REQ 2025 3549 s32AA Evaluation Report.pdf

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Appendix 4: Section 32AA Evaluation Report
Introduction
Section 32AA of the Resource Management Act 1991 (RMA) requires that a further evaluation be
undertaken where changes are recommended to a proposed policy statement or plan since the
Section 32A Evaluation Report was originally completed and notified. The Section 32AA evaluation
must be undertaken in accordance with the criteria outlined in Section 32A(1(b))-(4), and must be
undertaken at a level of detail that corresponds to the scale and significance of the changes. For the
purposes of this Report, Section 32A(1)(a) is not assessed as no new objectives are recommended to
be added to the Land and Water Plan (L&WP).
In response to submissions and further submissions received on the Proposed Plan Change 1 to the
L&WP, Council staff are recommending the addition of two new rules to the Plan. Only these new
provisions are the subject of this Section 32AA further evaluation as they are the key changes being
recommended to Plan Change 1, and they have implications for resource consenting and compliance
monitoring. Staff are also recommending a number of other minor changes to the proposed
miscellaneous changes and the Schedule 1 and 2 wetland boundaries which do not need further
evaluation as they have relatively minor consequences, and the reasons for these changes are already
given in the Section 42A Report.
The two new provisions analysed in this Report are:
 Permitted Rule 7a Harvesting of Sphagnum Moss within Schedule 2 Wetlands
 Permitted Rule 27a Clearance and Spraying of Blackwater Creek in the Kongahu Area,
Karamea
Copies of the new Rules are included at the end of this Evaluation Report.
Structure of the Evaluation
The next section contains an evaluation of the two new Rules against the Section 32A(1)(b)-(4) criteria,
outlining whether the Rules (which are classed as a Method) are the most appropriate way to achieve
the Plan Objectives having regard to their efficiency and effectiveness and their likely benefits and
costs. The risks associated with acting or not acting where there is uncertain or insufficient information
are also discussed where appropriate.

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RMA Section 32 provision
Assessment
Permitted Rule 7a. Harvesting of Sphagnum Moss within Schedule 2 Wetlands
(1)(b) Are the policies and methods the most Yes. The recommended permitted activity Rule is considered the most appropriate way to achieve the Plan
appropriate way to achieve the objectives, Objectives.
by:
(i) are there other reasonably practicable (i) In the consideration of the development of the new permitted Rule and whether there were other
options for achieving the objectives?
reasonably practicable options to achieve the Objectives:
(ii) are they efficient and effective to achieve
the objectives?
Do nothing: This option would be to proceed with the proposed amendment to the definition of “vegetation
(iii) what are the reasons for deciding on the
disturbance” in the Land and Water Plan (L&WP) Glossary as notified, to exclude the harvesting of Sphagnum
policies and methods?
moss within Schedule 2 wetlands from being caught by the definition. The notified change would make the
harvesting in Schedule 1 and 2 wetlands permitted with no rule or conditions in the Plan to manage any
adverse effects on the wetland values.
As a result of a number of submissions and further submissions supporting and opposing the change to the
definition of “vegetation disturbance”, it is considered inappropriate to ‘do nothing’. Some submitters
opposing the proposed change disagreed with the Section 32 Evaluation Report explanation, that at the time
of the Environment Court case the parties had agreed that it was not intended for the harvesting of sphagnum
moss to require resource consent. Instead, these submitters believe that at the time of the Environment
Court decision, the parties considered that not enough was known about the activity and so it should require
consent. Therefore, these submitters requested the proposed change to be rejected. This led to staff
investigating the issue through an Envirolink grant whereby Landcare Research reviewed previous research,
interviewed key stakeholders, and assessed whether any identified effects could be managed through rule
conditions. Attached at the end of this Evaluation Report is a copy of the Landcare Report, which concluded
that current, known harvesting practices do not significantly impact on the scheduled wetland, however,
without a rule, condition, or consent process, there is no guarantee that these current practices will be
employed by all harvesters, including any future harvesters. Staff then organised a workshop with the key
stakeholders and Landcare Research to discuss the recommendations in the Landcare Report and decide on
a way forward. Based on the information in the Landcare Report, and from the workshop, we consider that
we cannot move forward with amending the definition of ‘vegetation disturbance’ to exclude the harvesting
of sphagnum moss.
Other reasons for not continuing with the proposed amendment to the vegetation disturbance definition are
given in the Section 42A Report. Namely, that we consider it inappropriate for sphagnum moss harvesting to
be undertaken in Schedule 1 and 2 wetlands without a relevant rule to manage any adverse effects.

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Status quo: Under this option, there would be no change made to the definition of “vegetation disturbance”
in the L&WP Glossary. This means that sphagnum moss harvesting would be considered as a vegetation
disturbance activity, and the current rule status in the L&WP would apply, that is, a non-complying activity
in a Schedule 1 wetland under Rule 19(ii) or (iii), and a discretionary activity in a Schedule 2 wetland under
Rule 17(ii).
Staff consider that keeping the harvesting of Sphagnum Moss within Schedule 1 wetlands as a non-complying
activity is appropriate. Many submitters raised concerns that harvesting within Schedule 1 wetlands would
impact on the significant ecological values of these wetlands. Their view was that harvesting would remove
significant native vegetation which would reduce the habitat available for rare and threatened native bird
species. The September 2017 workshop with key parties reaffirmed these views. Staff agreed that harvesting
should not occur within Schedule 1 wetlands.
Having said that, it would be impractical to amend the vegetation disturbance definition so that it applies to
Schedule 1 wetlands but not Schedule 2. It is more practical to amend the vegetation disturbance definition
so that harvesting in a Schedule 1 wetland remains as a non-complying activity, and consider alternative
wording for harvesting in Schedule 2 wetlands.
We also consider that retaining the discretionary rule status for harvesting in Schedule 2 wetlands is
inappropriate. From the research undertaken by Landcare Research, it appears that few harvesters harvest
sphagnum moss within Schedule 2 wetlands. The research does not provide reasons for why this may be the
case. However, only 3,687ha (6%) of Schedule 1 and 2 wetlands are privately owned, the rest are on land
administered by the Department of Conservation (DOC). This limits the number of Schedule 2 wetlands where
harvesting can occur without the harvester needing to require a concession from DOC, as well as a resource
consent from the Regional Council. Many Schedule 2 wetlands do not have moss growing in them, further
limiting the number of Schedule 2 wetlands where harvesting can occur. Staff also understand that the high
costs of having to obtain a consent, and pay for an ecologist to undertake an assessment of the wetland
values and effects of the harvesting in a Schedule 2 wetland with sphagnum moss present, may have
discouraged harvesters from picking there. Costs are further discussed later in this Report.
Other options: At the workshop held in September 2017, all parties stated that they felt they could commit
to a permitted activity rule provided that the conditions in the rule protected the values of the wetland. Staff
agreed to draft up a permitted activity rule in consultation with the workshop parties. From initial feedback,
all parties appeared to generally support the draft conditions of the Rule. During the workshop, the option of
limiting the permitted rule to allow harvesting within Schedule 2 wetlands that were geographically identified
in the L&WP was considered. However, assessing every Schedule 2 wetland would be time-consuming and
costly for the Council, and so this was not considered to be a viable option.

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Several months after the September 2017 workshop, DOC advised that they had concerns with the permitted
activity rule, and suggested that a restricted discretionary rule would be more appropriate. Their key concern
was that under permitted activity status, the Council would not have control over where harvesting could and
could not occur, limiting the ability to provide greater protection to significant ecological species where
required. If the harvesting of sphagnum moss within Schedule 2 wetlands is a restricted discretionary rule,
then a Schedule 3 assessment of the ecological values would be required as part of the consent application.
Requiring consent would allow the Council to either decline the consent if the Schedule 3 assessment found
that the area has significant values, or limit where and how harvesting could occur based on the assessment.
However, we consider that having a restricted discretionary rule is excessive given the small number of
harvesters harvesting within Schedule 2 wetlands, and the types of methods they now use which the Landcare
Report identifies have minimal impacts. Information staff have obtained indicates that the methods of
harvesting have changed over the last 25 years with many of the more damaging methods no longer used
as harvesters and landowners realise the economic values of maintaining healthy wetlands for the purpose
of ongoing sphagnum moss growth. For example, most commercial harvesters now use heavy machinery
that has been adapted to spread the weight over a wider area, so they can be driven on the wetlands without
altering the hydrology. This also reduces rutting and drainage, allowing for harvesting to be undertaken
without affecting the hydrology of the scheduled wetland, which is a key driver for maintaining the ecological
values of scheduled wetlands.
Staff also considered the option of a controlled activity rule. A controlled status rule would allow the Council
to manage effects of harvesting as conditions of a resource consent, however the Council must grant the
consent. Staff consider this type of rule is also excessive given that few harvesters harvest within Schedule
2 wetlands, and the methods now used to undertake harvesting have no more than minor effects on the
scheduled wetland. We also do not anticipate that there will be a significant increase in the number of
harvesters harvesting within Schedule 2 wetlands in the future, as less than 6% of Schedule 2 wetlands are
on private land, and not all of these have sphagnum moss growing in them. Harvesters may also move away
from wanting to harvest within Schedule 2 wetlands to undertake harvesting within a more controlled system.
Sphagnum moss harvesting in a non-scheduled wetland is permitted with no rule or conditions for it in the
L&WP. For this reason, we had anticipated that most harvesters would prefer to harvest sphagnum moss
from non-scheduled wetlands over scheduled wetlands. However, we understand it is the view of the
harvesters that harvesting sphagnum moss within the Schedule 2 areas ensures the areas remain as wetland
so that the moss will continue to grow rather than these wetlands being cleared for other land uses such as
dairy farming or mining.

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(ii) The proposed permitted activity rule is considered to be effective and efficient to achieve the Objectives
in the Plan as follows:
Allowing the harvesting of sphagnum moss within Schedule 2 wetlands ensures the wetland areas, where
moss grows, to remain as wetland. Without harvesting, the moss affects the hydrology of the area,
enabling dryland plant species to establish. The Permitted Rule ensures that harvesters undertake
harvesting in a way that has temporary and minimal effects on the values of the Schedule 2 wetlands.
The rule has a number of conditions requiring harvesters to maintain the natural hydrology of the wetland
area. This is key for safeguarding and maintaining wetland values. A number of other conditions also
ensure habitat is retained within the designated area for rare and threated species such as brown mudfish
and fern birds. Conditions (e) and (p) ensure that the area is only cleared for the sole purpose of
harvesting sphagnum moss. Conditions (a), (b) and (q) require harvesters to provide Council with data
on when, where, and how harvesting is being undertaken. The Council can then use this information to
gain a better understanding of the scale and location of the activity, and to assist with any compliance
monitoring that may be required. The conditions of the Rule are considered to be effective for achieving
Objective 6.2.1 of the Plan, to provide protection for any significant ecological values of Schedule 2
wetlands that are sought to be harvested for sphagnum moss. The permitted Rule also achieves Objective
3.2.1 of the Plan as it provides for the sustainable use of Schedule 2 wetlands with harvestable sphagnum
moss resources.
The permitted Rule cannot guarantee there will be no “cow-boy” harvesters. However, it is in the
industry’s best interests to promote good practice so that the Rule is complied with, and remains effective.
If Council receives complaints regarding non-compliance with the Rule, Compliance staff are able to
undertake site visits to investigate potential issues and undertake enforcement action if required.
Education, advice, and field days are also options that the Council can consider using to reduce the risk
of poor harvesting techniques being utilised. Also refer to the last section on assessing the risk of acting
or not acting.
The permitted activity rule is considered efficient as it allows harvesters to undertake harvesting within
Schedule 2 wetlands without incurring the substantial financial cost and time delays of applying for a
resource consent, and paying for an ecological assessment of the site they wish to harvest. This is a
potentially prohibitive cost to the harvesters. Staff do not anticipate a substantial increase in the number
of harvesters harvesting within Schedule 2 wetlands, given that less than 6% of all Schedule 2 wetlands
are on private land and not all Schedule 2 wetlands will have moss that is harvestable.
For the reasons given above, staff consider that the permitted activity rule can enable appropriate
resource use as well as wetland protection, and meet the Objectives in the Land and Water Plan.

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(iii) At the end of the Environment Court process for scheduled wetlands, the parties agreed that the Council
would not enforce the requirement for harvesters to obtain resource consent when harvesting within
scheduled wetlands. Rather, the Council would work with the industry and DOC to design a sensible
permitted activity rule. The recommended permitted Rule completes what was initially agreed to amongst
the parties involved in the Environment Court process.
Additionally, the permitted rule is considered necessary to enable harvesting to continue to be undertaken
sustainably in the short term, until we have more certainty that growing and harvesting moss from
artificially developed wetlands is a feasible alternative. Staff are currently seeking funding for advice on
this option.
(2) (a) Identify and assess the costs and We anticipate that the new permitted rule will not generate large-scale economic growth and/or a large
benefits of the environmental, economic, increase in employment. The sphagnum moss industry on the West Coast is at a substantially smaller scale
social, and
cultural effects that
are regionally compared to other sectors such as dairy farming or forestry. However, the majority of jobs involve
anticipated
from
implementing
the picking and washing the moss, so if the permitted Rule provides more opportunities for sustainable harvesting
provisions, including the opportunities for-
in Schedule 2 wetlands, then this could generate increased income and employment.
(i) economic growth that are anticipated to
be provided or reduced;
Benefits
(ii) employment that are anticipated to be Environmental: Enabling harvesting in Schedule 2 wetlands under the permitted Rule means that habitat for
provided or reduced;
Brown mudfish and Fern birds can be maintained in the long term. Brown mudfish occur in wetlands with
natural variations in water levels. Harvesting methods, such as using machinery that spread the weight of the
machines over a wide area of wetland, help to maintain these water variations. Other freshwater species such
as short finned eels, galaxids, and freshwater crayfish may also be found in wetlands where harvesting occurs.
Harvesting sphagnum moss will maintain a Schedule 2 wetland as a functioning wetland. Harvesting delays
succession to forest in anthropogenic wetlands (human induced wetlands) by maintaining low-saturated
vegetation, including open rush and sphagnum moss communities. Without harvesting, the wetland would
follow natural ecological processes to become forest. The purpose of having the Schedule 2 wetlands is to
maintain these areas as wetlands, of which harvesting is a useful tool to achieve this.
Information on the values in the Schedule 2 wetlands can be collected by the permitted activity rule to help
with ongoing management of these wetlands, to ensure the areas remain as wetland, and that habitat for
Brown mudfish and other similar species is maintained.

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Economic and Social: Harvesters will not have the significant cost of obtaining resource consent. This will help
to reduce industry costs and continue to bring income into the Region, especially in rural areas where job
opportunities can be limited.
There may be a small increase in employment opportunities in the future. Additional income and employment
will contribute to the social and economic wellbeing of West Coast people and communities.
Private landowners of a Schedule 2 wetland, with sphagnum moss that is harvestable, will likely benefit from
receiving a royalty from harvesters to take the moss.
Cultural: The benefits identified will also accrue to Poutini Ngāi Tahu where they are involved with harvesting
or own land with a Schedule 2 wetland that can be harvested under the new permitted rule.
Costs
Environmental: A number of submitters perceive that having a permitted activity rule for harvesting sphagnum
moss within Schedule 2 wetlands would lead to damage to, or loss of, significant wetland ecological values.
This is further discussed in the risks section below.
Social: If harvesters are required to obtain consent to undertake harvesting within Schedule 2 wetlands, then
they may choose to leave the industry, leading to a loss of opportunities for income and employment on the
West Coast.
Economic: Harvesters will have a financial cost of undertaking monitoring of the harvesting site as per
condition (q) of the permitted rule. However, this cost is anticipated to be less than the cost of obtaining
resource consent and an ecological assessment under a controlled or restricted discretionary rule.
Staff are not aware of any specific cultural costs other than what is already identified.
(2)(b) Quantify if practicable the benefits and It is considered unnecessary to undertake a full monetary benefit-cost analysis. Concerns about the cost of
costs
obtaining a resource consent and an ecological assessment have been raised in this Report, however,
quantifying the identified benefits and costs is neither practical or useful, and does not add reasonable value
to this section 32AA evaluation. The time and cost it would take to do a monetary cost/benefit analysis is
considered unjustified.

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(2)(c) Assess the risk of acting or not acting There is always potential for sphagnum moss to be harvested whether the Permitted Rule is in place or not.
if
there
is
uncertain
or
insufficient If the Permitted Rule is in place, there is no certainty that harvesting would be undertaken within the Rule’s
information about the subject matter of the conditions. This applies to any resource management activity and is a matter that the Regional Council has
provisions.
to manage on a day to day basis. Staff are aware of two harvesters harvesting within Schedule 2 wetlands
who are using good practice techniques to maintain wetland values. Sphagnum moss harvesting has been
undertaken for many years, and harvesters will know from experience the need to maintain the wetland to
enable the moss to replenish for future harvesting. Taking a risk averse approach and requiring consent is,
in our view, not a practical option. Staff consider that the risk is not so insurmountable that the activity cannot
be made permitted with conditions. While there are currently gaps in the information we have, the monitoring
requirements in the permitted Rule enables these gaps to begin to be filled.
Additionally, owners of private land with a Schedule 2 wetland with moss that is suitable for harvesting, are
unlikely to risk allowing harvesters who use poor practice methods into their wetland, as this may reduce the
amount of moss that will regrow in the future. Adversely affecting the hydrology of the wetlands could limit
future harvesting, and the landowner will miss out on income from the harvesting.
If an ecological assessment finds that the area does not have significant ecological values, the cost of the
assessment and obtaining consent still falls on the harvester or landowner. Having borne this cost, the
landowner may choose to develop the area into farmland, in particular dairy farming, rather than proceeding
with sphagnum moss harvesting. This could be an unintended consequence of having a controlled or restricted
discretionary rule.
One of the concerns raised by some submitters with permitting harvesting in Schedule 2 wetlands is the risk
that if there are rare or threatened species in a Schedule 2 wetlands, then they could be adversely affected
by harvesting, causing these values to be damaged or lost. There is little or no risk of this happening in
Schedule 2 wetlands on public conservation land as DOC requires a concession for any sphagnum moss
harvesting, and DOC assess effects of harvesting proposals through the concession process. The risk is further
reduced in Schedule 2 wetlands on private land as these comprise only 6% of all the scheduled wetlands,
and not all of these wetlands would have moss at a scale that would be cost-effective to harvest. For the
small remaining number of Schedule 2 wetlands on private land that have harvestable moss, the Rule includes
a number of conditions that direct harvesters to only undertake harvesting in a way that does not harm the
ecological values of the Schedule 2 wetlands.

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MA Section 32 provision
Assessment
Permitted Rule 27a. Clearance and Spraying of Blackwater Creek in the Kongahu Area, Karamea
(1)(b) Are the policies and methods the most Yes. The recommended draft permitted activity rule is considered the most appropriate way to achieve the
appropriate way to achieve the objectives, objectives.
by:
(i) are there other reasonably practicable
(i) Do nothing: Mr Brian Jones, on behalf of the Kongahu Rating District, made a further submission on the
options for achieving the objectives?
Proposed Plan Change 1 requesting that the Schedule 1 and 2 wetland designation be removed from
(ii) are they efficient and effective to achieve
Blackwater Creek as the Rating District has consent to clear the Creek. The consent was granted in 1994
the objectives?
to allow the removal of sediment and debris from Blackwater Creek, when needed, to reduce the risk of
(iii) what are the reasons for deciding on the
flooding to the surrounding farmland. Rejecting this submission would equate to ‘doing nothing’, however,
policies and methods?
‘doing nothing’ is considered to not be an option. Since the consent was granted, rules in the Land and
Water Plan (L&WP or the Plan) have changed. The activity now does not meet Rule 27 in the Plan as
clearance will likely change the natural flow, path and fluctuation of water levels in the creek. The activity
is also a discretionary activity within a Schedule 2 wetland under Rule 36, and non-complying within a
Schedule 1 wetland under Rule 37. The part of Blackwater Creek that the consent covers includes a
section between Schedule 1 and 2 wetlands KAMP002a and KAMP002b.
Retaining the very restrictive non-complying status for the creek clearance in the Kongahu wetlands is
considered inappropriate. The consent is due for renewal in 2019, and would have to be assessed under
the non-complying Rule. This means the Kongahu Rating District would need to undertake extensive
monitoring of the wetlands species present and water flows within the stretches of the creek that are
located within the Schedule 1 and 2 wetlands. This is needed to show that there will be less than minor
effects on the Schedule 1 and 2 wetlands from clearing the creek when there is a flooding risk, and that
the clearance is consistent with the Objectives and Policies of the Plan. This process will be difficult to
undertake and costly for the Rating District, with no guarantee that consent will be granted. It is important
that the creek can be cleared, when necessary, to reduce the flood hazard risk, as flooding can reduce
pasture growth and availability, impacting on the farmers’ incomes. Given that the creek has been cleared
4-5 times in the last 24 years, and both wetlands are still functioning and the ecological values have been
maintained, non-complying rule status does not reflect an appropriate level of management.
Other options: Staff also considered removing the wetland designations from the section of Blackwater
Creek that flows through the Schedule 1 and 2 wetlands. However, removing the designation would limit
the control Council has over managing the effects of any other activity in the creek on these wetlands. If
the Council has no control over other activities occurring within these areas of Blackwater Creek, then

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Council cannot be certain that the values of both the Schedule 1 and 2 wetlands will be protected.
Therefore, we concluded this would not meet the Policies and Objectives of Chapter 6 in the Plan.
During pre-hearing consultation, Council staff discussed the matter with DOC, and identified that a
permitted Rule for clearing the Creek would be appropriate. DOC had some initial concerns about
permitted rule status, and so staff obtained Envirolink funding for NIWA to review the hydrology and
ecological state of the wetlands, and advise if creek clearance would affect the wetlands. The NIWA
Report confirms that clearance can be undertaken without adversely affecting the wetland values. The
draft permitted activity rule allows the creek to be cleared of sediment and debris when required, subject
to conditions to ensure effects remain minimal, without having to obtain resource consent.
The permitted Rule also provides for the spraying of the aquatic pest plant Parrots Feather within
Blackwater Creek, and the wider area. Parrots Feather is an invasive pest plant within the Kongahu area
and is listed in the West Coast Pest Plant Management Strategy, which requires that the plant be
managed. It is appropriate that spraying of Parrots Feather be provided for in the new permitted Rule,
as the plant is spreading and restricting the flow of water in the Creek, which potentially increases the
flooding risk, reduces the aquatic ecology in the creek, and could affect the wetlands.
(ii) The permitted activity Rule is considered to be effective and efficient to achieve the Objectives in
Chapters 3 and 6 of the Plan. Having the permitted activity rule allows the Kongahu Rating District to
undertake the removal of sediment and debris, and the aerial spraying of Parrots Feather (Myriophyllum
aquaticum) when required, while ensuring wetland values of both the Schedule 1 and 2 wetlands are
maintained. The values of both the Schedule 1 and 2 wetland areas will be protected because the Rule
only permits the clearance of the creek and the spraying of Parrots Feather within the Creek in the two
scheduled wetland areas. The rule also sets a number of conditions about how the clearance and spraying
can occur, including where sediment can be deposited within the two wetland areas. The conditions
mostly reflect past clearance practice which has been effective in managing the flood risk and protecting
the wetland values. Conditions (a), (b), and (g) requiring that the Council be notified, equipment be
cleaned prior to clearance, and no refuelling within the wetland do not place any onerous requirements
on the Rating District or the operator.
The permitted activity Rule meets several Objectives of the Plan:
3.2.4: The creation or exacerbation of a flood hazard will continue to be avoided or mitigated.
5.2.1: Any adverse effects of the creek clearance on the wetlands will be avoided, remedied or mitigated.
6.2.1: The values of both the Schedule 1 and 2 wetlands will continue to be protected.
(iii) Refer to other reasons under Decision Requested 2.18 in the S42A Recommending Report.

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(2) (a) Identify and assess the costs and The permitted rule will not generate large-scale economic growth and/or changes in employment because
benefits of the environmental, economic, contractors already clear the creek when required an the Council does not expect there to be an increase the
social, and
cultural effects that
are number of times the creek will require clearing.
anticipated
from
implementing
the
provisions, including the opportunities for-
Benefits
(i) economic growth that are anticipated to Environmental:
be provided or reduced;
Significant ecological values of the Schedule 1 wetland will be protected because consent will be required for
(ii) employment that are anticipated to be activities within Blackwater Creek that do not meet either the new permitted Rule, or other rules in the Plan.
provided or reduced;
Any significant ecological values of the Schedule 2 wetland areas will be protected because any activities,
other than which is permitted by this Rule or other rules in the Plan, will continue to require an ecological
assessment under Schedule 3 of the Plan and a resource consent.
Reducing the risk of flooding will reduce the risk of overland flow from surrounding farmland entering the
wetland, preventing undesirable nutrient inflows into the wetland as the flows will be maintained in the
channel of Blackwater Creek and more easily be directed out to sea.
The spread of the pest plant Parrots Feather will be contained by allowing aerial spraying in Blackwater Creek.
Economic: Allowing the activity to occur will remove the cost of obtaining resource consent, and undertaking
monitoring of species and water flows, for the Rating District. This cost is unnecessary given the need to have
the creek cleared to reduce the risk of flooding, and the spread of Parrots Feather contained within the area.
Creek clearance will continue to avoid, or reduce the occurrence of the pest plant Parrots Feather and the
loss of dairy pasture and income from flooding for affected landowners.
Social: Clearing Blackwater Creek will contribute to reducing the risk of flooding in the wider Kongahu area,
which will ensure the safety of people within the area.
Cultural: Staff are not aware of any direct cultural benefits or adverse effects arising from the permitted Rule.
Costs
Staff are not aware of any environmental, economic, social or cultural costs arising from this recommended
Rule. There are costs to the Council for staff time spent investigating management options to provide for both
hazard mitigation and wetland protection, however this is considered to be business as usual for the Council
and not an additional cost.

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(2)(b) Quantify if practicable the benefits and It is considered unnecessary to monetise the identified benefits and costs. Quantifying them is not practical
costs
or useful, and does not add reasonable value to this section 32AA evaluation. The time and cost it would take
to do a monetary cost/benefit analysis is unjustified.
(2)(c) Assess the risk of acting or not acting This is not relevant because there is sufficient information to recommend adding the permitted Rule to the
if
there
is
uncertain
or
insufficient Plan. The creek clearance has been undertaken for a large number of years with less than minor effects on
information about the subject matter of the the Schedule 1 and 2 wetlands. The NIWA Report concludes that the creek has little effect on the hydrology
provisions.
of the wetland areas as they are mainly fed by rainfall and groundwater, and clearance of the creek will help
to protect the ecological values of the two wetlands. The creek is below the level of the wetlands and so farm
runoff will not be able to flow into the Schedule 1 and 2 wetland areas from the creek.

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Draft Permitted Activity Rule for the Harvesting of Sphagnum Moss within Schedule 2 wetlands.
Rule 7a. Harvesting of Sphagnum Moss within Schedule 2 wetlands
The harvesting of Sphagnum Moss within a Schedule 2 wetland is a permitted activity if all of the
following conditions are met:
(a) The Council is notified in writing of the location of the activity and the area to be harvested at
least seven working days prior to the activity taking place;
(b) Photographs are provided to the Council of the area to be harvested at least seven working
days prior to the activity taking place;
(c) The post-harvest moss surface is at or above mean water level;
(d) Drainage of the area is not altered in any way;
(e) Only existing formed access to the harvesting area is used;
(f) Drains and weirs are not used to manipulate water levels;
(g) The weight of machinery used for harvesting is spread by either:
a. Widening the tracks on track-driven vehicles, or
b. Using platforms for machinery to drive on;
(h) Only the living portion (acrotelm) of the moss is removed;
(i) Crushing of vegetation, to maintain sphagnum dominance, is undertaken either during
harvesting, as a component of harvesting, or post-harvest, to rehabilitate the sphagnum moss
in the wetland area;
(j) Machinery and equipment are cleaned prior to entering the scheduled wetland to avoid the
introduction of pest, or exotic, plants;
(k) No harvesting of sphagnum moss or removal of plants is to occur within riparian margins;
(l) No refuelling of machinery or equipment from bulk fuel tankers (i.e. containers greater than
20 litres in capacity) takes place in the scheduled wetland;
(m) No fertilisers are dispersed in the scheduled wetland;
(n) The site is left tidy at the completion of harvesting;
(o) The activity does not disturb any breeding, roosting or nesting sites of indigenous birds;
(p) Disturbance of the area is limited to the extent necessary to undertake harvesting;
(q) Harvesters must:
a. Monitor the harvesting operation throughout harvesting;
b. Record the information on the prescribed form;
c. Provide the prescribed form to Council within 20 working days of the completion of
harvesting.
Explanation
Where one or more of the conditions are not met, a resource consent under Rule 17 will be required.
The conditions of Rule 7A are based on best practice processes to manage the effects of harvesting
sphagnum moss, and ensure the ecological values of the potentially significant Schedule 2 wetlands
are maintained. If the harvesting activity is not undertaken in accordance with good practice, effects
such as dryland plants establishing can modify these wetlands and impact on their significant values.
To meet condition (a) the area proposed to be harvested needs to be shown on a map.
Leaving plants along riparian margins protects the moss from wind damage and provides habitat for
species such as for brown mudfish, and other species of flora and fauna.
Condition (q) is included in the rule so Council can monitor the effects of harvesting within Schedule
2 wetlands and ensure the wetland values are maintained. Harvesters need to note that the form
requires harvesters to provide photos of the site pre-harvest (these can be the same photos as
provided under condition (a)), while harvesting is being undertaken, and post-harvest.

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Rule 7a Form for assessing area of Schedule 2 wetlands following the harvesting of Sphagnum Moss
General information
Today’s date:_______________________________________________________________________
Harvesting organisation/company:______________________________________________________
Name of harvester:__________________________________________________________________
Name and ID of Schedule 2 wetland: ____________________________________________________
Site address/ location of site:__________________________________________________________
Legal Description of area where site is located:____________________________________________
Map reference of site:________________________________________________________________
Area harvested (also include map showing the harvested area):__________________________________
Dates that harvesting was undertaken at the site:__________________________________________
Checklist of conditions to meet
Natural hydrological processes were maintained by:
 The post-harvest moss surface being near but above the water level;
 Drainage of the area has not been altered in any way;
 Only existing formed access was used to get to the harvested area;
(Note this needs to be shown on a map and attached to this form)
 Drains and weirs were not used to manipulate water levels;
The machinery used spreads the weight over the wetland by either the widening of track-
driven vehicles or using platforms for machinery to drive on;
Crushing of the moss was undertaken;
Only the upper living portion (acrotelm) of the moss was removed;
All machinery and equipment was cleaned prior to entering the wetland;
No removal of plants or moss has occurred within any riparian margins:
No containers larger than 20 liters were used to refuel machinery or equipment within the
wetland;
No fertilisers were dispersed within the wetland;
No breeding, roosting, or nesting sites were disturbed;
The site was left tidy following the completion of harvesting;
Disturbance of the area was limited to the extent necessary to undertake harvesting.
More detailed information on particular conditions
Describe how harvesting was undertaken: _______________________________________________
__________________________________________________________________________________
__________________________________________________________________________________
Describe how the machinery used for harvesting spreads the weight over the harvested area
(include photos of described machinery):________________________________________________
__________________________________________________________________________________
__________________________________________________________________________________
Please provide any other information you feel is relevant:___________________________________
__________________________________________________________________________________
__________________________________________________________________________________

187
Attach photos showing the site before harvesting has occurred, while harvesting is occurring and
post-harvest. (Note photos need to show the date they were taken)
Once compliance staff have received this form, they will organise a site visit to the site to assess the
information contained within the form.

188
Draft Permitted Activity Rule for Clearing Blackwater Creek adjoining Kongahu wetlands
Rule 27a. Clearance and Spraying of Blackwater Creek in the Kongahu Area, Karamea
The clearance of sediment, debris, and the pest plant Parrots Feather (Myriophyllum aquaticum), and
the spraying of Parrots Feather, within Blackwater Creek is a permitted activity provided that all of
the following conditions are met:
a) The Council is notified in writing of the location and extent of the activity, at least seven working
days prior to the works commencing;
b) All machinery must be cleaned before undertaking the activity or entering the Schedule 1 and 2
wetland areas to minimise the entry of petroleum products, and pest plants and weeds;
c) Existing access routes shall be used where practicable, in particular the cleared area that runs
along the bank of Blackwater Creek;
d) The bed disturbance is limited to the extent necessary to clear the sediment, debris and the pest
plant Parrots Feather;
e) The bed disturbance does not damage any riverbank or cause any flooding or erosion;
f) The natural channel width and depth is maintained to ensure the cross section of Blackwater Creek
is maintained;
g) No refuelling of equipment takes places within Blackwater Creek or any area of the Schedule 1
and 2 wetlands;
h) Sediment and debris is placed on the edge of Blackwater Creek to create a bund, with intermittent
spaces in the bund to allow some water to flow through to the wetlands;
i) No sediment or debris shall be placed within the Schedule 1 and 2 wetlands where it is likely to
result in the smothering of wetland vegetation;
j) Any fish pulled from Blackwater Creek during the clearance must be returned;
k) Aerial spraying of Parrots Feather is undertaken;
l) The site is left tidy following any clearance and/ or spraying of Blackwater Creek.
Explanation
Clearance of Blackwater Creek channel to remove sediment, debris and the pest plant Parrots Feather
is necessary to reduce the incidence of floodwaters affecting adjacent land, and the spread of the
aquatic pest plant Parrots Feather which is listed in the West Coast Pest Plant Management Strategy,
and so needs to be managed. Under this Rule, these activities will have no adverse effects on the
significant ecological values of the wetlands, and will contribute to maintaining their biodiversity
values.

189

Identifying the environmental effects of sphagnum
moss harvesting on wetlands
Envirolink Grant: C09X1626

190

191

Identifying the environmental effects of sphagnum moss harvesting
on wetlands
Rowan P. Buxton
Landcare Research

Prepared for:
West Coast Regional Council
388 Main South Road
PO Box 66
Greymouth 7840
New Zealand
August 2017
Landcare Research, 54 Gerald Street, PO Box 69040, Lincoln 7640, New Zealand,
Ph +64 3 321 9999, Fax +64 3 321 9998, www.landcareresearch.co.nz

192
Reviewed by:
Approved for release by:
Bev Clarkson
Gary Houliston
Plant Ecologist
Portfolio Leader – Enhancing Biodiversity
Landcare Research
Landcare Research
Landcare Research Contract Report:
LC3002
Disclaimer
This report has been prepared by Landcare Research for West Coast Regional Council. If used by other parties,
no warranty or representation is given as to its accuracy and no liability is accepted for loss or damage arising
directly or indirectly from reliance on the information in it.
© Landcare Research New Zealand Ltd and West Coast Regional Council 2017
This information may be copied and distributed to others without limitation, provided Landcare Research New
Zealand Ltd and the West Coast Regional Council are acknowledged. Under no circumstances may a charge be
made for this information without the written permission of Landcare Research and the West Coast Regional
Council.

194

195

Summary
Project and client

West Coast Regional Council sought an updated review of the effects of moss
harvesting following submissions received on a proposed plan change to remove
sphagnum moss harvesting from the definition of vegetation disturbance in the
Regional Land and Water Plan 2016.
Objectives

To review the techniques for harvesting sphagnum moss from wetlands on the West
Coast.

To identify any environmental effects on wetlands (positive and negative) of
harvesting.

To assess whether any identified negative effects could be managed through standard
conditions.
Methods

Previous research was reviewed.

Interviews were held with key stakeholders.

Field inspections were made to assess current techniques and impacts.
Results

Most submitters opposed to Plan Change 1 were concerned that there was no
scientific evidence presented to show that sphagnum harvesting impacts were minor,
or that such harvesting could be achieved sustainably. The international literature
suggests that sphagnum harvesting can be sustainably managed.

Traditional management has resulted in increased woody vegetation and decreased
sphagnum yields in previously harvested conservation areas, whereas current
practices on private land have increased sphagnum yields, with temporary minor
impacts on vegetation and wildlife.

The negative impacts of harvesting are generally short term and minor.
Conclusions

Both managers and harvesters wish to protect the wetlands that nurture the
sphagnum moss resource.

Few of the currently identified Schedule 2 wetlands occur on private land, and only
two of those are known to have been harvested.
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Identifying the environmental effects of sphagnum moss harvesting on wetlands

Without a rule, condition or consent process there is no guarantee that current
practices will be employed by all harvesters. The concern expressed by many of those
opposed to the rule change is that, as proposed, the plan change would allow cutting
and crushing of vegetation in any Scheduled wetland.

Whether to allow harvesting in a Scheduled wetland will depend on the ecological
values that are to be protected or promoted. Harvesting may provide useful
management in anthropogenic wetlands.
Recommendations
The options available to the Council for managing sphagnum harvesting on Scheduled
wetlands include:

Excluding sphagnum harvesting from the definition of vegetation disturbance may
present the Council with a risk under its obligations to protect biodiversity in
Scheduled wetlands.

It is probably not feasible to allow harvesting only in geographically identified
wetlands within the relevant timeframes.

Allow sphagnum harvesting on Scheduled wetlands as a permitted activity rule with
conditions. The conditions would need to be able to control the effects of the activity.

Allow sphagnum harvesting on Scheduled wetlands as a controlled or limited
discretionary activity.  Sites and harvesting operations should be considered on a case-
by-case basis.

Impose conditions through a permitted activity rule, or on any resource consent, to
enable the Council to monitor the effectiveness of the rule.

Conditions could also set guidelines for harvesting methods on Scheduled wetlands.

It is also recommended that a programme for monitoring be considered and
implemented, regardless of which option is pursued.

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1
Introduction
Sphagnum moss has been harvested from West Coast wetlands since the early 1980s from
both private and Crown land, the latter under licence. More recently most harvesting has
been from private land.
The main species harvested, Sphagnum cristatum, forms hummocks and carpets, which
often dominate large areas of wetland. This is particularly so in open areas where the water
table is high and the moss is not shaded by competing vascular plants. Excess water
promotes the dominance of mire plants and impedes the decomposition of their dead
remains, which, consequently accumulate as peat (Minayeva et al. 2017). Peatland plants
like sphagnum create conditions suitable for their own self-maintenance.
Worldwide, large areas of peatlands have been drained to facilitate agriculture, forestry and
peat extraction. These activities destroy the biodiversity, carbon storage capacity and
hydrological regulation function of fens and bogs (Temmink et al. 2017). While sphagnum
harvesting impacts are seldom this severe, careless management activities can have
negative ecological effects.
There was therefore some opposition to West Coast Regional Council’s Proposed Plan
Change 1, which sought to remove sphagnum moss harvesting from the definition of
vegetation disturbance in the Regional Land and Water Plan 2016.

2
Background
As a result of an Environment Court case in 2012 a number of minor changes were made to
the West Coast Regional Land and Water Plan (May 2014), which resulted in resource
consent being required to harvest sphagnum moss from Scheduled wetlands. This was
understood by the West Coast Regional Council to be an unintended consequence of the
Court decision, and the Council also understood that at the time the parties agreed that a
permitted activity rule would probably be sufficient to manage any adverse effects from the
activity.
In the lead up to Plan Change 1 on the Land and Water Plan (2016), the Council reviewed
existing available research on the harvesting of sphagnum moss. From this research it
appeared that the effects of the activity were negligible, and so the Council agreed to
amend the definition of vegetation disturbance to exclude the harvesting of sphagnum moss
to make it an activity that did not require consent rather than a permitted activity.
In response to notification of Plan Change 1, a number of submissions were received from
environmental groups opposed to the harvesting of sphagnum moss in Scheduled wetlands.
They disputed the Council’s understanding of the original Environment Court case and felt
that the commercial harvesting of sphagnum moss could have negative impacts on
wetlands. Local harvesters expressed a contrary view and argued that harvesting moss is an
activity that contributes to the long-term sustainability of the wetlands.
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Identifying the environmental effects of sphagnum moss harvesting on wetlands
Landcare Research was contracted to provide an independent review of the effects of moss
harvesting and to assess the Council’s options for managing Schedule 1 and 2 wetlands.
Schedule 1 wetlands have been verified by ground assessments and include some of the
significant wetlands in the region. Schedule 2 wetlands are likely to be significant, based on
aerial mapping, soils and size, but have not been assessed for ecological significance.
Ultimately, ecological assessments of Schedule 2 wetlands will be made using criteria in
Schedule 3 (Appendix 1) to determine significance, and they will either be included in
Schedule 1 or removed from Schedule 2. Specified activities on Schedule 1 and 2 wetlands
require resource consent, which under the current Plan includes sphagnum moss
harvesting.
Sphagnum wetlands are variously referred to as bogs, fens, swamps or pākihi, and
collectively these are called mires or peatlands. These types are separated by differences in
substrate and water regime, but they often co-occur (Johnson & Gerbeaux 2004).
In Westland, sphagnum peatland communities have been favoured by activities associated
with past logging of native forests. Tramways have impeded drainage and forest removal
has raised the water table. Here sphagnum occupies a transitional phase to closed
shrubland and forest that would ultimately reduce its abundance. Although forest clearance
has led to sphagnum abundance in the first instance, it is the disturbance associated with
continued harvesting of sphagnum moss (particularly cutting and crushing of vegetation)
that appears to be maintaining sphagnum dominance. These cut-over forests are now some
of the major sites of commercial sphagnum harvesting in the South Island (Whinam et al.
2003; Díaz et al. 2007).
3
Objectives
  To review the techniques for harvesting sphagnum moss from wetlands on the West
Coast.
  To identify any environmental effects on wetlands (positive and negative) of
harvesting.
  To assess whether any identified negative effects could be managed through
standard conditions.

4
Methods
Previous research was reviewed and interviews were held with key stakeholders
(environmental groups and commercial harvesters). Field inspections were made to assess
current techniques and the impacts of harvesting.

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5
Concerns expressed by submitters
These concerns fell into four main categories:

widespread loss of wetlands

protection of natural character, indigenous biodiversity and other values of wetlands
in the region

the need to ensure the natural character of wetlands and associated ecosystems
(including ecosystem functions and habitats) is sustained

the need to manage all wetlands sustainably.
Jen Miller (Royal Forest and Bird) was concerned that removing sphagnum harvesting from
the definition of vegetation disturbance would allow harvesting and associated activities to
occur on any wetland, with resulting loss of biodiversity. While current harvesters may
agree to operate in a way that is mutually beneficial for themselves and the wetlands, there
is some apprehension that without some form of control or guidelines there is no guarantee
that this would continue if, for example, the industry expanded in the future. She would like
to see a list of parameters that would exclude particular wetland types from sphagnum
harvesting.
There are certainly a number of fragile systems (generally where sphagnum growth is very
slow) that should be excluded from harvesting. These include wetland forms such as string-
bogs, domed mires, blanket bogs and tarn margins, which typically occupy upland sites
above 600 m. Very wet sites such as floating systems and some inter-dune swales should
also be excluded.
Most submitters opposed to Plan Change 1 were concerned that there was no scientific
evidence presented to show that sphagnum harvesting impacts are minor, or that such
harvesting could be achieved sustainably. The Department of Conservation (DOC) also noted
a lack of information on the impacts and scale of harvesting.
Some submitters raised concerns over the sustainability of sphagnum harvesting based on
observations that the quantity of moss removed decreased with successive harvests.
Harvesters agreed that sphagnum yields have decreased on many of the DOC concession
areas, but this contrasts with improved yields that have been achieved on some private
land. The difference between these outcomes is related to post-harvest management.
Harvesters operating on private land have had the freedom to experiment and develop
management techniques that would not be approved under current guidelines on public
conservation land, because they involve heavy machinery and the cutting of shrubs.
However, rather than being detrimental to sphagnum production, it appears that these
techniques have increased the biomass of sphagnum obtained per hectare while the
sphagnum yield on equivalent DOC concession blocks has decreased.
My cursory observations suggest that while shrub density and biodiversity have increased
on the DOC concession blocks relative to those on private land, sphagnum dominance has
declined markedly. DOC’s position throughout the appeals process was that until the scale
of harvesting is known it is not possible to determine the effects of harvesting. It is
therefore useful to look at some of the numbers.
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Scheduled wetlands in the West Coast Region occupy 57,832 ha, which is 2% of the total
area. Most of this (50,404 ha) occurs in Westland District, where only 1,042 ha (2%) is
privately owned. Overall, 3,687 ha (6%) of Scheduled wetlands in the region are privately
owned. Private ownership of Scheduled wetlands in Buller and Grey Districts is 23% and
56%, respectively. These values do not include the vast majority of wetlands that are
harvested for sphagnum. Only two of the Scheduled wetlands are known to have been
harvested in the past, and they occur on private land. The Council is unable to differentiate
between Crown-owned and privately owned land when determining rules that apply to
Scheduled wetlands.
Total sphagnum exports from New Zealand in 2006 came to 500 tonnes. To sustain this on a
6-year cycle requires roughly 500 to 1,300 ha depending on productivity, of which 80 to 200
ha is harvested annually.
There has been a decrease in harvesting concessions on public conservation land, partly due
to the decreasing yields outlined above, but also because of greater costs and uncertainty
compared with harvesting on private land. While some conservation areas exclude
sphagnum harvesting completely, harvesters can still apply for a concession. This requires
an initial payment of $1,500, plus costs for an ecological assessment of harvesting impacts
on conservation values. If the concession is granted, harvesters tend to pay higher royalties
on DOC land than on private land.
Paul Elwell-Sutton (from Haast) suggested in his submission that ‘It may be advantageous
and necessary to create a schedule of wetlands available for moss harvesting, plus
conditions governing the scale, time and mode of harvesting.’ Identifying which wetlands
could be subjected to harvesting may have some merit, as it would provide some certainty
and alleviate the fears of all parties.
However, both landowners and harvesters were worried about losing control of activities on
private land. There was concern that application of the Schedule 3 process to wetlands
where sphagnum moss is currently harvested on private land, even if not listed in Schedule
2, may have an impact on their livelihoods. They were worried that conditions might be
imposed on harvesting operations that would decrease yield, stifle innovation, or result in
sphagnum-producing wetlands being lost altogether. The latter concern has some validity,
as several wetlands have been subjected to wilful damage to lower conservation values or
converted to land uses incompatible with wetland recovery, and this has been a loss to both
conservation and the moss harvesting industry.
Site visits
Three sites on or adjacent to Schedule 2 wetlands and two sites of current moss harvesting
were visited to observe current harvesting techniques, wetland management and recovery.
Site examinations were cursory and did not include the compilation of species lists, but they
were sufficient to obtain an indication of mire health and sphagnum recovery.
Within each of the harvested sites were areas that had been harvested 6 years previously,
as well as areas where current harvesting operations were underway. These sites had been
managed by ‘crushing’ vegetation following harvest of the sphagnum.
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Some previously harvested sites were also inspected. Two of these had been harvested
approximately 6 years before. The first site, on private land, had been regularly harvested
approximately every 5–6 years. Bales had been extracted using a modified tractor to reduce
weight per unit area, with no long-term negative impacts to the wetland. Sphagnum
recovery was good, and it would currently be able to sustain another harvest. Diversity of
other native species was relatively low, and woody vegetation was concentrated on the
margins.
The second site was on the DOC estate, where presumably shrubs were not cut and bales
were removed by helicopter. Sphagnum abundance here had declined, but other native
species were doing well and woody species were becoming dominant.
A third site (HOKP119 Lake Mudgie) had been open wetland in 1987 and was where some of
the first sphagnum growth trials were established. This is now returning to dense woody
vegetation with little sphagnum evident (Figure 1.).

Figure 1. Regenerating shrubland in Lake Mudgie wetland, previously dominated by
sphagnum.
Other sites designated Schedule 2 that were not visited as part of this investigation, but with
which I am familiar, include REEP009 Rahu Saddle bogs, Ianthe Forest wetland near
HARP010, WAIP003 Ōkārito Forks, and portions of HAAP006 and HAAP008 near Haast.
Vegetation history and sphagnum mire formation
Deforestation and fire, particularly since European settlement, has altered the hydrology of
many wetland systems, favouring sphagnum dominance, and it is clear that most were drier
and woody earlier in their history (McGlone 2009).
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Many wetlands where sphagnum harvesting is currently focused would not have existed
around 1840 as they would have been forested.  While most harvesting occurs in wetlands
that most closely resemble pākihi, these sites are generally anthropogenic wetlands, having
been induced by a past history of logging, fire or other human disturbance. Forest clearance
on poorly drained soils decreases transpiration and generates waterlogged conditions that
impair the recolonisation of forest and stimulate sphagnum establishment and dominance
(Whinam & Buxton 1997; Díaz et al. 2007).  Some of these deforested sites of secondary
wetlands have become major sites for the commercial harvest of sphagnum in both New
Zealand and Chile (Diaz & Silva 2012).
If there is a desire to maintain the natural values of these anthropogenic wetlands, then
active management will be required to prevent them from slowly returning to a forested
state. In the Netherlands sphagnum harvesting was allowed in nature reserves (Denne 1983)
as harvesting helped to maintain the open character of mires by simultaneously removing
some seed plants. Equally, at higher shrub densities, these wetlands may provide important
fernbird habitat.

6
Harvesting methods
Twenty-five years ago most harvesting was done by hand, and bale extraction was by a
variety of methods, including helicopter, aerial ropeways, wooden tramways, four-wheeled
motorbikes, and in one case using a wide-tracked bulldozer and sled (Buxton et al. 1995). At
that time it appeared that sphagnum harvesting could be managed sustainably at some
sites, but some uncertainty remained over whether the resource could cope with continued
demand. Guidelines were suggested (Buxton et al. 1995; Whinam & Buxton 1997; Whinam
et al. 2003), but the results of these are unknown.

It was therefore useful to observe harvest sites where several repeat harvests had been
made with good sphagnum regrowth and what had been done to achieve this. Conversely, it
was interesting to see areas where sphagnum recovery was poor or diminished and explore
the reasons for that.

Although harvesting is still done by hand, many of the more damaging methods are no
longer used as harvesters and landowners realise the economic value of maintaining healthy
mires. The wide-tracked bulldozer and sled method for extracting bales has been developed
further. Most commercial harvesters now use heavy machinery that has been adapted to
spread the weight of the machines, either through widening the tracks on track-driven
vehicles, or by creating wooden platforms so that they can be driven on the wetlands
without altering the hydrology (Figure 2).
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Figure 2. Heavy machinery supported by a wooden platform has less ground pressure than a
person. The stump is a relic of historic forestry.

This is largely to allow the post-harvest vegetation to be crushed and left as a level surface
in close contact with the water table (Figure 3), which was the key to the success of the
original method. It also relies on operators avoiding repeat passes over the same site, which
causes rutting and drainage. The increased yields (Figure 4) that can be obtained through
this method have led several landowners to now insist that harvesters crush vegetation in
this way after harvest. Others are demanding that bales be extracted by helicopter to
maintain wetland water regimes. These methods are similar to recent developments on
‘bog grassland’ in Germany (Wichmann et al. 2017).

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Figure 3. Sphagnum wetland after harvest and crushing of vegetation.

Figure 4. Sphagnum harvest 6 years after crushing of vegetation. Yields are four to six times
greater than on sites without crushing.

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7
Impacts of harvesting
Globally there is a negative perception of sphagnum moss harvesting, particularly because it
is sometimes confused with peat extraction, which is often viewed as a non-renewable
resource. Sphagnum harvesting involves removing part of the upper, living portion
(acrotelm) of a peat bog, whereas peat harvesting removes the lower decomposed layers
(catotelm) and so has greater impacts.
Over-harvesting and drainage for agriculture or urban development have contributed to this
perception and the loss of many wetlands, especially in Europe. However, researchers have
shown that vegetation components of degraded peatlands can be restored relatively quickly
(Andersen et al. 2006). The Peatland Ecology Research Group, based at Laval University in
Quebec and working in partnership with the Canadian peat industry, have developed a moss
transfer technique that can re-establish sphagnum-dominated plant cover within 3–5 years
following restoration, with biodiversity and hydrology approaching pre-harvest conditions.
Clarkson et al. (2017) report similar recovery times in Australia and New Zealand.

This has led to investigations of sphagnum farming (paludiculture) using previously cut-over
bogs as the starting points (Glatzel & Rochefort 2017). Sphagnum farming is defined as the
sustainable production of non-decomposed sphagnum biomass on a cyclic and renewable
basis. Trials of sphagnum farming in Germany have produced biomass of 19.5 t ha−1 after 9
years (Gaudig et al. 2017) and up to 6.7 tDWha−1 yr−1 (Temmink et al. 2017). Methods
involved the installation of underground irrigation pipes and perimeter ditches to regulate
the water table, and mechanised harvesting. However, the principle of creating an even
surface for moss regrowth is similar to that developed by Westland harvesters.

There is potential for paludiculture to be successful in Westland, particularly on former
wetland soils where other agricultural land use may be less desirable. West Coast
temperatures are warmer and the growing season longer than at the European sites. While
there are obvious costs in establishing paludiculture systems, the advantages over natural
wetlands include the design of harvesting areas with access ways to achieve mechanical
harvest, greater control over associated vascular vegetation and water regimes, and
potentially better growth. Stokes et al. (1999) suggested sphagnum yields could reach
13 tha−1 yr−1 in Westland with appropriate management. In their trials Temmink et al.
(2017) found sphagnum was able to sequester nitrogen, which meant it could act to reduce
nitrogen inputs into adjacent waterways. Within limits this could make paludiculture a
useful tool on wet soils adjacent to dairy or other land uses in Westland. The N:P ratio has
proven to be a particularly useful predictor of which nutrient is limiting in oligotrophic sites
(Clarkson et al. 2004).
While growth rates in Westland are much faster, results from Finland at 62o47´N (Silvan et
al. 2017) suggest harvesting of sphagnum biomass to a depth of no more than 30 cm has a
relatively short-term (<5 years) effect on sphagnum carpet coverage and carbon
sequestration, allowing a harvesting cycle of c. 30 years. They proposed that environmental
effects would be negligible compared with the conventional extraction of white horticultural
peat, and suggested sphagnum harvesting is more comparable with sustainable forestry.
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When comparing sphagnum harvesting to forestry or agriculture conversion, Denne (1983)
concluded that sphagnum harvesting was unlikely to change the basic ecosystem structure
and function of mires. However, he suggested that some sensitive elements could be lost or
reduced, particularly South Island fernbirds, through the loss of suitable habitat, and
therefore proposed leaving some undeveloped land surrounding harvested mires. Beyond
the shelter of shrubs, sphagnum can suffer from wind exposure, therefore retaining
corridors of shrub cover is not only good for the ecological outcomes of the wetlands but
may help to improve sphagnum growth for harvesters.
Potential negative impacts
The potential ecological impacts of sphagnum harvesting in New Zealand were first
investigated in the 1980s (Denne 1983; Johnson 1988). Wetland health can decline through
changes in hydrology, water pollution, nutrient enrichment, and invasion by weeds and
pests, which lead to biodiversity loss and impaired wetland functioning (Clarkson et al.
2004). Sphagnum mires are very sensitive to human impact; for example, trampling may
induce small pools, while removal of sphagnum in other sites may cause the substrate to dry
out and slow regrowth (Denne 1983). Díaz and Silva (2012) note that indiscriminate
exploitation in Chilean wetlands could cause disruption of sphagnum ecosystems, changes
in water storage capacity and reduction of biodiversity.

These effects may be short or long term depending on their severity. Harvesting exposes
sites to the risk of weed invasion, particularly on drier margins. Gorse and Spanish heath can
be problematic, and Sphagnum subnitens can increase in areas where S. cristatum is
preferentially harvested. There is the potential risk of pollution (oil or fuel) from machinery,
and possible degradation of mudfish habitat. Dragging of bales by hand or use of quad bikes
can result in localised drainage.

Succession to taller, woody vegetation is delayed by harvesting. This can be either positive
or negative depending on the ecological values of the site (Figure 5).

Figure 5. Sphagnum wetland 6 years after harvest with regenerating forest on the margin.
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Previous guidelines (Buxton et al. 1995) suggested that sphagnum harvesting requires
careful site selection, avoiding excessively wet or very dry areas, ensuring the post-harvest
surface is near but above the mean water table level, and reseeding of the site (i.e. leaving
about a third of the acrotelm behind to speed recovery). Avoiding machinery or practices
that cause rutting or drainage of the bog was also emphasised. Failure to follow these
guidelines had resulted in some moss-producing areas being severely degraded.

The use of heavy machinery would not have been encouraged previously, but local
innovation has shown that by spreading the weight of these vehicles over a wide area they
can be less damaging than human or animal tracking. The average human male exerts about
16 psi ground pressure when walking, whereas the ground pressure of an 8 tonne Snow Cat
can be as little as 0.8 psi.

Positive impacts of sphagnum harvesting
Key wetland functions such as hydrological status are largely unchanged by sphagnum
harvesting. This is particularly important if wetlands are to recover. Hydrology is probably
the single most important determinant of the establishment and maintenance of specific
types of wetlands and wetland processes (Clarkson et al. 2004).

Harvesting delays succession to forest in anthropogenic wetlands by maintaining low-
statured vegetation, including open rush and sphagnum moss communities. Sphagnum
harvesting may be a useful management tool where there is a wish to retain the ecological
values of these communities provided there is a sufficient buffer remaining as a seed
source.

Management associated with harvesting can reduce invasive weeds and feral animals that
are also incompatible with commercial harvesting.

Native fauna
Brown mudfish are found in pākihi and other West Coast wetlands from Karamea to
Ōkārito, mostly at low altitudes (Department of Conservation 2003; Figure 6). Mudfish occur
in wetlands with natural variations in water levels, but are seldom found in water more than
0.3–0.5 m depth (O’Brien & Dunn 2007). Reduction or modification of habitat is one of the
major threats to mudfish, particularly drain clearance or activities that restrict the natural
variations in water levels. Drain clearance, especially machine clearance where spoil and
weeds are dumped on the margins, destroys the habitat for mudfish living in these drains.
Fish can also be killed as they get caught up among the spoil and weeds and stranded on the
banks.
There don’t appear to be any data on brown mudfish numbers in harvested versus non-
harvested sites. However, only one of the Schedule 2 wetlands directly mentions mudfish
(HARP024 Ianthe Mudfish Habitat). This is immediately north of a wetland where sphagnum
was previously harvested (Buxton et al. 1995). Denne (1983) suggested brown mudfish were
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likely to be displaced by harvesting, but that it was unknown what importance sphagnum
mires played in their life cycle.

Figure 6. Brown mudfish distribution (from Department of Conservation 2003).

DOC has a very good online factsheet outlining practices to protect mudfish habitat
(http://www.doc.govt.nz/nature/native-animals/freshwater-fish/mudfish/). Following are
some of the key points relevant to harvesters.


Allow natural water-level fluctuations. Avoid using drains and weirs to manipulate
water levels.

Maintain drains using mudfish-friendly methods. Planting or retaining native plants on
drain margins will suppress the growth of freshwater weeds. If physical removal of
weeds is essential, then clear only short sections, or one side of the drain at a time, to
retain habitat.

Prevent invasive fish establishing by finding out what invasive fish species are present
in the catchment around the wetland and being careful not to accidentally move them
between waterways.
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Other freshwater species that may be found associated with sphagnum mires include short-
finned eels (Anguilla australis), galaxids (Galaxias spp.) and freshwater crayfish
(Paranephrons planifrons) (Denne 1983).

Denne (1983) reports that the New Zealand Wildlife Service did not consider West Coast
pākihi to have very high wildlife values, although those with reasonably dense vegetation
were of considerable importance to the South Island fernbird (Bowdleria punctata
punctata). Preferred habitat includes dense stands of reeds with shrubs and some trees.
However, areas with low vegetation and sphagnum as a dominant carpet, or even-height
shrubbery (e.g. mānuka or gorse), are not well inhabited.

However, fernbirds do not seem to compete well with insectivorous birds in closed forest,
and Miskelly (2013) suggests that vegetation succession probably led to North Island
fernbirds dying out on Great King and Aldermen Islands. Sanders and Winterbourn (1993)
found that insects in sphagnum mires recovered quickly after harvesting. Therefore
harvesting probably has little or only a temporary impact on fernbird diet. Harvesting may
promote predator access and post-harvest control should be considered.

Experimental studies are needed to determine the effects of vegetation density, human
presence, and sphagnum harvesting on fernbird populations. However, harvesters report
that fernbirds commonly call and move around them while they are harvesting. Fernbirds
were also heard calling at Taminelli Creek and Ward Road during site visits for this project.

Other threats to wetlands include grazing by domestic stock, and feral animals. Rooting by
pigs has been observed on some wetland margins and landowners have initiated control
operations.

Significant wetlands and size
Feldmeyer-Christe and Küchler (2017) found that the quality of bog vegetation (the
proportion of specialist species) increased with distance from bog margins and associated
draining structures. This means wetland shape may be as important as total area. Deane et
al. (2017) found that the complete removal of small wetlands resulted in the highest risk to
regional species diversity for a given decrease in the total area of the regional wetland
estate. Therefore it may not be useful to restrict significant areas of pākihi to those over 40
ha in size as indicated in Schedule 3. Equally, it may be possible for sphagnum harvesting to
be compatible with species diversity goals when this involves only a portion of larger
wetlands.

Can management for sphagnum harvesting and conservation be compatible?
Just as the best sites can be selected for protection, Johnson (1988) argued it should also be
feasible to seek harvesting sites where there is little conflict with biological conservation,
where downstream hydrological effects are likely to be minimal, where the impacts of
sphagnum harvesting can be monitored from the outset, and where experimental trials can
be aimed at maximising sphagnum regrowth.

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Studies in New Zealand (Buxton et al. 1995) have shown that sphagnum height growth is
improved when growing under partial shade of other species compared to open sites.
Vascular plants reduce irradiance and water losses, and consequently maintain high relative
humidity, which provides optimal growth conditions for sphagnum. Pouliot et al. (2011)
demonstrated that the microclimate provided by vascular plants at moderate densities can
enhance sphagnum growth. They also showed that rushes can provide physical structure to
support moss growth. This has also been observed by harvesters in Westland.

Working with local harvesters to develop site-specific guidelines for moss harvesting allows
harvesters to contribute their knowledge and ensure that guidelines are workable,
sustainable and cost-effective (Peck & Studlar 2008).

8
Monitoring
Ideally, monitoring involves the comparison of treatments and controls established in close
proximity to one another and followed through time. While this was not possible for the
sites visited in this project, it was possible to compare some areas known from past
experience with their current state and gain information from their management history.
Harvested sites could also be compared with similar areas that have never been harvested
to gauge the impacts of harvesting activity. The difficulty with this is when harvesting
practices have changed or other conditions vary between sites.

Recovery can be gauged to some extent by comparing recently harvested areas with areas
where the number of years since the last harvest is known. It is possible to estimate this age
from annual changes in shoot elongation of the moss, which is most commonly associated
with red-brown bands caused by low winter temperatures (Figure 7).

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Figure 7. Annual red-brown bands associated with slower sphagnum growth alternate with
paler sections formed during more rapid shoot elongation.

Clarkson et al. (2004) list five semi-independent indicators of wetland condition based on
major threats and stress factors known to damage wetlands. The indicators are scored for
the wetland as a whole. They are:

change in hydrological integrity

change in physicochemical parameters

change in ecosystem intactness

change in browsing, predation and harvesting regimes

change in dominance of native plants.

Guidelines for scoring wetlands based on these indicators are attached in Appendix 2. Each
indicator component is scored on a scale from 0 to 5, with 5 representing the unmodified or
best condition and 0 representing the most degraded condition. The average values for each
indicator are totalled to give a score out of 25 (Table 1).

Most actively harvested wetlands should score relatively highly (20+) using these indicators,
meaning they have a low degree of modification. Suggested minimum values for each
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indicator component would be 4 on any inspection, except for harvesting level, which could
drop to 3 (25–49% actively harvested or 50–75% recovering from earlier harvesting).

Monitoring using these indicators would be valuable for ensuring that conservation values
are retained, and would also help harvesters and landowners to maintain their wetlands to
maximise sphagnum production. Permanent plots based on Clarkson et al. (2004) would
help to monitor vegetation composition, cover, and structure. These indicators also help to
demonstrate that all components need to be considered together when assessing impacts
on wetlands. Although harvesting is only one factor, it can have direct as well as indirect
effects on wetland health.

Table 1. Hypothetical example of the indicator index to determine wetland condition

Indicator
Indicator components
Specify and comment
Score  Mean
0–5
score
Change in
Impact of man-made
Old drain near one boundary,
4
4
hydrological
structures
none in wetland
integrity
Water table depth
Remains high in most areas
4
Dryland plant invasion
Low. Confined to margins
4
Change in
Fire damage
No recent evidence
5
4.5
physio-chemical  Degree of
No sediment, some minor spot
4
parameters
sedimentation/erosion
erosion
Nutrient levels
Remaining low at present
5
Von Post index (peat bogs
Plant structure distinct, yields
4
only)
yellowish water
Change in
Loss in area of original
15% of original area converted to  4
4
ecosystem
wetland
agriculture
intactness
Connectivity barriers
Some pasture conversion
4
downstream
Change in
Damage by domestic or feral  Stock excluded by fences, some
4
3.7
browsing,
animals
browsing by possums
predation and
Introduced predator impacts  Low predator access, fernbirds
4
harvesting
on wildlife
frequent
regimes
Harvesting levels
40% of wetland recently
3
harvested
Change in
Introduced plant canopy
Gorse on margins, less than 25%
4
4
dominance of
cover
cover
native plants
Introduced plant
Very little, mostly on margins
4
understorey cover
Total wetland condition index / 25

20.2

Notes: Degree of modification is assigned as follows: 5 = very low/none; 4 = low; 3 = medium; 2 = high; 1 = very
high; 0 = extreme. Source: Clarkson et al. 2004.
9
Conclusions
Both managers and harvesters wish to protect the wetlands that nurture the sphagnum
moss resource. There has been a trend towards more harvesting on private land and less on
public conservation land. Few of the currently identified Schedule 2 wetlands occur on
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private land and only two of those are known to have been harvested. Correspondingly, the
majority of Scheduled wetlands have an additional level of protection by virtue of the
processes required for any activity on the DOC estate.

Current practices associated with sphagnum harvesting, particularly cutting and crushing of
vegetation, conflict with traditional conservation management of wetlands. Traditional
management has resulted in increased woody vegetation and decreased sphagnum yields in
previously harvested conservation areas, whereas current practices on private land have
increased sphagnum yields with only temporary minor impacts on vegetation and wildlife.
Current practices may therefore also decrease the harvesting footprint.

However, without a rule, condition or consent process there is no guarantee that current
practices will be employed by all harvesters, including any future harvesters. The number of
Scheduled wetlands sought for harvesting will likely always be low, but it may be difficult for
the Council to allow harvesting as an activity that does not require consent due to potential
industry expansion or other unforeseen effects. The impact of cutting and crushing of
vegetation can be more than minor, and the concern expressed by many of those opposed
to the rule change is that, as proposed, the plan change would allow this in any Scheduled
wetland. While this is unlikely given that most Scheduled wetlands occur on conservation
land, the Council may determine that harvesting in Scheduled wetlands is more suitable as a
controlled or limited discretionary activity in order to protect values on private land.
Both harvesters and those interested in wetland conservation are seeking clarity regarding
areas that can be utilised for sphagnum harvesting. Setting geographical limits by identifying
Scheduled wetlands that are either suitable or unsuitable for harvesting would be ideal, but
this would require detailed information to enable decisions to be based on the ecological
values of each site. This is essentially the Schedule 3 process. While current methods may be
best practice for sphagnum harvesting, they do not replicate natural conditions and should
be confined to previously modified and harvested wetlands.
Whether to allow harvesting and the methods used will depend on the ecological values
that are to be protected or promoted. For example, harvesting with cutting and crushing of
vegetation will promote the continued dominance of sphagnum, whereas harvesting
without cutting or crushing of vegetation will lead to dominance by woody vegetation. So
long as no degradation of the Scheduled wetland occurs, harvesting could occur on wetland
areas that contribute to larger or significant Scheduled wetlands and may provide a useful
management tool, especially in anthropogenic wetlands. However, monitoring including
permanent plots is needed to determine rates and trends in vegetation composition, cover
and structure, to be able to assess effects and inform rules or conditions.

10  Recommendations
The options available to the Council for managing sphagnum harvesting on Scheduled
wetlands include:
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1.  Excluding sphagnum harvesting from the definition of vegetation disturbance. This
may present the Council with a risk under its obligations to protect biodiversity in
Scheduled wetlands. While the number of Scheduled wetlands involved is low, no
conclusive data exists on the impact that harvesting will have on the ecological value
of wetlands.
2.  Geographically identify wetlands suitable for harvesting in the Regional Plan and
allow harvesting in these areas only. Although ideal, because it would provide a high
level of certainty for all parties, this option is likely to require more information than
is currently available, or can be realistically obtained within the relevant timeframes,
and so is probably not feasible.
3.  Allow sphagnum harvesting on Scheduled wetlands as a permitted activity rule with
conditions. Conditions would need to be able to control the effects of the activity.
4.  Allow sphagnum harvesting on Scheduled wetlands as a controlled or limited
discretionary activity.  This would allow the suitability of sites and harvesting
operations to be considered on a case-by-case basis, and would allow the Council to
exercise discretion through the consent process. However, this option would result
in costs associated with the consent application process.
5.  Conditions should be imposed through a permitted activity rule, or on any resource
consent. Conditions could restrict harvesting to previously harvested sites or restrict
the area available for harvesting in Scheduled wetlands; for example, allowing a
small amount of harvesting (up to XXm2) or a percentage of the Scheduled wetland.
Harvesters could be required to notify the Council in advance of commencing
harvesting on Scheduled wetlands and provide specified information (e.g. yield per
hectare, percentage of wetland harvested, harvest strategy) to enable the Council to
record where harvesting takes place and to monitor the effectiveness of the rule.
6.  Conditions could also set guidelines for harvesting methods on Scheduled wetlands.
For example, if heavy machinery is used in a Scheduled wetland to optimise the post-
harvest surface, the weight should be distributed so that ground pressure is no more
than 3.5 psi (2,500 kg/m2).
7.  Monitoring using wetland indicators and permanent plots (Clarkson et al. 2004)
would be useful for both harvesters and the Council to establish baselines before
harvesting and to highlight potential threats to wetland health. Monitoring after
harvesting will help to determine vegetation patterns and rates of recovery, inform
best practice for harvesting, and inform refinements to any rules or conditions. It is
recommended that a programme for monitoring be considered and implemented,
regardless of which option is pursued.

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11  Acknowledgements
Funding for this project came from the Regional Council Envirolink Fund via contract
C09X1626 between the New Zealand Ministry of Business, Innovation and Employment and
Landcare Research. The project has benefited greatly from input from the numerous
submitters and stakeholders who have shared their views and time. I especially thank Joy
Comrie and Jane Marshall (DOC), Jen Millar (Royal Forest and Bird), Paul Elwell-Sutton, and
the harvesters who allowed me to visit their harvesting operations. Ted Brennan (DOC)
provided useful advice on site history and locations.
I thank the West Coast Regional Council and Council staff for their assistance throughout
this project, particularly Sarah Jones and Alyce Melrose for coordinating meetings with
harvesters and other stakeholders, responding to questions, and providing constructive
feedback on the report. The report was much improved by comments from Bev Clarkson
and Ray Prebble.

12  References
Andersen R, Francez A, Rochefort L 2006. The physicochemical and microbiological status of
a restored bog in Québec: Identification of relevant criteria to monitor success. Soil
Biology and Biochemistry 38: 1375-1387.
Buxton RP, Johnson PN, Espie PR 1995.  Sphagnum Research Programme: the ecological
effects of commercial harvesting.  Landcare Research Contract Report LC9495/124 for
Department of Conservation. 46 p.
Clarkson BR, Sorrell BK, Reeves PN, Champion PD, Partridge TR, Clarkson BD 2004.
Handbook for monitoring wetland condition: coordinated monitoring of New Zealand
wetlands. Wellington, Ministry for the Environment. 74 p. doi: 10.7931/J2Z60KZ3.
Clarkson B, Whinam J, Good R, Watts C 2017. Restoration of Sphagnum and restiad
peatlands in Australia and New Zealand reveals similar approaches. Restoration
Ecology 25: 301–311. doi: 10.1111/rec.12466.
Deane DC, Fordham DA, He F, Bradshaw CJA 2017. Future extinction risk of wetland plants is
higher from individual patch loss than total area reduction. Biological Conservation
209: 27–33. http://dx.doi.org/10.1016/j.biocon.2017.02.005.
Denne T 1983. Sphagnum on the West Coast, South Island, New Zealand: resource
characteristics, the industry and land use potential. MSc thesis, Centre for Resource
Management, University of Canterbury and Lincoln College.
Department of Conservation 2003. New Zealand mudfish (Neochanna spp.) recovery plan
2003–13. Threatened Species Recovery Plan 51. Wellington, Department of
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Díaz MF, Bigelow S, Armesto SJ 2007.  Alteration of the hydrologic cycle due to forest
clearing and its consequences for rainforest succession. Forest Ecology and
Management 244: 32–40. http://dx.doi.org/10.1016/j.foreco.2007.03.030.
Díaz MF, Silva W 2012. Improving harvesting techniques to ensure Sphagnum regeneration
in Chilean peatlands. Chilean Journal of Agricultural Research 72: 296–300.
Feldmeyer-Christe E,  Küchler M 2017. Quality loss of Swiss bog vegetation: the key
importance of the margins. Mires and Peat 19(3): 1–15. doi:
10.19189/MaP.2016.OMB.237
Gaudig G, Krebs M, Joosten H 2017. Sphagnum farming on cut-over bog in NW Germany:
long-term studies on Sphagnum growth.  Mires and Peat 20(4): 1–19. doi:
10.19189/MaP.2016.OMB.238.
Glatzel S, Rochefort L 2017. Growing sphagnum. Mires and Peat 20(0): 1–3.  doi:
10.19189/MaP.2017.OMB.276.
Johnson PN 1988. Sphagnum moss in Otago. Department of Conservation, Science &
Research Internal Report 34. 18p.
Johnson PN, Gerbeaux P 2004. Wetland types in New Zealand. Wellington, Department of
Conservation. http://www.doc.govt.nz/documents/science-and-
technical/WetlandsBW.pdf.
McGlone MS 2009. Postglacial history of New Zealand wetlands and implications for their
conservation. New Zealand Journal of Ecology 33: 1–23.
Minayeva TY, Bragg OM, Sirin AA 2017. Towards ecosystem-based restoration of peatland
biodiversity. Mires and Peat 19(1): 1–36. doi: 10.19189/MaP.2013.OMB.150.
Miskelly CM 2013. Fernbird. In: Miskelly CM ed. New Zealand birds
online. http://www.nzbirdsonline.org.nz/species/fernbird (accessed 29 August 2017).
O’Brien LK, Dunn NR 2007. Mudfish (Neochanna Galaxiidae) literature review. Science for
Conservation 277. Wellington, Department of Conservation. 88 p.
Peck JE, Studlar SM 2008. Establishing international guidelines for the sustainable harvest of
forest moss. Evansia 25: 65–71.
Pouliot R, Rochefort L, Karofeld E, Mercier C 2011. Initiation of Sphagnum moss hummocks
in bogs and the presence of vascular plants: is there a link? Acta Oecologica 37: 346–
354.
Sanders MD, Winterbourn MJ 1993. Effect of sphagnum harvesting on invertebrate species
diversity and community size. Science and Research Series No. 57. Wellington,
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Silvan N, Jokinen K, Näkkilä J, Tahvonen R 2017. Swift recovery of Sphagnum carpet and
carbon sequestration after shallow Sphagnum biomass harvesting. Mires and Peat 20:
1–11. doi: 10.19189/MaP.2015.OMB.198.
Stokes JR, Alspach PA, Stanley CJ 1999. Effect of water table on growth of three New
Zealand Sphagnum species: implications for S. cristatum management. Journal of
Bryology 21: 25–29. doi: 10.1179/jbr.1999.21.1.25.
Temmink RJM, Fritz C, van Dijk G, Hensgens G, Lamers LPM, Krebs M, Gaudig G, Joosten H
2017. Sphagnum farming in a eutrophic world: the importance of optimal nutrient
stoichiometry. Ecological Engineering 98: 196–205.
http://dx.doi.org/10.1016/j.ecoleng.2016.10.069.
Whinam J, Buxton R 1997. Sphagnum peatlands of Australasia: an assessment of harvesting
sustainability. Biological Conservation 82: 21–29.
Whinam J, Hope G, Clarkson B, Buxton RP, Alspach PA, Adam P 2003. Sphagnum in
peatlands of Australasia: their distribution, utilisation and management. Wetlands
Ecology and Management 11: 37–49. doi: 10.1023/A:1022005504855
Wichmann S, Prager A, Gaudig G 2017. Establishing Sphagnum cultures on bog grassland,
cut-over bogs, and floating mats: procedures, costs and area potential in
Germany. Mires and Peat 20(3): 1–19. doi: 10.19189/MaP.2016.OMB.235.

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Appendix 1 – Schedule 3: Ecological Criteria for Significant Wetlands
The criteria in this Schedule will be used to ascertain whether a wetland is ecologically significant. A
wetland is ecologically significant if it meets one or more of the following criteria:

Ecological Context
1)  The ecological context of the wetland has one or more of the following functions or attributes:
a)  It plays an important role in protecting adjacent ecological values, including adjacent and
downstream ecological and hydrological processes, indigenous vegetation, habitats or
species populations; or
b)  Is an important habitat for critical life history stages of indigenous fauna including
breeding/spawning, roosting, nesting, resting, feeding, moulting, refugia, or migration
staging points (as used seasonally, temporarily or permanently); or
c)  It makes an important contribution to ecological networks (such as connectivity and
corridors for movement of indigenous fauna); or
d)  It makes an important contribution to the ecological functions and processes within the
wetland.

Representative wetlands
2)  A representative wetland is one that contains indigenous wetland vegetation types or
indigenous fauna assemblages that were typical for, and has the attributes of, the relevant class
of wetland as it would have existed circa 1840.
3)  This criterion will be satisfied if the wetland (not including pakihi wetlands) contains either:
a)  Indigenous wetland vegetation types that have the following attributes:
(i)  The indigenous wetland vegetation types that are typical in plant species composition
and structure; and
(ii)  The condition of the wetland is typical of what would have existed circa 1840 in that:
  Indigenous species dominate; and
  Most of the expected species and tiers of the wetland vegetation type(s) are
present for the relevant class of wetland; or
b)  The wetland contains indigenous fauna assemblages that:
  Are typical of the wetland class; and
  Indigenous species are present in most of the guilds expected for the wetland
habitat type.
4)  A pakihi wetland is a representative wetland where:
a)  It is greater than 40 hectares in area; and
b)  It is dominated by a mixture of sedges, ferns, restiads, rushes, mosses and manuka
(Leptospermum scoparium) of which Baumea spp, Sphagnum spp, Gleichenia dicarpa, and
Empodisma minus are the main species.
5)  The representative wetland criterion applies to the whole or part of the wetland irrespective of
land tenure;
6)  Each wetland is to be assessed at the ecological district and freshwater bio-geographic unit
scale.

Rarity
7)  The wetland satisfies this criterion if:
a)  Nationally threatened species1 are present2; or
b)  Nationally at risk species or uncommon communities or habitats are present and either:
  The population at this site provides an important contribution to the national
population and its distribution;
  There are a number of at risk species present; or
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  The wetland provides an important contribution to the national distribution and
extent of uncommon communities or habitats;
c)  Regionally uncommon species are present; or Is a member of a wetland class that is now less
than 30% of its original extent as assessed at the ecological district and the freshwater bio-
geographic unit scales; or
d)  Is a member of a wetland class that is now less than 30% of its original extent as assessed at
the ecological district and the freshwater bio-geographic unit scales; or
e)  Excluding pakihi, it contains lake margins, cushion bogs, ephemeral wetlands, damp sand
plains, dune slacks, string mires, tarns, seepages and flushes or snow banks which are
wetland classes or forms identified as historically rare by Williams et al (2007).
Distinctiveness
8)  The wetland satisfies the distinctiveness criterion if it has special ecological features of
importance at the international, national, freshwater bio-geographic unit or ecological district
scale including:
a)  Intact ecological sequences such as estuarine wetland systems adjoining tall forest; or
b)  An unusual characteristic (for example an unusual combination of species, wetland classes,
wetland structural forms, or wetland landforms); or
c)  It contains species dependent on the presence of that wetland and at their distribution limit
or beyond known limits.

Explanation
9)  The wetland classes may be determined in a number of ways including the classification index of
Johnson and Gerbeaux (2004).
10) Wetland indigenous vegetation types are identified with reference to the dominant plant species
that are present, the structural class, wetland class and hydrosystem (see for example Johnson
and Gerbeaux (2004) or similar method).
11) The three freshwater bio-geographic units in the West Coast region are the Northwest Nelson-
Paparoa, Grey-Buller and Westland units (Leathwick et al 2000).
12) Ecological districts are described and mapped in McEwen (1987). The maps of the ecological
districts on the West Coast region have been refined by David Norton and Fred Overmars for use
at the 1:50,000 scale and are available from the Department of Conservation (West Coast
Conservancy).

1 The Threatened and At Risk categories are defined in the current version of the New Zealand threat
classification system (Townsend et al. 2008). Species are reassessed according to these categories
approximately every three years.
2 For mobile species such as kotuku, this requires some assessment of the importance of the site for
the species i.e. the intention is not to include areas such as wet pasture where these birds are
foraging.

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Appendix 2 – Guidelines for scoring of indicator components (from Clarkson
et al. 2004)
https://www.landcareresearch.co.nz/publications/researchpubs/handbook_wetland_condit
ion.pdf
Each indicator component is scored on a scale from 0 to 5, with 5 representing the
unmodified or best condition and 0 representing the most degraded condition. A ‘Specify
and Comment’ column in Table 1 (above) provides information on the reason a particular
score has been given so that it can be recalled at a later date. This is essential if the scoring
system is to be used to monitor change in condition over time, which is its main function.
The scores are based on observations made and data collected during site visits, and from
knowledge/data about the site already available.

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