A National Policy Statement for Indigenous Biodiversity has been drafted and submissions are sought. Joanna Grigg offers her suggestions.

I’m not a fan of monoculture.

I can see the sense of having diversity in an ecosystem; especially including indigenous species which may not be found elsewhere in the world. A mixed sward is my preferred pasture any day; for stock and under grapevines which are a monoculture along a wire. Swathes of coprosma and kanuka across a hill block don’t look untidy to me. It’s protection for nesting birds.

But promoting biodiversity takes money. It needs a profitable landowner who can afford to exclude some areas from grazing, and pay the control bill for broom, gorse, barberry, nassella, wilding conifer, possum, old man’s beard or goat year after year.

A land manager needs to recognise species and know the landscape inside out; to respond to pest and weed incursions. They need to notice and care that populations of birds or plants are disappearing from pockets of scrub. A land manager needs skin in the game; to want to promote shade down a stream and keep the cattle out of regenerating bush because they live and picnic on site.

My ideal land manager to promote biodiversity is a farmer. Not someone far away in an office with a map and a transitory job term. The office worker may care a lot but nothing replaces living onsite and controlling the cheque book.

The ideal way to get a farmer to improve their biodiversity management is education, clear guidelines on best practice and a baseline of regulations to stop bad behaviour. This should be backed up with ongoing financial incentives. Not just a couple of thousand dollars as a one-off.

This weed and pest work shouldn’t follow lines set by significant natural areas (SNA) classifications, although these distinctions can help identify precious areas and focus work. Farmers don’t see lines on a map when they manage their farm; it’s one big beast with movement of plants and animals across, over and through.

This is what I’ll be suggesting in my submission on the National Policy Statement for Indigenous Biodiversity.

In 2018/19 the average weed and pest spend on New Zealand sheep and beef farms was about $18,000. This does not include capital and maintenance fencing or tree planting, nor losses from grazing exclusions. We need a new column for biodiversity management in our farm accounts.

I agree with creating uniform rules. The current approaches vary in style, from being stated in plans or through resource consent conditions. For example, some councils identify and map their plans with community involvement, while other councils do not identify SNAs until a landowner or developer applies for a resource consent that may disturb indigenous vegetation or habitat of indigenous fauna. Litigation and wasted resources often result.

A uniform SNA classification system is proposed. SNA (medium or high value of indigenous biodiversity) would be mapped by each council (or authority) by 2026 – a desk exercise with ground visits where possible.

Looking at the Economic Impact Report, the amount of private land potentially tagged as SNAs won’t be huge on most farms but is still significant. The area of general land (which is private land) expected to have a SNA classification varies in the economic impact report; for example Tasman 28%, Waikato 9%, Westland 30%, Far North 26%.

Some farms will have large tracts marked as SNAs, especially high-country farms with preserved indigenous cover. Farmers who have been conservative in their land development are precisely those that should be rewarded for their work protecting biodiversity.

To get landowners on board with SNAs there must be monetary incentives to do the weed and pest work, to fence them and keep them maintained. After all it is for the public good so should be drawn from public funding.

Within the SNA, farm activity effects would be judged according to an effect management hierarchy. This is different to the outcomes-based approach recommended by the Biodiversity Collaborative group.

At the top of the hierarchy is ‘avoiding adverse effects’. This seems tricky. Can some indigenous species be cleared if it’s obviously adverse on that plant but perhaps not the population viability of plants in the area?

Biological offsetting is proposed as an option (take in one spot but give in another) but offsetting is ranked lower. This may fit quite well for farmers however who are prepared to let one area recolonise with indigenous species if they can clear another area. This is where a farm environmental plan is a powerful tool. Appendix 4 (page 42) is worth reading and submitting on.

It’s proposed that farmland outside SNAs also be managed by the effects management hierarchy. It should be more flexible however because there is no requirement to avoid key adverse effects. Instead, adverse effects should be avoided where possible. If land borders an SNA there may need to be an environmental assessment before an activity goes ahead, however.

One area that may be contentious is what is defined as a regular spray cycle. The discussion document definition up for discussion is; spraying indigenous plants is allowed as long as the regenerating indigenous vegetation has not itself become an SNA in the time since the last clearance event.

Periodic clearance of indigenous vegetation as part of a regular cycle to maintain improved pasture is unlikely to compromise the protection of SNAs or the maintenance of indigenous biodiversity; and c) consideration of effects (under Schedule 1 of the Act or through a resource consent application) may be required in the following circumstances, to ensure the outcomes in subclause (2) are met:

• a proposed clearance is likely to have adverse effects that are greater in character, intensity or scale than the adverse effects of clearance that has previously been undertaken as part of a regular cycle to maintain improved pasture on the farm.
• There is inadequate information to demonstrate that a proposed clearance of regenerating indigenous vegetation is part of a regular cycle of clearances to maintain improved pasture.
• a clearance is proposed in an area that supports any threatened or at-risk species.
• a clearance is proposed in an area that supports alluvial landforms that have not been cultivated.

That may take a few minutes to digest!

It seems you can spray to maintain the status quo but will be tricky to go beyond (i.e: remove older bush/scrub on country). A guess would be that the farmers with regular spray/burn or mulch programmes will get the go-ahead more than those that did nothing for 20 years.

Dairy and pastoral farms cover about 50% of NZ and about 17% of indigenous forest are on these farms. The farming process has stripped areas of indigenous cover but many farms have maintained and even created a patchwork of indigenous landscapes within a power-house food and fibre-growing hub.

Understanding of the flora and fauna and why it’s important to NZ Inc. makes farmers more likely to tag a few thousand in the budget to enhancement.

Farming should not be seen at odds with promoting biodiversity. I agree with the policy objective that local authorities must recognise maintaining biodiversity does not preclude subdivision, use and development in appropriate places and forms, within appropriate limits.

The strategy has as an objective to recognise the role of landowners, communities and tangata whenua as stewards and kaitiaki of indigenous biodiversity by allowing people and communities to provide for their social, economic and cultural wellbeing now and in the future.

We’ve all seen those weed-infected areas of public land – along roads, waterways and the struggle on DOC-managed land to combat broom, gorse and wilding pines with a budget that doesn’t match the work needed. It’s common for farmers to spray adjacent public land to help keep out weeds, out of their own pocket.

This is why farmers need to shout from the rooftops about what they are spending on weed and pest control on their land, plantings of new habitat and protection of stream, bush and soil life. Create a code for biodiversity work in your farm accounts to track it. Let’s push for a Policy Statement that gives more recognition and assistance to carry on doing it.

What is the draft National Policy Statement for Indigenous Biodiversity?

It sets out the objectives and policies to identify, protect, manage and restore indigenous biodiversity under the Resource Management Act 1991 (RMA).

It builds on a draft created by the Biodiversity Collaborative Group (Federated Farmers and NZ Forestry Owners were involved). It has been developed by the Ministry for the Environment and the Department of Conservation.

Consultation closes 5pm, March 14, and policy decision is due mid-2020. Federated Farmers will run sector meetings on the topic in February.

Carrot better than stick

Professor David, Norton, School of Forestry, University of Canterbury, believes improving biodiversity management comes from education and engagement with landowners, not just more rules and regulations.

He said exactly this during his presentation to the Biodiversity Collaborative Group panel in 2018 and came away pretty confident that any new biodiversity policy statement they had input to would have increased education, guidance and support to landowners as a cornerstone. The Ministry for the Environment and the Department of Conservation report did recommend both option one (guidance and support) as well as option four (rules and regulation), he said.

However, the final proposed National Policy Statement for Indigenous Biodiversity put in front of New Zealanders in November is weighted towards regulation, he said.

“While I want to protect indigenous biodiversity, rules are just more negatives.”

“If it’s top-down, farmers won’t feel ownership of it; this strongly prescriptive tone will piss farmers off.”

He recommended that biodiversity management be integrated into farm operations through using incentives for farmers. He would prefer the strategy delivers funds into helping farmers produce detailed farm management Plans which outline how significant areas and species will be promoted, not reduced further.

This way biodiversity is integrated into the overall farm operation.

“This proposal downplays the chance of collaboration.”

Norton believes that there should be funding to educate farmers about how to look after an ecosystem and financial incentives provided to do so.

He suggests creating farming biodiversity ambassadors, outside council staff, that are free and independent to work with farmers.

“ECAN has land management Officers which are very helpful but they still have to report any rule breaking.”

He describes the $1.6 million offered for biodiversity promotion onfarm as a pittance from Government.

“We need $100m.”

Funds should come from the public pot as there is massive public good from looking after the environment.

He wants to see more extension resources; such as best practice for spraying near riparian strips, best practice for helicopter spraying indigenous areas mixed in with exotic weeds.

“Farmers can relate to leaving the first five metres of bush unfenced for stock shade, then fencing the rest.”

He suggests farmers, in their submission, outline what weed and pest work they are doing onfarm (in dollar terms/year). This will show that farmers are doing the work, without more rules.

The best incentive for farmers to look after older indigenous forest is give them the carbon credits earnt off it post-1990.

“These credits grown pre-1990 all went to the government but the carbon sequestration of the forest since 1990 should go to farmers, as they look after the forest.”

Why farmers should submit

• Affects management of indigenous biodiversity on all types of land, including public, private and Maori land.
• About 4000 native species have been identified as threatened with or at-risk of extinction. Farmers have these on their land.
• It proposes to make rules affecting biodiversity uniform across all councils.
• It’s proposed that Significant Natural Area (SNA) be the uniform classification (and rated as either High or Medium). Territorial authorities to identify, map and notify all SNAs within five years.
• Farming (or any activity) within an SNA must be shown to not lead to the loss, including through cumulative loss, of extent or degradation of the ecological integrity of any SNA; and ensure the adverse effects of an existing activity are of no greater character, intensity or scale than they were before the National Policy Statement commencement date.
• New activities in an SNA may be hard to get approval.
• National Policy Statement provisions allow existing farming to continue as long as impacts on indigenous biodiversity don’t increase. This has implications for farm development.
• A non-regulatory approach (for example a Regional Biodiversity Strategy) is also suggested and could be supported by farmers. Having a restoration vision has worked well in some regions.

Cost analysis tackles six districts

When farmers have finished reading the 45-page draft policy statement they can sink their teeth into the 196-page Cost- Benefit Analysis, commissioned by DOC and undertaken by 4SIGHT Consulting.

It reports that, overall, the draft Section 32 evaluation found that the impacts, costs and benefits of the NPSIB are expected to vary significantly between, and within, regions and districts and for different land-uses, agencies and stakeholders.

It goes on to say that because of this a number of key benefits (e.g: natural capital benefits from improved indigenous biodiversity) and costs (e.g: opportunity costs for landowners) have not been monetised/ quantified at this stage. This will require some additional data collection and agreement on an approach to extrapolate NPSIB benefits and costs across all districts and regions. The expected answer is it will be costly.

What it did have a crack at was estimating the potential SNA classification areas within six districts; Far North, Auckland, Waikato, Tasman, Westland, and Southland. These areas could be restricted in development activity.

The Southland District example estimated that of the 981,210 hectares of General Land Tenure area (which includes private ownership farmed areas), 10% of this would be designated as SNA and affect 39,000 properties. Most of the properties (89%) would have less than 1% SNA cover, however.

In Waikato 16% of all land is calculated to be marked as a SNA; 87% of DOC land, 47% of Maori land and 9% of General Land Tenure Area. Dairy farms that have low or high-producing grassland have less than 1% SNA coverage so will be less impacted by restrictions.

In the Far North District, an estimated 18% of all pastoral properties have 50% or greater Indicative SNA coverage. Provisions to provide for periodic indigenous vegetation clearance to maintain improved pasture outside of SNAs is likely to be highly relevant for these farmers.

In the Tasman District, indigenous land cover has been extensively cleared on General Land Tenure, leaving just fragments that equate to less than 10% of the original coverage (i.e. they are highly threatened). This is relevant for the ‘rarity’ characteristic in Appendix 1 and 2 of the NPSIB which is one of four to be evaluated to inform the split between High and Medium SNAs. This means that the significant majority of Indicative SNAs on general owned land are Indicative High SNAs (73% of SNA area) compared to Indicative Medium SNAs (11%).

No choice over SNA

Ecological criterial for identifying and mapping significant Natural Areas (SNA). Proposed National Policy Statement for Indigenous Biodiversity. To be rated High or Medium.

Representativeness – where indigenous vegetation or habitat of fauna is typical or characteristic of the indigenous biodiversity of the ecological district; this can include commonplace vegetation/ habitats where it is representative, depending on the wider natural environment

Diversity and pattern – the extent that the expected natural range of diversity of flora and fauna and physical aspects are present in the area

Rarity and distinctiveness – where there are rare, depleted or distinctive flora or fauna, habitats or ecosystems, such as threatened and at-risk species, and naturally uncommon ecosystems

Ecological context – how the size, shape and configuration of the area contributes to the wider surrounding landscape and ability for biodiversity to be maintained.

Classification ahead

Accepting a significant natural area (SNA) classification on your land is usually voluntary.

This would change if the proposed National Policy Statement for Indigenous Biodiversity is adopted. It would require councils to identify areas with significant vegetation and habitats of indigenous fauna and manage their protection through regional and district plans, and consent processes under the RMA.

Farmers will no longer have the choice whether land areas on-farm are classified as SNAs. They would be identified by councils and ecologists working with landowners, using significance criteria developed by ecologists. Each SNA would be verified by physical inspection and landowners have access to the information.

It favours the status quo or improvement of indigenous biodiversity. For example, the mixed exotic and indigenous grasses that are used for grazing may include rare indigenous grasses or habitat of rare indigenous animals.

The provision intends to allow existing farming activity to continue, while making sure the impact to indigenous biodiversity does not increase. It is up to the landowner to prove there are not adverse effects from new activities that impact on SNAs and indigenous species outside SNAs.

Traditionally councils have embraced the use of SNAs to different levels. For many farmers, an approach about a potential SNA on their land is one that comes with an offer of education rather than a list of rules. Farmers get reports about what species are there and recommendations on farming practices to improve their survival.

It is highly likely that most of the high-country pastoral use land will be marked as SNAs. Matagouri is listed as a trigger plant for an SNA and the species is widespread.

Federated Farmers is concerned that the ecological criteria may result in most indigenous vegetation being identified as significant while this was not the initial intention. As noted in the discussion document, SNAs represent the most iconic and highly valued indigenous biodiversity, the criteria should not capture wider than that.

The proposal doesn’t favour biodiversity offsetting. A biodiversity offset is a commitment to redress [more than minor] residual adverse impacts. The proposal states it should only be contemplated after steps to avoid, remedy and mitigate adverse effects have been demonstrated to have been sequentially exhausted. There is a limit to offsetting as many biodiversity values cannot be offset and if they are adversely affected then they will be permanently lost.

Farmers can make a submission on the proposal, with closing date March 14.

Manuka and kanuka classified as Threatened

Farms where kanuka and manuka are viewed as weeds may be limited in their ability to spray them where myrtle rust is a risk.

The recent arrival of myrtle rust in New Zealand (April 2017) is anticipated to have significant, negative consequences for all Myrtaceae taxa. As a result, a precautionary approach has been taken in the most recent NZ Threat Classification System lists for vascular plants and all Myrtaceae taxa have been classified as Threatened. However, some Myrtaceae taxa are relatively common in some areas, in particular manuka and kanuka would classify as Threatened only due to the risk of myrtle rust.

If a significant Natural Area (SNA) is identified only because of the presence of manuka and kanuka that is considered Threatened only because of the threat posed by myrtle rust, it is proposed it should not be managed as if it is a SNA. Assessment against the other SNA criteria must also determine whether it is a SNA. If it qualifies as significant for any other reason, then it should be managed as a SNA.

Scenario example from the Biodiversity Collaborative Group:

Lucinda manages a high-country station in Otago. The farm runs extensive sheep and beef. As the property is large, maintaining pasture on any part of the property only occurs as part of a programme to improve pasture composition every few years and sometimes out to a decade or more.

Matagouri has started to regenerate but Lucinda wants to continue to cultivate or topdress areas. Under the proposed NPSIB, as long as the regenerating matagouri has not itself become a SNA since Lucinda last cleared it, the periodic clearance to maintain improved pasture is unlikely to compromise the protection of SNAs or the maintenance of indigenous biodiversity, and the farming activities can continue.