s59(2)(a)(i) cumulative effect important to consider time
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Based on 35
years
extraction &
conservative
assumption
about France
S59(2)(a)(i) Cumulative effect
Important to consider time scale and volumes, and consequent flow
through impact on the environment
& ‘first time nature’ in this regard
‘conservative for
TTR, as based on
50 million tonnes =
27million cubic
meters – so
includes downtime!
No downtime =
70million tonnes
p.a.
TTR will be the
largest dredger-
consumer of heavy
fuel oil, by quantity
and time scale – as
it GRINDs ORE
which is hugely
energy intensive,
especially for
magnetite
1
Cost to convert away from HFO?
My guess $45million
Question put at Hearing to Shawn
Thompson & not answered
World-wide efforts to build low
emission ships
e.g. Spartacus del. 2019
S59(2)(a)(i) Cumulative effect
Important to consider time scale and volumes & location of Heavy Fuel Oil
emissions
S59(2)(i) The EPA must take into account best practice in relation to an
industry or activity
TTR could not
provide an
equivalent ship
burning the same
HFO
2
IMO CONVENTION
Annex VI NZ hasn’t signed up to
HFO 35,000 ppm
Marine Gas Oil 1,000ppm
Marine Diesel Oil 5,000ppm
Emission control areas covering EEZ of North
America, Baltic Sea, English Channel will begin to
use Marine Gas Oil (1,000ppm),
from 2020 ships sailing outside ECA will switch to
Marine Diesel Oil (5,000ppm)
Aviation and shipping are excluded in Government’s
initiatives to reduce greenhouse gas emissions through
the ETS
Maritime NZ ‘installations’ max $25million
s59(5)
Despite subsection (3), the EPA must not have regard to—
(a)
trade competition or the effects of trade competition; or
(b)
the effects on climate change of discharging greenhouse gases
into the air
16 super ships
emit as much
sulphur as the
world’s fleet of
cars3
Christina Dianne D2 (3-5m) X2
Million tonnes 218.96 241.57 27 68
218.96
241.57
27
68
HIGH GRADE ORE SITES, MILLION OF TONNES EXTRACTED OVER THE LIFE OF THE PROJECT
Dianne
D2
X2
35-42m
depth 21-43m
depth
19-25m
depth
25-36m
depthChristina
Diagram pg 9 IA 2014
10 years to
extract all 4
sites4
• “The importance of protecting” in sections 59(2)(d) and (2)(e) indicate that particular
emphasis should be given to the protection of:
• (a) biological diversity and integrity of marine species;
• (b) ecosystems and processes;
• (c) the habitats of threatened species.
SECTION 59(2)(D) & (2)(E
Page 587
Hearing
22/2/2017
5
Mr Holm, page 13 Transcript “Work has been done on existing environment and
potential effects”
S(4)(1) environment means the natural environment, including ecosystems and their constituent parts and all
natural resources, of—
“baseline is not being used as a proxy for
establishing the existing environment”
6
39IMPACT ASSESSMENT
(1)
AN IMPACT ASSESSMENT MUST—
(A)
DESCRIBE THE ACTIVITY FOR WHICH CONSENT IS SOUGHT; AND
(B)
DESCRIBE THE CURRENT STATE OF THE AREA WHERE IT IS PROPOSED THAT THE ACTIVITY WILL BE UNDERTAKEN AND THE
ENVIRONMENT SURROUNDING THE AREA;
(2)
AN IMPACT ASSESSMENT MUST CONTAIN THE INFORMATION REQUIRED BY SUBSECTION (1) IN—
(A)
SUCH DETAIL AS CORRESPONDS TO THE SCALE AND SIGNIFICANCE OF THE EFFECTS
(3)
THE IMPACT ASSESSMENT COMPLIES WITH SUBSECTION (1)(C) AND (D) IF THE ENVIRONMENTAL PROTECTION AUTHORITY IS SATISFIED
THAT THE APPLICANT HAS MADE A REASONABLE EFFORT TO IDENTIFY THE MATTERS DESCRIBED IN THOSE PARAGRAPHS.
NO
CAWTHRON REPORT: “it is
likely that macro-algal beds
occur at levels consistent with
the EEZ (2012) sensitive
habitat criteria
NO sub-tidal reef
habitat mapping,
no food-web work
Bryozoan
nursery ground for fish
Provide same role as a coral
reef, provide for biodiversity:
Abby Smith7
Unknown
8
HR Wallingford
NIWA PLUME MODELLING
PLUME – dynamic
movement by wave and
wind – using ‘average rate
of discharge’
Ignore as deemed insignificant:
1. Propellor
turbulence/resuspension
2. Suction head
3. Erosion of km’s of mounds
Lab tests3D model
Static tonnages used.
Doesn’t take into account ‘worse
case’ increases occurring for x%
of days.
Ecological load under estimated
by modelling
No Project-site
testing
NIWA
1DV
model
Beaker
test
9
I have prepared in-depth,
fully referenced,
explanations of errors and
information gaps with
HRW – majority not
addressed
Lack of experts/non-
experts conducting a
detailed review of non-
redacted information re
plume modelling
ECO-SYSTEM
MPI Report
125
Habitats
significant
for finfish
Leather jackets: especially in
association with rocky reef,
feed on sponges and ascidians,
juveniles recruit into Ecklonia Radiata
plants
Juvenile snapper, terakihi, blue cod,
leatherjacket often associate with 3D
floor structure & biogenic habits:
bryozoans, sponges, kelp forests,
horse mussels, seagrass
‘
Sustainable-
Seas’
ATLANTIS
MODEL – Golden
Bay, Tasman Bay
Key
biological
habitats
Food
web
linkages
What factors
influence
abundance of
scallops &
snapper
CONNECTIVITY
= KEY
MPI report expands on the findings of Hurst et al. (2000a), using information that has been published in the last 12
years, including recent work both in New Zealand and overseas. We also include some new thinking and conceptual
frameworks that have evolved since that time, for example around nursery habitats and migration dynamics
Blue Cod: in association with light
foul (reef edges, shingle/gravel and
biogenic structures, or sand close to
rocky outcrops. Small cod
association with bryozonas (Vooren
1975) and polychaetes & salps
during spring
No such
modelling done
by TTR 10
SPONGES ARE AN IMPORTANT HABITAT & A ‘SPONGE GARDEN’ MEETS
‘SENSITIVE HABITAT CRITEREA
RISKs:
NO sponge expert evidence,
NO survey work for sponges,
NO DOC survey work for
South Taranaki (other than the
N& S Traps)
Seives of
planktonic
algae and
bacteria,
filter 1,000
times their
own
weight,
they
consume
much of the
production
of local
algae
Diametre of 1m
= 80 years old11
Through their benthic-pelagic coupling, some of the
densest sponge aggregations have a significant local or
regional impact on major biogeochemical cycles and food
webs
Day 1 Transcript
1. A.J.M. Zainal, D.H. Dalby, I.S. Robinson
2. Monitoring marine ecological changes on the east coast of Bahrain with Landsat TM
3. Photogrammetric Engineering and Remote Sensing, 59 (3) (1993), pp. 415–421
o Abstract
The main aim of this study was to assess the potential of Landsat TM for detecting and quantifying
marine habitat changes on the Fasht-Al-Adham reef complex of the east coast of Bahrain. It was
found that the problems can be significantly reduced by subdividing the images around the change
areas and then classifying each subscene independently after appropriate masking of deep water
areas. The results indicated that between 1985 and 1992, an estimated total of 38,700 m2 of dense
corals, 1.8 × 105m2 of lower density corals, and 10.2 × 106m2 of seagrass areas were lost.
“phenomenal fluxes of
matter and energy from
sponges”
“significant local or
regional impact on food
webs”:
NZ Study: Any loss of
canopy, e.g. Ecklonia
radiate might have
negative effects on
sponge assemblages
and affect over
biodiversity
12
spawning sites - social
transmission of
knowledge (Warner
1988, 1990.
TTR
DOC
locals
hard rock outcrops (dredges at Sites 5 and 6 nearshore
study) accounted for more than 25% of all specimens and
61% of all species collected during the survey13
nearshore
14
Trevally
fishing
5
7
53
50
42
46
20
15
12 3.7
60 2.6
8 2
RISK: Desk-top study based on ‘outside
region dives’ & desk-top study – not
reflective of South Taranaki 16
20 0.2
17
Common Roughy ‘rare’
according to NIWA!
Eklonia
Radiata
1
occurance
in the inner
shelf
RISK: No diver
transect survey
work –
understate algal
cover
18
TRC
cautionary
note
TARANAKI REGIONAL COUNCIL SUBMISSION
19
20
TARANAKI REGIONAL COUNCIL20% reduction in
water column PP
over 704km2
2014:
50%
reduction
2016:
31%
reduction
21
Duration of reduced light 1-6
months
Reduction of up to 65% in
benthic light
Up to 9km away reduction of
29%
The decline in benthic light due to dredging, relative to reference conditions, was greatest in
October-December at most sites, reduced by up to 6 mol m-2 d-1 . This is the time that under
background conditions the maximum daily light was observed. From the limited data available
for NWWA, this appears to be a time of rapid growth and reproduction for seagrasses, so
declines at this time are likely to have a large impact on seagrass.
22
Christina Dianne D2 (3-5m) X2
7.8
8.4
4
7.5
DEPTH IN METERS
Metal
testing
3 samples:
50%
62%
25%
of depth
tested
Metal
testing
2 samples:
22%
55%
of depth
tested
Metal
testing
NIL
Metal
testing
NIL
RISK:
50%
GEOGRAPHIC
AREA NOT
TESTED
RISK:
45% (av.) of
depth tested for
Christina &
Dianne
Lack of
environmental
investment in
2016
Test samples
obtained in
2013 with ‘old
technology’
equipment –
no further work
done
RISK: DEPTH PROFILES
UNKNOWN – 11m?
No
Cumulative
impact
assessment
from copper
release from
hull: 23
Pg 17
Environmental
risk
assessment
for MfE (done
by NIWA) fails
to give Vopel’s
cautionary
note – about
limited depth
and
geographic
sampling
Additional analyses of sediment slurry collected to a maximum depth below the
seafloor of 18 m, however, did not reveal evidence for such trend. BUT 18m
results different than core samples, so questionable conclusion. Need statistical
work.
50%
tested
62%
sampled25%
sampled
22%
sampled
55%
sampled
0% sampled
for D2 and X2
24
25
“Baseline & ongoing monitoring will address” the uncertainty that
remains due to not sampling across the mining area, and at depth
greater than 5 metres http://www.epa.govt.nz/EEZ/EEZ000011/Mark_James_Re
sponses_to_questions.pdf
26
“difficult
to obtain
samples
”
IMPACT OF IRON-ORE GRADE
27
Watch condition 24 in terms
of this variabililty:
First ten years will look
‘better’ than next ten years
TTR need to formally apply
under s87
CONDITIONS
Agree with EPA advisor - condition on max flux by sediment size.
Agree with adopting DOC’S 2014 RECOMMENDATIONS
RISK:
NUMEROUS
ISSUES TO BE
AWARE OF IN
THE
CONDITION
SETTING e.g.
DOC and TTR in
2014
28
48 Tonne < 8microns
2014 Condition 5(b((ii)
OUTPUT
CONDITION
“When averaged over
the reported period the
occurrence of <8micron
sediments does not
exceed 1.8% of the
total sediment
extracted
2016 Condition 47e
INPUT CONDITION RISK:
1. NO OUTPUT CONTROL
at source of discharge
2. Averaging condition
unsuitable – see DOC ’14
& my graph below!
3. Outputs, such as 13% to
1% of material can go to
milling would not be
captured by an input
conditon
.
29
DOC 2014:
ROM PSD is not an
effective
mechanism
2014: TTR favours
relaxing constraints of
PSD, if Plume effects
are less than
predicted
Do not agree – if a condition is
presented on this:
Danger with this: variability over the
life of the mine – different mud lenses,
different iron-ore concentrations,
different grind technology
DOC 2014: mass flux and PSD distribution is an effective mechanism
’
EPA Decision Document DOC =
Longdill
30
DOC s44 response
Pg 159 of my
submission31
DOC 2014 not satisfied with ‘averaging’ – RISK allows for short period of high fines
I agree with DOC.
The EPA got K Pratt 3-month rolling
average stmt TOTALLY INCORRECT
– have notified EPA of this32
Disagree that these are the worst case parameters
33
“ TIMES WHERE EXTRACTION WILL BE GREATER THAN 8,000 TONNES
PER HOUR, TO CATCH UP ON DOWNTIME”
‘design extraction rate’ is different
to ‘ship capacity extraction rate’
Proposed this as a monthly
average last time
Extract from
EPA
Decision
2014
34
TCMA COULD BE MORE ECOLOGICALLY
SIGNIFICANT THAN PREVIOUSLY THOUGHT
Results suggest sensitive marine habitats and threatened
taxa are likely to exist within the TCMA,
Beaumont et al. (2013) suggest the South Taranaki area may be more diverse than some of the previous
references
and charts suggested.
Nemertesia elongata is a leptolid hydroid. It is a habitat-
forming hydroid, 17-14 km from N&S boundary 0-50m
depth, Eurygonias hyalacanthus is a type of pin-cushion
star found in high current deep sands and gravels (DOC
2011), similar to those found offshore from Patea,
Bryozoan near Grahams Bank (approx. 40 m depth, 17
km offshore, Euchone sp. A was reported. Similar to
chaetopterid worms, this sabellid worm binds the
surrounding sediments together to
form its tube
35
RISK: ISSUES RAISED IN SUBMISSION
NOT CONSIDERED BY EXPERTS
Issue not mentioned
anywhere in
Transcripts
Matt Brown’s diagram
– missing thrusters
36
http://www.citicpacificmining.com/templates/OperationalEn
vironmentalManagementPlan.pdf37
The WAMSI Dredging Science Node is one of the largest single issue research programs in Australia meeting the needs of the State Government and industry to improve their understanding of how key primary producers are affected by dredging-related pressures.
The WAMSI Dredging Science Node is made possible through $9.5 million invested by Woodside, Chevron and BHP as environmental offsets.
A further $9.5 million has been co-invested by the WAMSI Joint Venture partners, adding significantly more value to this initial industry investment.
The node is also supported through critical data provided by Chevron, Woodside and Rio Tinto Iron Ore.
38
2014: 1,860km2
Site A: 30%
reduction &
Site B: 43%0.04mol photons
BENTHIC MICRO-ALGAE REDUCTIONS
2016:
3,805km2
Site A: 27%
reduction0.04mol photons
Ignored reef
primary
productivity
39
OBIS, Mollusc &
Algae data TePapa:
1 sponge record
Conclusion: most
taxa have been
poorly sampled in
the study area
compared to may
coastal areas of
NZ
40
NIWA’S
SPECIFY
DATABASE –
2 species of
sponge
CAUTION:
NOT
QUANTATIVE
DATA
CAUTION:
A SUB-SET OF
SPECIMENS
ARE
RECORDED
INTO
SPECIFY41
2014 Application: percentile 50 and 99
42
HOW THE <8 MICRON HAS CHANGED 2014 TO
2016
Almost an Olympic
sized swimming
pool equivalent of
mud per day
43
KEY ISSUES
44
FEBRUARY 2017 CONDITIONS REPORT, PAGE 10 2.1 “THIS
SECTION BRIEFLY DESCRIBES TTRL’S PROJECT (GENERALLY
ADOPTING TTRL’S DESCRIPTION)”
MISSING ‘the grinding of
ore’ & the de-salination plant
ERROR:
DISCHARGE FROM HYPERBARIC
DISC FILTRATION IS NOT CLEAN.
45
46
ECONOMICS
$132.6 million ‘domestic
spend
LESS offshore
HFO$30million
LESS DeBeers $25million
LESS 70% labour figure
$7million
Less offshore insurance
$3million
$67 million domestic spend
Uncertainty over R&M
$21million every year
Maybe $40 million domestic
spend
47
EXPORTS LESS IMPORTS
$312M LESS $154M = $266M
48
ULTIMATE OWNERS IMPACTS FOR
ROYALTY PAYMENTS AND PROFITS
Exploration costs and prospecting
costs deductible – losses to offset
against profits
BANKABILITY OF THE PROJECT
• Alan Eggers – is in the rare metals business - Uranium (Vanadium in US obtained as a by
product of Uranium) (Summit Resources Director & currently CEO of Manhattan Corp.
• Vanadium and Titanium
• Vanadium – energy storage and renewable energy – 65% of global supply comes from co-
production of steelmaking slag
• Target of the Chinese government is to ensure at least 50% of its future iron ore supply
comes from a Chinese mine, not necessarily a mine in China.
CITIC, China’s largest conglomerate booked $3.3b of losses on Sino Iron YE 2014 – has a
capital intensity of $US333 ton, the cost of development divided by output at full capacity.
The global average was $US153 a ton. Because it is a magnetite mine, and magnetite ore
requires more processing.
China is a deep pocket investor, which is targeting long term supply
49
50
Pg 758
submission
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