SE01 DOC Evidence of S Courtney - FINAL

Transcription

SE01 DOC Evidence of S Courtney - FINAL
Before the Tasman District Council
IN THE MATTER OF
the Resource Management Act 1991
AND
an Application by Waimea Community Dam Limited for
IN THE MATTER OF
resource consents to construct, operate and maintain
the Lee Valley Community Dam, including generation of
electricity
(Application number RM140540 etc)
STATEMENT OF EVIDENCE OF SHANNEL COURTNEY
For the Director-General of Conservation
Dated 21 November 2014
Department of Conservation
RMA Shared Services
Private Bag 4715, Christchurch Mail Centre, CHRISTCHURCH 8140
Phone: (03) 371 3700
Contact Person: David Newey / Anna Cameron
Counsel: Victoria Tumai
DOCDM-[1516585] Evidence of Shannel Courtney
INTRODUCTION
1.
My full name is Shannel Peter Courtney. I am a plant ecologist having obtained a Master
of Science degree in Plant Ecology from Canterbury University in 1983. Since that time I
have been employed primarily as a plant ecologist by various Crown agencies in
Northland, Bay of Plenty, Gisborne, Taranaki, Nelson, Marlborough and Canterbury. I
am currently employed as a plant ecologist (Senior Ranger Services – Biodiversity) by the
Department of Conservation in Nelson, a position I have held for 27 years.
2.
Work experience that is relevant to this case includes undertaking ecological surveys and
natural area assessment of conservation values, vegetation monitoring, providing advice
on protected area management issues and habitat restoration, and leading threatened
plant species recovery in the northern South Island. I have been a member of the
national threatened plants panel for 14 years, which convenes regularly to assess,
update and publish threat rankings for the NZ indigenous flora.
3.
I have visited the dam site and the footprint area of the reservoir on 5 November 2009.
Earlier site inspections of threatened plants in the Lee and Wairoa catchments were
undertaken on 22 March 2006 with Sally Marx of Tonkin & Taylor, on 20 April 2006 with
contract botanist Philip Simpson, and on 9 August 2006.
4.
Inspections along the Waimea River and of Rough Island were made with Dr Graham
Ussher of Tonkin & Taylor Ltd and Martin Heine of WWAC on 30 September 2014 to
assess potential restoration sites as part of a compensation package. Compensation
options for loss of threatened plants within the dam footprint were also discussed at this
time. I also provided data to Dr Ussher of all known sites for shovel mint, the most
threatened of the native plant species affected by the dam (see paragraphs 9-15).
5.
I have read the evidence of Dr Ussher, the draft Biodiversity Management Plan attached
to his evidence, and other evidence/application documents (as necessary).
6.
I have read the Environment Court’s Code of Conduct for Expert Witnesses as set out in
Environment Court Practice Note 2014, especially in respect of statements of evidence,
procedure at hearings and expert witnesses, and I agree to comply with it.
My
qualifications as an expert are set out above. I confirm that the issues addressed in this
brief of evidence are within my area of expertise. I have not omitted to consider
material facts known to me that might alter or detract from the opinions expressed.
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SCOPE OF EVIDENCE
7.
My evidence will cover:
a.
the threatened plant species within the footprint of the Lee Valley Community
Dam: their national and regional status, numbers and extent within the project
area, distributions, habitat requirements and agents that have contributed to their
decline,
b.
proposed measures to compensate for loss of the populations of these species;
c.
proposed consent conditions required to ensure successful implementation of
compensation measures for these threatened species
THREATENED PLANTS WITHIN THE FOOTPRINT OF THE LEE VALLEY COMMUNITY DAM
8.
There are four species of native plant within the footprint of the Lee Valley Community
Dam which, due to their national or regional rarity, would be significantly negatively
impacted by loss of these populations.
They are shovel mint (Scutellaria novae-
zelandiae), rock coprosma (Coprosma brunnea), scented broom (Carmichaelia odorata
subsp. “glabrata”) and river cloak daisy (Euchiton polylepis). I shall treat these species
individually below, documenting for each its threat status and the main agents of decline
that have contributed to its status, its distribution, the size and extent of the populations
affected by the dam, and the importance of these populations with respect to the total
population of the species.
Shovel mint (Scutellaria novae-zelandiae)
9.
This is a creeping herb in the mint family (Figures 1a, 1b). Its ecology is such that it is
almost entirely confined to alluvial terraces under old-growth beech-podocarp forest,
especially black beech-mataī-tōtara forest, where it forms an open ground cover. Its
habitat requirements are very particular. It typically requires relatively fertile substrates
on leaf litter, being under mature forest comprising small-leaved canopy and
understorey species which produce dappled light. Sites are usually influenced by frost
and are subject to modest intermittent disturbance. The vector for seed dispersal is
largely water hence its restriction to riparian alluvial habitats. It is absent from coastal
and warm lowland sites and I consider this is because of the predominance of frostlimited, large-leaved canopy and understorey species within these bioclimatic zones.
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Large-leaved trees and shrubs produce too much ground shade for shovel mint to persist
and they also smother plants upon annual leaf-fall.
10.
The natural distribution of shovel mint is confined to north-western Marlborough,
namely the mid-Pelorus catchment, and the northern Nelson region (Figure 2). There
are 40 extant wild populations known of this species: 12 within the lower Tinline River of
the Pelorus catchment, 15 scattered along the Takaka valley, 5 in the Lee valley and the
remaining 8 populations shared amongst the Hacket, Roding and Wairoa Rivers (all close
to the Lee populations), the Maitai River and a western outlier in Stanley Brook in the
mid-Motueka catchment. Of the 40 known populations, 27 occur within Tasman District
and the Lee valley populations are the southern limit for the species.
11.
Most populations are small to very small, with an average ground cover extent of less
than 1m2 at each site. It is also declining, having disappeared from 10 sites where it has
been previously recorded. For these reasons it has been accorded a national threat
status of Nationally Critical (de Lange et al 2012), the definition of which is: a very small
population with a total area of occupancy of ≤ 1 hectare and with a high ongoing or
predicted rate of decline (NZ Threat Classification System, Townsend et al 2008).
Nationally Critical is the highest threat category before the category of Extinct.
12.
Only half of the remaining 40 populations of shovel mint have legal protection. This is
typical for many threatened species that are confined to the lowlands. Most land
protected for nature conservation is upland (above 600m), loss of native lowland
vegetation, especially alluvial forest, is acute and many of the surviving native forest
remnants have no legal protection.
13.
The main agent of decline by far for shovel mint is historic and current habitat loss.
Beech-podocarp forest on alluvial terraces was once common in Nelson and
Marlborough and, by strict association, so would shovel mint have been common. Most
lowland alluvial forest has been cleared from the Nelson and Marlborough regions in the
last 160 years leading to the loss of habitat for shovel mint. Secondary agents of decline,
which have become significant since shovel mint has become rare, are uprooting by pigs
and overshading by understorey species.
14.
I hold database information on all the known remaining populations of shovel mint and
have visited most of these sites. Unfortunately, I have been unable to visit the five
populations in the Lee valley. Therefore, the information I am relying on with respect to
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these populations is from vegetation reports by contract botanist Dr Philip Simpson
(2006, 2008, 2009, 2013), and personal communications with him. During his surveys,
Dr Simpson discovered three populations of shovel mint within the dam/reservoir
footprint, between the dam site itself and Waterfall Creek. He discovered a further two
small populations downstream of the dam site and above Lucy Creek. Two of the
populations of shovel mint within the dam/reservoir footprint are small, but the third
population is highly significant because of its large size, which Dr Simpson estimates as
having a ground cover extent of 10m2 (pers. comm., 12 November 2014). It is on the
true left of Lee River on a broad, low terrace just downstream of Waterfall Creek under
kahikatea-kanuka-tānekaha forest. Being familiar with the other populations of shovel
mint, I can confirm that this is the largest population known for this species.
15.
The loss of such an important population of shovel mint and its alluvial forest habitat
within the footprint of the Lee Valley Community Dam is significant as it will substantially
contribute to the trend towards extinction for this species.
Rock coprosma (Coprosma brunnea)
16.
Coprosma brunnea (Figures 3a, 3b) is closely related to sand coprosma (Coprosma
acerosa) and some botanists prefer to regard it as a form of it. However, genetic
research shows that C. brunnea is a distinct lineage within the Coprosma acerosa
complex which is supported by morphological and ecological differences. Until further
taxonomic research is conducted, the threatened plants panel, me included, consider it
better to retain C. brunnea as a species distinct from C. acerosa. The species has
typically been referred to as Coprosma acerosa and sand coprosma in the application,
but these references should therefore be changed to Coprosma brunnea and rock
coprosma respectively.
17.
Rock coprosma is endemic to the South Island and occurs almost entirely inland, its
typical habitat being riparian on bedrock banks and ledges of rivers, often within the
flood zone, or less commonly in cobbles within river beds or on broken bedrock away
from rivers in extremely dry environments. It requires high sunlight and persists where
flooding creates the disturbance necessary to maintain open habitat for recruitment.
Despite it being found widely from Nelson to Southland (Figure 4), there are only 47
collections of it lodged in registered national herbaria (NZ Virtual Herbarium). The
current national threat status of rock coprosma is “Data Deficient” because, while there
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is evidence to indicate that this species is nationally threatened or at-risk, there is
insufficient information available for the threatened plants panel to designate a threat
status with confidence. In the Nelson Region this species is uncommon, being recorded
infrequently from the Lee, Wairoa, Motueka, Wangapeka and Cobb Rivers. Populations
are usually small and scattered. The main agents of decline are invasion of riparian rock
habitats by competitive weeds such as gorse, broom, willow and barberry. It is also
palatable to goats, deer, possums, hares and rabbits. Restricting river flows to limit
degree and frequency of flooding further favours weed invasion thereby outcompeting
rock coprosma.
18.
The Lee population was discovered by Dr Philip Simpson when surveying the upper
reaches of the footprint of the dam lake on 19 March 2009 (Simpson 2009). I have not
seen the site personally, but Dr Simpson’s photographs and his estimate of 0.25ha
population size and containing and estimated 50 plants (pers. comm.) easily makes this
the largest known single population of this species in the Nelson Region, exceeding
those of the upper Cobb River.
19.
I have not surveyed the Lee River headwaters above the extent of the reservoir. It is
possible that additional populations of rock coprosma occur along these reaches as
suggested by Dr Ussher. I caveat this by noting that I have surveyed riparian habitat on
various occasions over the last 25 years along the Pelorus catchment to the east of the
Lee River, and along the nearby Wairoa River including its left branch to its headwaters,
for the presence of a suite of threatened species, including rock coprosma, and have
only found two other very small populations of rock coprosma (one in the mid-Wairoa
catchment and one in the lower Lee catchment). For similar reasons and on various
occasions, I have led surveys in the Hacket, Browning, Roding and Miner catchments,
which flow through mineral belt geology to the north of Lee River, and have not
recorded rock coprosma in any of these (Druce & Courtney 1992). Despite apparent
availability of potential sites, intolerance to ultramafic rock is likely to be the primary
reason for this absence.
20.
Due to its size and relative rarity elsewhere in the Nelson Region I therefore consider the
Lee population of rock coprosma important and its loss significant.
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River cloak daisy (Euchiton polylepis)
21.
River cloak daisy is a mat-forming herb (Figures 5a, 5b) which is naturally distributed as
scattered populations from the lower North Island and thoughout the mainly eastern
and inland parts of the South Island (Figure 6). It is a rheophyte – a species adapted to
riparian habitats within the flood zone of rivers. It typically occurs on bedrock within
pockets of accumulated silt and is a component of a specialised rheophyte turf flora. Its
low stature and tight habit provides resilience to frequent flood events and encourages
the trapping of silt which sustains it.
Indeed, flooding is the crucial driver of this
species’ ecology, as it provides silt and prevents the establishment of dense, taller
statured vegetation within the flood zone, with which it could not compete.
22.
Agents that are contributing to its decline, at least in parts of its range, are excessive
siltation of bedrock of river habitat due to upriver erosion or conversely, the alteration
of flood regimes resulting in starvation of silt and succession of turf habitat to other
vegetation types.
23.
River cloak daisy has a national threat category of “At-Risk- Naturally Uncommon” which
applies to species that occur within naturally small and widely scattered populations. It
is in decline over some of its range and due to its diminutive nature it is easily
overlooked which has contributed to limited knowledge about the ecology and
conservation of this species.
24.
It is has been collected from a total of 38 sites nationally, although due to its cryptic
nature I am sure at least as many unrecorded additional populations exist. Ten of the
known populations occur within Tasman District. These include a site that I collected it
from in 2006 within the footprint of the proposed reservoir, at the beginning of the
gorge section (grid ref: E2523857 N5968800, alt.: 180m). This is contrary to the evidence
of Dr Ussher which states that river cloak daisy was not recorded within the project site
(para 2.15(c)). I estimate the ground cover extent of river cloak daisy at this site to be
5m2.
25.
River cloak daisy is not confined to the lowland zone and is well-represented within
public conservation land where it has long-term viability. Therefore, I am not as
concerned about the loss of this population in the Lee project site compared to those of
shovel mint, rock coprosma or scented broom. Nevertheless, it is nationally at-risk and
ongoing human-induced losses in the lowlands could result in an increase in its national
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threat status. Given this, I consider the population in the Lee River of moderate
importance and its loss from the dam project to be moderately significant nationally and
significant regionally.
I concur with Dr Ussher that the loss of the bedrock turf
community, of which river cloak daisy is a notable component, is significant.
Scented broom (Carmichaelia odorata var. “glabrata”)
26.
Scented broom (Figures 7a, 7b) is a member of a distinctive broom genus, almost
entirely confined to NZ, which contains 23 species and numerous varieties. Eighteen of
these species are nationally threatened or at-risk. Scented broom is currently ranked as
not threatened, but this status should be treated with some caution. It is becoming
increasingly clear that throughout its range from Westland northwards to the lower
North Island scented broom shows distinct morphological variation which correlates
with distribution nodes (Figure 8).
27.
There are three recognisable varieties (previously described as distinct species) which
correlate to the areas of Westland-North Canterbury (var. “angustata”), Nelson-North
Marlborough (var. “glabrata”) and the lower North Island (var. “odorata”). Compared to
the Nelson-North Marlborough variety, the Westland-North Canterbury variety
proliferates vegetatively to form thickets, is more robust and leafier, with larger leaves
and wider stems. Compared to the Nelson-North Marlborough variety, the North Island
variety has thinner branchlets, and less compact, larger inflorescences (flower clusters).
28.
The Nelson-North Marlborough variety is the least common of the three varieties of
scented broom and has been collected from a total of only 15 sites (NZ Virtual
Herbarium) including the Lee River, where it is scattered along the full extent of the
reservoir footprint. By far the largest population is on the slopes above the 700m gorge
section of the reservoir footprint. I estimate there to be at least 200 individuals within
this stretch which is comparable in size only to the population in the Tinline River of the
Pelorus catchment. The Wairoa, Roding, Hacket and Maitai River populations I have
observed are all either small, or scattered and localised in comparison. This is also the
case for the North-West Nelson catchments of the Waingaro, Anatoki and Aorere Rivers
where I have also recorded this variety.
29.
Scented broom’s ecology is similar to that of rock coprosma, in that it is largely confined
to riparian sites within the upper flood zone of major rivers and most often occurring on
bedrock. It was almost certainly far more common over a range of riparian habitats
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previously but has been reduced in numbers and extent by browsing animals, which are
the main agents of decline for this species along with habitat loss and woody weed
competition. Without doubt, the large size of the population in the Lee gorge section is
by virtue of its inaccessibility to browsing animals.
30.
Given its distinctiveness from the North Island and the Westland-North Canterbury
scented broom populations and its ongoing decline and relative rarity in the NelsonNorth Marlborough regions, I consider this variety of scented broom to be “regionally
vulnerable” i.e. the total population size is 1000-5000 mature individuals and there is an
ongoing or predicted decline of 10-50% in the total population over the next 10 years
due to existing threats (adapted from national threat classification criteria, Townsend et
al. 2008).
31.
This threat status, combined with the large size of the Lee population, leads me to
concur with Dr Ussher’s assessment that the scale of ecological effect by the dam project
on this species is significant.
PROPOSED COMPENSATION FOR THE LOSS OF THREATENED PLANTS
32.
It is clear that the location of the dam was not chosen so as to avoid impacts on these
nationally or regionally threatened plants.
Avoidance would only be possible by
substantially changing the position of the dam or the proposed reservoir level. Further,
the opportunity to remedy these impacts is very limited as the riparian habitats of these
species will be permanently inundated. That leaves off-site works as the main means by
which compensation for impacts on these species can be achieved – a conclusion also
reached by the applicant.
33.
I have read the compensation package proposed by the applicant in Dr Ussher’s
evidence, the draft Biodiversity Management Plan (BMP) appended to Dr Ussher’s
evidence, and the proposed consent conditions.
34.
I endorse the requirement for a BMP as one of the consent conditions for this
application. I concur with the application of the nine principles outlined in the BMP to
guide the type of management initiatives chosen and their effectiveness. I also agree
with the over-arching objective of the draft BMP in respect of threatened plants
(4.2.1.a), which is “like-for-like” replacement that provides for the persistence of these
species at new sites.
DOCDM-[1516585] Evidence of Shannel Courtney
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35.
In my opinion “like-for-like” replacement is at least worth attempting for these species,
but I consider that some aspects of the processes required to give effect to this outcome
are far from certain.
Nevertheless, the period sought for the consent is long enough
within which to trial and refine processes that should improve degree of certainty.
36.
In my opinion, the most appropriate compensation outcome for the loss of these
threatened plants satisfies these criteria:
i.
successful long-term establishment of these species at new sites, for at least the
period of the proposed consent;
ii.
of at least the same numbers of plants (rock coprosma, scented broom) or
equivalent ground cover extent (shovel mint, river cloak daisy) that have been
extirpated;
iii.
in ecologically suitable habitats that meet the species’ ecological requirements
(e.g. old growth alluvial forest, riparian bedrock, turf community within flood
zone);
iv.
where ecological processes that contribute to habitat suitability for these species
are maintained (e.g. shade regime, flood regime, disturbance regime);
v.
where agents of decline are minimised, such as weed competition and
browsing/uprooting by wild animals;
37.
vi.
in sites that are as close to the dam project area as possible; and
vii.
in sites that are legally protected.
These need to be reflected in the consent conditions and BMP. While many of these
criteria are implied in the draft BMP and consent conditions, some are absent and few
are explicit. I recommend that there are alterations and additions to the proposed
consent conditions and/or BMP which I will detail below.
DOCDM-[1516585] Evidence of Shannel Courtney
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PROPOSED REQUIREMENTS TO GIVE EFFECT TO COMPENSATION MEASURES FOR
THREATENED PLANTS
38.
The BMP and associated Species Management Plans, which are required as consent
conditions, are the primary vehicles by which effect can be given to adequate
compensation for loss of the at-risk and threatened plants.
39.
The consent conditions which determine the content of these plans should state the
requirement to: establish and maintain, for the period of the proposed consent,
replacement populations of shovel mint, rock coprosma, scented broom and river cloak
daisy to quantities that at least match the numbers or ground cover extent of the
populations of these species lost to the dam project.
Biodiversity Management Plan
40.
To maximise the success and utility of the BMP I endorse the establishment of a
Biodiversity Technical Advisory Group comprising of plant ecologists who are
experienced in threatened plant restoration and restoration ecology. They will need to
have a good working knowledge of the species they are charged to provide advice on,
and a good working knowledge of Tasman District, especially in respect of natural areas.
41.
Within the draft BMP, the goal of Management Unit 2: Rare/threatened plant species is
“To establish replacement populations in wild candidate sites”. This should be expanded
to include a time dimension with the aspiration of self-sustainability: “To establish selfsustaining replacement populations in wild candidate sites”.
42.
The objectives of Management Unit 2: Rare/threatened plant species should clearly
state that there is a requirement to establish new populations of at least the same
numbers, or equivalent ground cover extent (“like-for-like”), for each species and
thereby clearly define what “replacement” means in the goal.
43.
Another important addition to the objectives is that these populations are to be
managed so that they are maintained at the prescribed replacement numbers / ground
cover extent throughout the period of the consent.
This objective needs to be
translated through to the actions.
44.
There is no mention of compensation measures for river cloak daisy and how they are to
be implemented. As this species occurs within the reservoir footprint it should be
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included in the BMP with compensation actions in Management Unit 2
(Rare/threatened plant species) and Management Unit 3 (Downstream forest
restoration and turf gorge protection).
45.
The Management Unit 2: Rare/threatened plant species objectives indicate the
minimum number of newly established populations and where they should be
established. I suggest that the total numbers of plants/ ground cover extents are stated
here also – currently they are only mentioned in the performance measures. I estimate
that there are at least 200 individuals of scented broom in the dam project area and so
this should be the target replacement number in lieu of an accurate census. Shovel mint
and river cloak daisy replacement size should be measured by ground cover extent, i.e.
at least 10m2 for shovel mint and 5m2 for river cloak daisy. Fifty individuals of rock
daisy, as stipulated, is the correct minimum number of replacement individuals for this
species.
46.
For all species, it is a good principle to prioritise the Lee River in selecting candidate sites
for establishment. This has been prescribed for shovel mint and scented broom, but
should also be specified for rock coprosma and river cloak daisy. In addition, there
needs to be the ability to establish populations in sites further afield if there are no, or
limited, suitable sites in the Lee, or if trials show them to be unsuitable. Alternative sites
are provided for the draft BMP only for shovel mint but should be extended to include
the other three species.
47.
Mt Richmond Forest Park (MRFP) is nominated in Dr Ussher’s evidence (Table 6) (but not
in the draft BMP) as the main area to receive shovel mint transplants. I consider this
area largely unsuitable for several reasons. The two main river systems in MRFP are the
Pelorus and Wakamarina. The alluvial terraces of these rivers, which are the required
habitats for shovel mint, fall largely outside of the Park and have been cleared of alluvial
forest. Further, there has never been shovel mint recorded from MRFP. As the Park
supports the least modified forest ecosystems in these catchments, it is where one
would most likely expect shovel mint to persist and thrive if suitable habitat existed.
48.
Similarly, the prescribed recipient sites for rock coprosma in MRFP (6.2 Procedure 2c), I
believe, will have a high chance of failure, because if the habitat requirements were
suitable for this species, it would be present at these sites already.
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49.
Actions in Management Unit 2: Rare/threatened plant species of the draft BMP need to
include:
i.
management of the recipient sites for the consent period (should the species
require it) to optimise conditions required for the establishment and maintenance
of the transplanted populations,
ii.
supplementation of the populations for the consent period (should the species
require it) to maintain replacement numbers / ground cover extent
50.
Procedure 1 of Management Unit 2: Rare/threatened plant species in the draft BMP
includes maintaining nursery stock only for the period up to new population
establishment. If new populations are to be maintained over the period of the consent
then, depending on how self-sustaining they are, they will likely require
supplementation to maintain at replacement numbers.
To achieve this, salvaged Lee
River stock of all four species would need to be maintained in nursery cultivation for the
consent period.
Cultivated rock coprosma and scented broom would provide
appropriate and convenient seed sources for the seed transplanting necessary to
establish and maintain these species.
51.
Trial transplantation should be undertaken for all four species not just for shovel mint
and scented broom as prescribed in Procedure 4.
52.
The performance measure for “successful establishment of a self-sustaining population”
(last cell in performance measure table of Management Unit 2: Rare/threatened plant
species) should be detection of the presence of recruitment and/or vegetative spread by
transplanted individuals, not by the presence of fruiting/seeding individuals as
suggested. Unless there is recruitment transplant sites will ultimately fail. Presence of
fruiting/seeding transplanted individuals could be a separate performance indicator but
it does not infer successful recruitment.
53.
I note that the contingency suggests a period of 5 years after which the BTAG can
redirect funds from any failed attempts at translocation. From my experience with
translocation projects this is too short a period, especially for woody species which take
several years to establish. Five years does not provide enough time to assess trials,
identify and address problems, review and refine techniques, or redirect translocation
efforts to new sites. I suggest a minimum period of 8 years for the herbs: shovel mint
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and river cloak daisy; and 10 years for the woody species: rock coprosma and scented
broom.
Species Management Plans
54.
Species Management Plans are proposed for each of shovel mint, rock coprosma and
scented broom as part of the consent conditions. Given that river cloak daisy is also
impacted by the dam, there should also be a requirement in the consent conditions for a
management plan for this species.
55.
Each Species Management Plan should be prescriptive enough to enable its
implementers to achieve the goal and objectives of the BMP for Management Unit 2.
Each plan should contain the following as goals, objectives, protocols, actions,
conditions or requirements:
i.
that new populations will be established that replace the numbers/ground cover
extent of the populations within the area affected by the Lee Valley Community
Dam;
ii.
that new populations shall be maintained at these numbers/extents for the
consent period;
iii.
that plants within the project footprint shall be salvaged for re-establishment
purposes;
iv.
that collection methods of salvaging plants shall be such as to maximise the
genetic diversity of the material collected;
v.
the preferred type of material salvaged (seed, cuttings, and/or whole plants);
vi.
the target number of sites at which the species will be established;
vii.
the target number/ground cover extent of plants to be newly established and
maintained;
viii.
ecological requirements for the species to inform site selection for new
populations;
ix.
a proposed programme, with methods, of: survey, assessment and selection of
candidate sites for population establishment;
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x.
candidate sites must be selected for the purpose of maximising the chance of
creating populations which are self-sustaining; the site selection process must
therefore take account of: suitability of habitat and ecological processes for the
species, achievability of managing threats and maintaining suitable habitat, ease
of access for ongoing management / monitoring, and legal protection of the site;
xi.
requirement to maintain supplementary plants in cultivation as a permanent
source for any ongoing transplant material needs, and as insurance against all
transplants failing;
xii.
nature, purpose and extent of planting trials;
xiii.
cultivation and transplant protocols including biosecurity, timing of transplanting,
methods of transplanting;
xiv.
implementation of protection measures, if required, against known or potential
agents of decline, such as weed control, wild animal control, fencing/caging;
xv.
post planting maintenance of the populations and habitats to ensure persistence
at least for the period of the consent and to increase the likelihood of recruitment
and long-term establishment;
xvi.
a programme of supplementing new populations with additional transplants
should the numbers/ground cover extent fall below target;
xvii. monitoring and reporting provisions, including time bound targets and
measurable, relevant indicators of success;
xviii. resourcing needs; and
xix.
56.
a review period.
My remaining comments expand on Species Management Plan content above (54 i-xix)
or are general in nature.
57.
The method of collection of propagation material must aim to maximise the genetic
diversity of plants cultivated for transplanting. This will minimise loss of unique genes
and contribute towards the success of transplanting initiatives. This can be achieved by
collecting all the known shovel mint and river cloak daisy populations from within the
dam/reservoir footprint and sampling from as wide a range as possible of the dam/
reservoir footprint populations of rock coprosma and scented broom. This is especially
important for shovel mint and scented broom which have limited pollination or seed
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dispersal ability by which to mix genetic material. The likelihood of the occurrence of
unique genetic material in the Lee populations is therefore high.
58.
Maintenance of Lee stock of shovel mint in cultivation will provide an insurance
population against loss of this genotype from transplant attempts as well as provide
source material for supplementation and further transplant attempts if required.
59.
Salvage of whole plants of shovel mint and river cloak daisy are preferred over cuttings
or seed as it makes best use of the plants, is less reliant on timing and allows quicker
establishment of cultivated stock. These herbs do not lend themselves to propagation
by cuttings. Conversely, cuttings or seed are preferred for rock coprosma and scented
broom due to difficulties with whole plant salvage. They both lend themselves well to
cutting-grown and seed-grown propagation. Fortunately, all four species are relatively
easy to grow and maintain in cultivation.
60.
I contend that there is moderate uncertainty about the ability to successfully establish
and maintain wild populations (contrary to Dr Ussher’s evidence assessment, Table 6).
This is mainly because sites with suitable ecological conditions, especially in the case of
shovel mint, are rare; or their dynamic nature, such as riparian and flood zones,
presuppose a high inherent risk of loss. Nevertheless, with the long period of the
proposed consent and taking regard of my recommended amendments to the consent
conditions and BMP, these will provide the time and framework in which to trial and
manage sites to decrease this uncertainty
61.
Scented broom will need to be established on bedrock habitat to provide long-term
establishment and protection from browsing animals. This can best be achieved by
direct seed sowing into fissures of riparian rock habitats.
62.
Pig control by caging will be required for shovel mint that is transplanted at sites
accessible to pigs to ensure that the populations are not uprooted.
63.
I encourage the use of scented broom and rock coprosma as amenity plantings on
constructed landforms associated with the dam, but as this environment will not provide
the conditions suitable for long-term persistence of wild populations, they shouldn’t
substitute for the establishment and maintenance of 200 individuals of scented broom
and 50 individuals of rock coprosma at suitable site in the wild.
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CONCLUSIONS AND SUMMARY
64.
There are four species of nationally and regionally at-risk or threatened plants that I
know to occur within the footprint of the dam project area. They are shovel mint
(Scutellaria novae-zelandiae), rock coprosma (Coprosma brunnea), scented broom
(Carmichaelia odorata subsp. “glabrata”) and river cloak daisy (Euchiton polylepis). I am
a member of the national threatened plants panel which, in 2012, reviewed and
updated the threat status of the NZ flora and assigned the current threat rankings to
these species.
65.
For each of these species, I have provided details of their threat status, national
distributions, ecology and habitat requirements, agents which have contributed to their
decline, and their numbers and extent within the dam project area. I have assessed the
relative importance of these populations and conclude that their loss is significant due
to the size of the affected populations and the rarity of the species.
66.
Avoidance or mitigation of impacts to these species is not possible without major
changes in the position and/or height of the proposed dam. This leaves off-site
compensation as the only achievable method of redress. That being the case, I agree
with off-setting this loss by “like-for-like” replacement even though the ability to fully
comply with the principles of certainty of outcome, permanence and sustainable
solutions will be difficult. I provide criteria which I consider need to be fulfilled to
provide adequate compensation.
67.
I recommend that consent conditions need to require the establishment and
maintenance, for the period of the proposed consent, of replacement populations of
shovel mint, rock coprosma, scented broom and river cloak daisy to quantities that at
least match the numbers or ground cover extent of the populations of these species lost
to the dam project.
68.
I consider the proposed Biodiversity Management Plan (BMP), Biodiversity Technical
Advisory Group and Species Management Plans to be useful tools to give effect to the
consent conditions. I have provided various comments and recommendations on the
content of these plans and the credentials of the BTAG.
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69.
I note that river cloak daisy is not provided for in the consent conditions, other evidence,
or the draft BMP. It is a nationally at-risk species with few recorded locations. The
population in the dam project area is at least regionally significant and therefore,
provision for its compensation should be included in the consent conditions and the
Biodiversity Management Plan, and a Species Management Plan is also required for it.
70.
I have commented on matters in the draft BMP relevant to compensation for the four
affected plant species, specifically suggesting changes to the goal, objectives, actions,
procedures, performance measures and contingencies.
71.
There are very limited details in the consent conditions and draft BMP regarding the
required content of the Species Management Plans.
I have outlined the content
required for Species Management Plans and propose that they are added to the consent
conditions and/or included in the BMP.
72.
I believe the salvage of plants within the area affected by the Lee Valley Community
Dam is feasible, and propagation and maintenance in cultivation of the four species
should not pose any difficulties. I contend though, that the key challenge will be to find
suitable recipient sites that will provide a good chance of sustaining in the long-term
replacement populations with minimal ongoing management. The success of “like-forlike” compensation for the loss of these species will largely depend on overcoming this
challenge.
Dated 21 November 2014
Shannel Courtney
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REFERENCES
de Lange, Peter J., Jeremy R. Rolfe, Paul D. Champion, Shannel P. Courtney, Peter B. Heenan,
John W. Barkla, Ewen K. Cameron, David A. Norton and Rodney A. Hitchmough, 2013.
Conservation status ofNew Zealand indigenous vascular plants, 2012. Department of
Conservation, Wellington. 70 pp.
Druce, A.P., and Courtney, S.P. 1992. Indigenous higher plants of Roding River and Hacket
Creek Mineral Belt, Bryant Range, Nelson, 150-800m. Unpublished list number 329.
Heenan, P.B. 1996. A taxonomic revision of Carmichaelia in New Zealand (part II). New
Zealand Hournal of Botany, vol.34: 157-177.
New Zealand Virtual Herbarium: http://www.virtualherbarium.org.nz
Simpson, P. 2006. Botanical values of the Wairoa and Lee River Valleys - Assessment in
relation to possible dam and reservoir sites. Uruwhenua Botanicals report for Tonkin and
Taylor Ltd.
Simpson, P. 2008. The Lee River Dam and Reservoir – Impacts on vegetation at the site and
downstream. Uruwhenua Botanicals report for Tonkin and Taylor Ltd.
Simpson, P. 2009. Lee River Water Augmentation Proposal: report on the vegetation along
the upper reach of the proposed reservoir. Uruwhenua Botanicals report for Tonkin and
Taylor Ltd.
Simpson, P. 2013. Lee River dam vegetation update. Uruwhenua Botanicals report for Tonkin
and Taylor Ltd.
Townsend, A.J.; de Lange, P.J.; Norton, D.A.; Molloy, J.; Miskelly, C.; Duffy, C. 2008: New
Zealand Threat Classification manual. Department of Conservation, Wellington. 30 pp.
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Appendix 1:
Plant photographs and distribution maps
Figure 1a, 1b. Shovel mint (Scutellaria novae-zelandiae) showing ground cover habit, dappled shade habitat, erect
flowering stems, flowers and distinctive shovel-shaped seed capsules (arrow).
Figure 2. Distribution of shovel mint (Scutellaria novae-zelandiae) indicated by localities of all the known extant
populations of this species – a total of 40 sites.
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Figures 3a, 3b. Rock coprosma (Coprosma brunnea) showing wiry
habit and cobble riverbed habitat, copper-coloured stems and
translucent blue-flecked fleshy fruit.
Figure 4. Distribution of rock coprosma (Coprosma brunnea) indicated by localities of all the known collections of this
species – a total of 47 sites. (Adapted from NZ Virtual Herbarium).
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Figures 5a, 5b. River cloak daisy (Euchiton polylepis) showing tight mat habit and rheophyte turf habitat, felt-backed
leaves with long-stalked daisy heads.
Figure 6. Distribution of river cloak daisy (Euchiton polylepis) indicated by localities of all the known collections of
this species – a total of 38 sites. (Source: NZ Virtual Herbarium).
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Figures 7a, 7b. Scented broom (Carmichaelia odorata var. “glabrata”) showing tall, weeping habit, leafy stems and
dense flower clusters.
Figure 8. Localities from which scented broom has been collected, highlighting the distribution of three
morphologically distinct varieties: var. “angustata” from Westland-North Canterbury,
var “glabrata” from Nelson-North Marlborough and var. “odorata” from the lower North Island.
(Adapted from Heenan 1996). Variety “glabrata”, which is the Lee River variety, is the least common of the three
varieties.
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