SUBMISSION FORM Trans-Tasman Resources South Taranaki ... · hans heumann. Date. 17/12/2013. Part...

From: hans heumannTo: TTR ApplicationSubject: Submission: hans heumann, TTR Marine Consent ApplicationDate: Wednesday, 18 December 2013 10:16:21 a.m.

To whom it may concern

Please find my submission on the Trans-Tasman Resources South Taranaki BightOffshore Iron Sand Project Marine Consent Application (EEZ000004) below.

Please reply to this email in case there is a problem with this submission.

Sincerely,hans heumann

SUBMISSION FORM

Trans-Tasman Resources SouthTaranaki Bight Offshore Iron SandProject Marine Consent Application

Proposal Name: Trans-Tasman Resources South Taranaki Bight Offshore IronSand Project Marine Project

EPA Reference: EEZ000004

Applicant: Trans-Tasman Resources Limited

Notification Date: 21 November 2013

Submission Close: 5:00pm, Thursday 19 December 2013

Further Information: http://www.epa.govt.nz/EEZ/trans_tasman

This is a submission on the marine consent application lodged by Trans-TasmanResources Limited with the Environmental Protection Authority (EPA). Theconsent application is made pursuant to Section 38 of the Exclusive EconomicZone and Continental Shelf (Environmental Effects) Act 2012 for the mining ofIron Sand at the South Taranaki Bight.

beedellaText Box107341

Part A

This part provides the EPA with data about you as a submitter. Sections with anasterisk are mandatory.

1. Submitter Details*

Please provide your name (or company name) and as much contact informationas possible. We may need to contact you during or outside of normal businesshours. Please advise us if any of your contact details change.

Name of organisation (if relevant):

Title:First name of submitter:* hansSurname of submitter:* heumann

Home Phone:Work Phone:Mobile:Fax:

Physical Address:Postcode:

2. Alternative contact person details (optional)

If you wish to nominate a person to be your point of contact (e.g. a friend,relative, lawyer, professional advisor or any other person), please provide theircontact details below. This person will receive all correspondence on yourbehalf.


Title:

First name of contact person: Surname of contact person:

Home Phone:Work Phone:

Mobile:Fax:


Postal Address:, Postcode:

Email:

3. Privacy Statement

Your personal information included in Part A of this form will be held by the EPA,215 Lambton Quay, Wellington. Other than your name, organisation (ifapplicable) and address for service, your personal contact information in Part A ofthis form will not be published on the EPA website. All information held by theEPA is subject to the Official Information Act 1982. It will be used by the EPA forthe administration of the Trans-Tasman Resources Limited marine consentapplication process. Copies of your full submission, including all personalinformation included in Part A, will be provided to the EPA, the applicant, andsubmitters, and may also be provided to other parties in the process. You havethe right to access and correct personal information held by the EPA.

Your name, organisation (if applicable) address for service, the information inParts B and C of this form and any attached information will be published on theEPA website, and made available to the EPA, the applicant, other submitters andthe general public for use in the processing and consideration of the Trans-Tasman Resources marine consent application.Note: If the submitter is a company then full business contact details will bepublicly available.

4. Authority to act*

If this submission is made on behalf of a group, please tick to confirm you areauthorised to represent all persons making this submission, and sign and datebelow. If you are an individual making this submission, please sign and datebelow.

I / We confirm that I / we have authority to sign this submission on behalf of allpersons named on this form.

Signature hans heumannDate 17/12/2013

Part B

This part asks for your position on the marine consent application.

5. Do you have an existing interest that may be affected?

Do you have an existing interest that may be affected by the application? (Tickas many boxes as appropriate)

If you have an existing interest (confirmed by ticking one or more of the aboveboxes), please describe your existing interest.

Description of your existing interest

If you have an existing interest (confirmed by ticking one or more of the aboveboxes) which you think may be affected, please provide a brief explanation ofhow you may be affected by the application.

Explanation of how your existing interest may be affected by theapplication

6. What is your position on the marine consent application?*

Please state your position on the Trans-Tasman Resources South Taranaki BightOffshore Iron Sand Project marine consent application either as a whole, or onany part of it. If you have specific opinions on different aspects of theapplication then you can detail these in the space provided below.

You may comment on any aspect of the application and there is no restrictionon the length of your submission. You can make a general submission and/orrespond specifically to any part of the application documentation. The morespecific your submission however, the greater the understanding of your views.This will help identify whether meetings and/or mediation are required; how ahearing might be structured; and provide information to inform the finaldecision. If you are making a detailed submission, it would be helpful if youcould state whether or not you disagree with any of the information provided inthe application. We have provided boxes for the sections in the document“Supporting Information for Marine Consent Application” compiled by Trans-Tasman Resources (TTR) Limited, dated October 2013.

If you require more space, please attach additional pages as necessary. Pleaseensure you include your name and ‘Trans-Tasman Resources’ on each additionaldocument.

Position Oppose in full

Reasons

Treaty breach:The application fails to provide active protection of Maori interests and taonga(particularly over fisheries), but also negates kaitiakitanga (or stewardship) bytangata whenua over the environment.

Consultation: The applicant’s consultation has been incomplete, insufficient and lacking integrityin the sharing of information. The information shared at meetings held by theapplicant has been selective and inadequate. This has lead to great difficulty forinterested and affected parties to form an understanding of the total proposaland effects of the application.

Precautionary Approach: The applicant has not provided a robust application proving that their proposal issafe for the marine environment and poses no threat to future viability. Taking aprecautionary approach to major projects of this nature is internationallyrecognised. I request that the EPA applies the precautionary approach to thisapplication and utilises the provisions of Sec 10 and s59(2)EEZ & CS Act 2012 toensure that the marine environment is protected in accordance with that Act.

Coastal erosion: Large scale mining of the Tasman seabed will remove non-renewable sandresources that supply west coast beaches up to Cape Reinga. It will causeincreased coastal erosion both up and downstream from where any mining takesplace. The South Taranaki area already has severe coastal erosion issues and thismining activity has potential to exacerbate the erosion.

There will be modification of the seafloor as well as natural waves and currentsthrough the removal and addition of sand. At risk is a fantastic coastline, stackedwith some of New Zealand’s most loved, and commercially valuable surf-breaks,plus a host of spectacular swimming beaches and fishing spots.

Migratory mammal species:Migratory mammal species such as Blues Whales and Southern Right Whales

have a high potential to be impacted along with Orca Whales plus the at riskMaui and Hectors dolphins. There are only approximately 900 Southern RightWhales with fewer than a dozen reproductive females remaining in New Zealand.Any adverse impacts to the migratory and resident mammal species could bedevastating and must be avoided.

Threats to seabed biology: The seafloor supports a wide variety of organisms, including mussels, worms andcrustaceans, which in turn support an extremely healthy fishery. The suctiondredging Crawler will remove the entire top surface of the seabed. Every livingthing in the sand will be killed in the process, turning the mined area plus asignificant area around the mining sites, into a dead-zone. Sediment surfacefeeding fauna has a high potential to die from mining process.

Plume impacts:There are plumes created at the time of mining and when the unwanted sand isdumped back down on the seafloor. The plumes will impact phytoplankton andzooplankton and light penetration, affecting the food web. The dischargedmaterial is chemically altered and will create adverse effects to the marine life. Intotal, the biology will be tremendously altered and recolonisation will be a veryslow process. The re-establishment of balanced seafloor biology may finally takedecades. In fact the applicant acknowledges that the plume effects are to be soadverse, that, the whole operation was moved further offshore out past the 12nautical mile limit.

Surface species impacts: Surface noise and light from operations that run day and night will negativelyaffect seabirds. Subsurface noise will affect marine mammals and fisheries.Disturbance of the seafloor may mobilise previously settled pollutants, such asheavy metals, that can bioaccumulate in fish species. The noise, light andseafloor disturbance has a high potential to place the Commercial, Recreationaland Customary fisheries at risk.

Economic worries:Profits will be directly exported overseas, while the risk of a potential ecologicalcollapse remains. Low royalty rates will not deliver economic gains and will notprovide economic benefits relative to economic losses resulting from theapplicant’s proposal.

There are minimal employment opportunities; while New Zealand’s clean greenimage and tourism will be undermined.

Only 250 jobs will be created and most of the work force will be taken up byoverseas personnel due to the skill levels required. The “Fly In Fly Out/Drive InDrive Out” majority of workforce will not reside in Taranaki but come from allparts of New Zealand.

The export value of the seabed iron ore is only in the same range as plasticproducts that are exported from New Zealand. The Food and Forestry sectorsgenerate 70% of New Zealand's merchandise export earnings and around 12% ofGross Domestic Product whereas, the seabed mining proposed will only be minorin expert earnings in comparison.

Tourism is one of New Zealand's largest export industries. Tourism directly andindirectly contributes almost 10% of New Zealand's GDP. The economic benefitsfrom this mining proposal pales into insignificance when compared against thepossible damage to the $23bn a year tourist industry; damage arising from

erosion, loss of surfing, swimmers, beach users, fishers and damage to the'clean-green' image. This will in turn have ongoing adverse cumulative effects oncoastal communities, people’s livelihoods and their quality of life.

The applicant only focuses on impacts on tourism in the immediate local area andfails to consider cumulative adverse effects to the larger region. There could alsobe damage to private property and to the fishing industry. The applicantacknowledges that impacts to commercial fisheries in the local area will takeplace and has not provided any evidence that compensation will be paid to thatsector. Additionally, there is no economic analysis of the loss to the recreationalfishing sector. The potential loss to people’s economic wellbeing and impacts tothe local and regional area will create adverse effects to those communities.

Risks from the vessels: The use of deep-sea moorings for stabilising the large extraction and exportvessels will create adverse effects and destroy a large area of seabed. There isthe possibility of oil spills that has the potential to create significant adverseeffects, particularly from the crude thick toxic heavy fuel transfer operations fromship to ship. The applicant maintains that the operation will be carried out with afocus of avoiding spillage but has failed to develop a contingency plan and failedto account for any potential effect of low probability that has a high potentialimpact. Furthermore there is minimal risk assessment on availability of resourcesfor managing risk at sea or from the land.

Worse still, the applicant has not developed any emergency plans for unplannedevents and relies on a risk matrix and a Hazard Register as a live documentinstead which is unacceptable.

Consent Conditions and Monitoring Plan:The general approach to the consent conditions is inadequate and the approachto the Environmental Monitoring and Management Plan lacks substance,particularly for an operation that has substantial risk.

Insurance:The applicant only intends to provide insurance cover of NZ$100,000,000 or alesser amount as agreed with the Chief Executive, for environmental restorationof any unplanned event which results in major unforeseen environmentalconsequences during the term of seabed mining operations. Two issues arisefrom the above. One is the definition of major unforeseen environmentalconsequence, and the other is the undefined amount of insurance as it is goingto be left up to the Chief Executive to determine the amount.

A substantial Bond should be set in place to counter the minimal vague insurancecover utilising Section 65 of the EEZ and Continental Shelf (EnvironmentalEffects) Act 2012 to bring certainty for effective risk management.

Statutory Regime: The application does not satisfy the requirements of the EEZ and ContinentalShelf (Environmental Effects) Act 2012. The assessment of environmental effectsis flawed, being based on inadequate scientific research. Additionally, theapplication fails to satisfy New Zealand’s international obligations under the Lawof the Sea. The applicant has failed to avoid, remedy or mitigate adverse effectsappropriately.

Section 1: INTRODUCTION

Please explain why you agree/disagree with the information in thissection

Section 2: PROJECT DESCRIPTION


Section 3: UNPLANNED EVENTS


Section 4: STATUTORY REGIME


Section 5: INVESTIGATIONS COMMISSIONED


Section 6: DESCRIPTION OF THE PROJECT AREA


Section 7: EXISTING INTERESTS CONSULTATION


Section 8: ECONOMIC BENEFITS


Section 9: DESCRIPTION OF EFFECTS ON IWI


Section 10: METHODOLOGY ADOPTED FOR EVALUATION OF EFFECTS


Section 11: EVALUATION OF EFFECTS ON THE PHYSICALENVIRONMENT


Section 12: EVALUATION OF MARINE ECOLOGICAL EFFECTS


Section 13: EVALUATION OF EFFECTS ON THE SOCIAL ENVIRONMENT


Section 14: OTHER EFFECTS


Section 15: MEASURES TO AVOID, REMEDY, OR MITIGATE ADVERSEEFFECTS IDENTIFIED


Section 16: CONSENT CONDITIONS FRAMEWORK


Section 17: ENVIRONMENTAL MONITORING AND MANAGEMENT PLANINITIATIVES


Section 18: OVERALL EVALUATION


APPENDICES

Please explain why you agree/disagree with the information in any ofthe appendices, please identify which appendix and provide a reason

SUPPORTING TECHNICAL REPORTS

Please explain why you agree/disagree with the information in any ofthe technical reports, please identify which report and provide a reason

7. Factors the EPA must take into account

When considering the proposed Trans-Tasman Resources South Taranaki BightOffshore Iron Sand Project marine consent application, the EPA must, amongother matters, take into account factors listed in section 59(2) of the EEZ Act.You may comment on any of these factors in the box below. If you requiremore space, please attach additional pages as necessary. Please ensure youinclude your name and ‘Trans-Tasman Resources application’ on each additionaldocument.

8. What decision would you like the EPA to make?*

Please identify the decision you would like the EPA to make about the proposedTrans-Tasman Resources South Taranaki Bight Offshore Iron Sand Projectmarine consent application, and provide reasons.If you require more space, please attach additional pages as necessary. Pleaseensure you include your name and ‘Trans-Tasman Resources application’ oneach additional document.

Decline

Provide reasons including any suggested conditionsReasons as above in section 6.

Hearings to be held in several regions, particularly in those regions where manysubmissions have been made.

That the E&R report is released well before the hearing date to allow submitters,expert witnesses sufficient time to respond to the issues raised in the report.

I/We hereby ask the EPA for permission to question each witness for theapplicant.

Part C

This part provides the EPA with information to assist with administration of thehearing.

9. How would you like to receive correspondence*?

Formal service of documents will be by way of the EPA website atwww.epa.govt.nz.For efficiency, as well as environmental and cost reasons, the EPA sends EPAcorrespondence via email. We usually provide links to documents on ourwebsite rather than emailing documents. This saves people the trouble ofdownloading large files that they may not want. We will send all informationand correspondence including copies of the final reports to the email addressprovided in Part A of the Submission Form, unless you state an alternativepreference below.If you choose to receive paper copies and wish to speak at the hearing, we willneed to provide you with a lot of information such as evidence, hearingschedules, board directions and reports. It may not always be feasible for papercopies to be posted to you in a timely manner (for example, the hearingschedule may change daily during the hearing).In some instances, such as when there is a large volume of information, wemay refer you to a location where this documentation is publicly available forinspection, such as a library.

I / we do not wish to receive any documentationOther than electronic copies of the final decision

10. Do you wish to speak to your submission*?

A hearing for the application may be held by the TTR decision-makingcommittee.As a submitter you may speak about your submission (and any evidence youmay provide) at that hearing. To assist us with planning, please advise us belowif you intend to speak at that hearing.If you do wish to speak at the hearing, we will contact you prior to the hearingto confirm whether you still wish to speak, and if so, how long you will need foryour presentation to the EPA. Many submitters speak on similar topics andissues. If this applies to one or more of your topics of interest then you mayconsider presenting a joint case at the hearing. If you would consider doing this,please indicate this by ticking the box.If you do not wish to speak at the hearing, the next information you will receivefrom the EPA will be the final decision. All submissions will be considered by theEPA, regardless of whether you speak at a hearing.If you do not select an option, we will assume you wish to speak about yoursubmission.

Yes, I / We wish to speak about my / our submission

11. Meetings and/or mediation to resolve matters beforedecision

The EPA may request that the applicant meets, or enters mediation, withsubmitters to discuss matters in dispute in relation to the application. In order toassist with scheduling, please confirm your expected availability to participate inmeetings or mediation. Timing for meetings mediation will be determined by theEPA TTR decision-making committee and that direction will be conveyed to theapplicant and submitters at that time.

If you expect that you won’t be available, please provide a brief reasonwhy

12. Do you intend to provide expert witnesses?

This section only relates to people who want to speak at the hearing.An expert witness is a person who, through training or experience, is a skilledpractitioner in a particular subject and is able to give professional independentevidence on that particular subject.If you consider yourself to be an expert, or you intend to provide evidence fromexpert witnesses, please tick the box below.

If you know the areas of expertise of your expert witnesses and/or their namesthen please provide these. This information is for provisional planning purposesonly. Final confirmation of expert witnesses will not occur until the evidence ofthe submitters is lodged with the EPA.

Where to send your submission

Your submission must be received by the EPA no later than 5.00pm onThursday 19 December 2013. You also need to send a copy of yoursubmission to the applicant (Bell Gully Limited will receive all submissions on

behalf of Trans-Tasman Resources Limited). A copy of your submission willautomatically be sent to the applicant when using the online form tool.You can send your submission to the EPA either by:

Using the online form available at:http://www.epa.govt.nz/EEZ/trans_tasmanEmail [email protected] (if smaller than 10MB). Please mark inthe subject line: ‘Submission: (Your name), TTR Marine Consent Application’Post to Trans-Tasman Resources application, Environmental ProtectionAuthority, Private Bag 63002, Waterloo Quay, Wellington, 6140.Deliver in person to Environmental Protection Authority, Level 10, 215Lambton Quay, WellingtonFax (04) 914 0433 Please mark in the subject line: ‘[Your name], Trans-Tasman Resources Submission’

You must also send a copy to Trans-Tasman Resources Limited. You can sendthis by:

Using the online form you can select to automatically send the applicanta copy of your submission from the online submission form.Email [email protected] to Trans-Tasman Resources Ltd, C/- Bell Gully, PO Box 1291,Wellington 6140, Attention: Andrew BeatsonDeliver in person to Bell Gully, Level 21, 171 Featherston Street,Wellington

From: Sylvia HewittTo: TTR ApplicationSubject: Submission: Sylvia Hewitt, TTR Marine Consent ApplicationDate: Sunday, 1 December 2013 7:52:06 p.m.




Sincerely,Sylvia Hewitt

SUBMISSION FORM









dickensonkText Box103855

Part A





Title:First name of submitter:* SylviaSurname of submitter:* Hewitt






Title:



Mobile:Fax:



Email:







Signature Sylvia HewittDate 30/11/2013

Part B













Reasons























APPENDICES








Decline





Part C

No, I / We do not wish to speak about my / our submission.









From: Peter HewsonTo: TTR ApplicationSubject: Submission: Peter Hewson, TTR Marine Consent ApplicationDate: Tuesday, 28 January 2014 11:29:49 a.m.




Sincerely,Peter Hewson

SUBMISSION FORM









powerhText Box108950

Part A





Title:First name of submitter:* PeterSurname of submitter:* Hewson






Title:



Mobile:Fax:



Email:







Signature Peter HewsonDate 27/01/2014

Part B













Reasons























APPENDICES








Decline





Part C

No, I / We do not wish to speak about my / our submission.









From: jamie heywoodTo: TTR ApplicationSubject: Submission: jamie heywood, TTR Marine Consent ApplicationDate: Wednesday, 18 December 2013 2:37:06 p.m.




Sincerely,jamie heywood

SUBMISSION FORM









georgesText Box107733

Title:



Mobile:Fax:



Email:







Signature jamie heywoodDate 18/12/2013

Part B













Reasons























APPENDICES








Dec

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