional council must be given written notice of:
|
Notice must be given:
|
| Regulation 38 – River Crossing |
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Notice must occur at least 20 and no more than 60 working days before the date on which the river crossing activity is planned to begin. |
| Regulation 52 – Forestry Quarrying | If the volume extracted from a forest quarry exceeds 200m³ in any calendar year, the relevant regional |
Although harvesting only has a small impact over the life of a forest, its short-term impact can damage the environment and breach Water Plan and NES-CF rules.
- Sediment and debris can enter waterways during harvesting, which can damage aquatic habitat.
- Excessive woody debris can damage streams and reduce the amount of oxygen available.
- Heavy machinery can damage soils, vegetation, habitat, and stream banks and beds.
- Leaving unstable or older trees in riparian zones can be destructive if the tree roots lift and destroy the stream bank.
- Poor harvesting techniques, such as dragging logs through a waterway, can damage the bed and bank and release sediment into the water.
- Harvesting can cause soil erosion and sediment entering waterways.
Perhaps amend below – refer to the forestry guide page?
The Ministry for Primary Industries (MPI) has developed resources to guide forestry activities. Most of the guidance from the older NES–PF is still relevant. Each activity guide explains the relevant NES-PF regulations, including:
- the activity definition – what is and isn’t covered by the NES-PF
- the conditions you must meet for that activity to be permitted
- how to determine whether you need resource consent
You can find more guidance on the MPI “Guidance for forestry activities" page here for all forestry activities.
The New Zealand Forest Owners Association (NZFOA) also have resources available on Best Practice Guidelines (BPGs) and road engineering for commercial forestry operators. These resources can be found here.
Your own forestry industry can be of help too.
Southern Environmental Working Group
Providing the forestry industry a chance to collaborate, share and learn alongside our regulators to improve our relationships.
NZ Farm Forestry association
A community of people that have been growing trees in New Zealand since 1957
NZ Forest Owners Association
Forest Practice Guides published to assist forest owners/managers and contractors to meet legislative requirements.
Our role is to make sure you adhere to the Resource Management Act 1991.
If the rules are broken and the environment is harmed, we have the options shown in the "Enforcement Process" flowchart.
The following activities might breach the water quality rules:
- Work that exposes soil, such as forest harvesting, site development earthworks, cultivation, or using sacrificial or fallow paddocks. These activities are prohibited unless sediment discharge is controlled.
- Working in waterways.
- Skid and slash pile failures (bird nests).
- Slash mobilised to waterways.
- Depositing and leaving slash in waterways.
For more information, please contact forestry@orc.govt.nz or ask for our Compliance Team on 0800 474 082.
Our Water Plan and the National Environmental Standard for Commercial Forestry (NES-CF) are documents that regulate forestry activities in Otago, to protect our freshwater resources and ecology.
Water plans and policies
Water is the first priority of the Otago Regional Council. Our Regional plan and Land & Water Regional plan are two documents that we use to help develop rules and regulations which will help communities protect our water for generations to come.
Resource Management (National Environmental Standards for Commercial Forestry) Amendment Regulations 2023
Resource Management (National Environmental Standards for Commercial Forestry) Amendment Regulations 2023
