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