Dear Wellington City Council,

The definition for the term ‘tree’ which WCC has proposed in the new 2024 District Plan is:

“a woody plant 3 metres or greater in height includes a Tree Fern, but excludes a vine with a stem diameter less than 50 mm.”

Please provide all meeting notes, correspondence, documents, records, regarding the reasoning for this definition, source material used, options choice and decision made as to the meaning of the term.

Please name the version (Draft, Proposed, etc) and date in which this definition was added. Specifically, whether it was added in a version that was still open for public feedback and contest.

The reason:

This definition WCC has proposed is novel, unfit for purpose, and with little basis in professional literature on the matter.

It appears to be opinionated and with ulterior motive in that
a) reducing the height captures scrub in the definition, affecting coverage statistics drastically, supporting a distorted statistics of increased tree coverage for political gain and
b) can be used to support the confiscation of use of a larger area of their private land.

As only one example of the reason the matter is significant:

“For example, the estimate of global forest area increased by 300 million ha (approximately 10 %) between 1990 and 2000 simply because the FRA changed its global definition of forest, reducing the minimum height from 7 to 5 m, reducing the minimum area from 1.0 to 0.5 hectares (ha) and reducing minimum crown cover from 20 to 10 % (FAO 2000)”

Performing the most cursory investigation of the both international and New Zealand specific literature and research that is publicly available on the web demonstrates that the use of 3m as a criteria is significantly in the minority, with the majority of definitions being more precise in terms of trunk count and circumference, and use heights of 5m, tending towards 6m and 8m.

The following were all found within just 20 minutes:

[Specht 1970] “a woody plant more than 5 m tall, usually with a single stem”

https://fennerschool-associated.anu.edu....

“a height of at least four metres and state that there must be a single trunk. A shrub or bush is a woody plant which is branched directly above or in the ground and therefore does not form a trunk.”

Src: https://environment.govt.nz/publications...

Src: Key terms and definitions | Ministry for the Environment

Src: Defined by the Environment Court having regard to the Shorter Oxford English Dictionary, 6th Edition, OUP

“New Zealand has a large number of trees (215 species ≥6 m in height)... However, this richness is due to a greater abundance of *small* trees (≤15 m in height)”

Src:(PDF) Comparative biogeography of New Zealand trees: Species richness, height, leaf traits and range sizes (researchgate.net)

“A tree is a woody plant with an erect perennial trunk at least 7.5 cm in diameter at 1.3 m, a denitely formed crown of foliage, and a height of at least 4 m.” (Little 1980) or so precisely inclusive that many species that most would regard as shrubs are included: “…any woody species reaching 3 m or more in any part of its range” (Adams & Woodward 1989)...Here, we will refer to self-supporting, woody species ≥6 m high as ‘trees’ and woody plants less than 6 m high as ‘shrubs’. This makes structural sense because tall woody plants with obligate multiple stems (e.g. mallee eucalypts) usually have a maximum crown height of 5m or less (Givnish 1984). A further advantage of using this denition is that compilations of ‘trees’ usually include almost all woody species ≥6 m but may use a variety of criteria with regard the inclusion of shorter species. In New Zealand, the 6 m minimum excludes nearly all woody plants conned to near tree-line situations in the so-called ‘subalpine’ scrub zone, thus giving a grouping largely restricted to forest. Analyses of tree distributions have often used a ≥3 m denition (Adams & Woodward 1989; Huntley 1993) and for comparative purposes, we have also developed a broader compilation that includes such species. To avoid confusion, here we refer to this broader grouping of all woody plants ≥3 m as ‘arborescents’. We refer to trees ≤15 m as ‘small trees’ and those >15 m as ‘canopy trees’.

Src”(PDF) Comparative biogeography of New Zealand trees: Species richness, height, leaf traits and range sizes (researchgate.net)

“Forest is determined both by the presence of trees and the absence of other predominant land uses. The trees should be able to reach a minimum of 5 meters in situ.”

(PDF) What is a forest? Definitions do make a difference: An example from Turkey (researchgate.net)

“The General Directorate of Forestry (GDF 2009) refers to 8m or above and the Forest and Agriculture Organisation of the United Nations (FAO) defines trees as 5m or above.”

“In the same search, I found nearly 240 definitions of tree (Lund 2013). While a ‘tree’ is usually considerd a single-stemmed Woody perennial, some national definitions include “Most definitions include a height of at least four metres and state that there must be a single trunk.”9

“A ‘tree’ is a woody plant, growing to greater than 5 meters in height (16 feet), with a single dominant stem.”

[Treepedia10]

One can go on. But it is clear from the above quick search that 3m is highly contestable, 4m is still contestable, 5m less so, and 6m and 8m difficult to contestable.

We also note that WCC has produced an public GIS map of trees at 6m or above. As such we recommend that WCC align its definition with its maps and use 6m to not mislead citizens.

Please state whether the term will be reviewed and corrected by WCC to be a definition that will not skew statistics to communicate an increase in tree coverage even though the gain demonstrated would only be a paper based one.

If not, please provide precise instruction on how it can be contested to be changed.

Dear BUS: Official Information,

I hope you will concur that we have been patient and provided your organisation sufficient time to track down the information to answer this query? It remains important to clarify the basis of this change.

Looking forward to obtaining an answer, thank you.

Yours sincerely,

Wellington RatePayer