BEFORE THE EPA CHATHAM ROCK PHOSPHATE MARINE CONSENT APPLICATION IN THE MATTER of the Exclusive Economic Zone and Continental Shelf (Environmental Effects) Act 2012 AND IN THE MATTER of a decision-making committee appointed to consider a marine consent application made by Chatham Rock Phosphate Limited to undertake rock phosphate extraction on the Chatham Rise __________________________________________________________ SUMMARY STATEMENT OF EVIDENCE OF LINDA SANDERS FOR CHATHAM ROCK PHOSPHATE LIMITED Dated: 29 September 2014 __________________________________________________________ __________________________________________________________ Barristers & Solicitors J G A Winchester / H P Harwood Telephone: +64-4-499 4599 Facsimile: +64-4-472 6986 Email: james.winchester@simpsongrierson.com DX SX11174 P O Box 2402 Wellington
1. Chatham Rock Phosphate considers genuine consultation and ongoing engagement is central to developing and managing our project. As a Director of the company I share this approach and actively promote it. 2. I have spent most of the past four decades working in media, communications and governance roles and have extensive experience with managing successful consultation and have used this for the programme CRP has undertaken. 3. I have mostly been the key liaison point for most consultations, but for Iwi and Imi CRP engaged Tuia Group Limited to be the main liaison point to ensure consultation follows the appropriate protocols. There are two key planks underpinning CRP’s development of this project: 4. making science-based decisions, and building stakeholders' input into our project design. 5. I would observe it is unusual for a mining project to have environmental benefits – such as low cadmium, low carbon footprint and low waterways runoff - and I observed through our consultation that this has made our project of considerable interest to a wide range of groups. 6. Consultation has helped CRP understand how its project will affect and benefit other persons and to build those considerations into the project wherever appropriate and possible. 7. Through consultation CRP has sought to explain what its scientific research says about the project's potential effects, demonstrate the benefits to New Zealand, and also to explain how CRP plans to minimise, mitigate and offset the environmental effects. 8. The objective of this consultation has not been to seek support. Instead, the objective has been to inform and educate those interested so they can reach their own conclusions about the project's merits, and to receive feedback about the project, including any concerns 9. All information and inputs, including those gathered as a result of consultation, have helped refine the proposals. Consultation has lead us Page 2 24806508
to undertake further targeted scientific research which has informed CRP's mining approach. For example, when Chatham Islanders raised questions about the migratory paths of eels and lobster we commissioned research, provided the answers to the questioners, and posted that information on our website. The same applied to the stock assessment modelling NIWA undertook with the DWG and the review of our modelling work we funded for DWG. A more recent example is CRP’s decision to reduce the size of the 10. application by about half. Key factors were to seek to ameliorate two major concerns of Ngai Tahu – possible impacts on fossilised whalebones (a matter which emerged during post-lodgment consultation with Ngai Tahu) and the ling fishery. 11. CRP has a team who collectively and individually undertake consultation. Normally the Chief Executive and/or I undertake the initial meeting, especially with an organisation. Once we have identified areas of particular interest, if appropriate we ask one of our technical specialists or scientists to provide more detailed or specific information and discuss technical issues. 12. Consultation began in 2010, immediately after receiving a prospecting licence (MPL 50270) with discussions with a range of potentially interested parties such as the Deep Water Group, some Iwi interests (including Te Ohu Kai Moana) and several government organisations and departments. 13. More intensive consultation got underway from 2012, once CRP had developed a mining plan and our research identified those most likely to be interested in CRP’s plans. 14. Consultation will continue during and following the processing of this application for a marine consent. This as an on-going commitment. It is the way CRP does business. 15. However, we also recognise there may be areas of disagreement with consulted parties, and these will need to try to be resolved through this process and continued discussion. Page 3 24806508
16. CRP has met with stakeholder groups in person where possible, as well as providing regular updates by email and telephone. CRP also aims to keep stakeholders and the general public informed by giving presentations at national and international conferences, holding community meetings, distributing newsletters in the Chatham Islands and regularly updating our website with factsheets, media releases, relevant articles and our presentations. 17. CRP has made a considerable effort to identify and consult with all interested parties, and has received positive feedback about its consultation process. 18. CRP has found almost all discussions to be useful and constructive. CRP listens to concerns and works to address the issues or ideas raised, and where possible adopts ideas for improving the project. 19. In my view, CRP has put considerable effort into identifying and consulting with interested persons and worked diligently and effectively to ensure any individual or organisation with an interest in the project has been treated with respect and their concerns have been listened to, considered, researched and responded to. One of the comments I have received from persons we have consulted with is how open CRP is with information. 20. CRP remains committed to ongoing consultation with all parties throughout the life of the project. This includes establishing a Chatham Island Trust, an Environmental Trust and the Environmental Reference Group. CRP aims to maintain strong relationships with the Chatham Islands community. I do not intend to comment in detail on Ms Appleyard’s references to my 21. evidence in detail. However, I would like to provide some additional context by saying CRP’s relationship with DWG was originally very cordial and supportive – to the extent that DWG executives suggested moving the BPA to accommodate our project. This was discussed in several meetings at that time. Page 4 24806508
22. However, DWG's position abruptly changed without warning when Chris Castle presented to the DWG board in late 2012. That abrupt change in position led CRP to being uncertain of DWGs motives and that is why CRP became reticent about sharing information. CRP resisted sharing the July 2013 EIA with DWG because the EIA was going to significantly change and were concerned the incomplete information could be misinterpreted by the DWG. 23. CRP ultimately decided to share the information with DWG because we were finding it difficult to genuinely engage with Te R nanga o g i Tahu ( Ngai Tahu ) without providing them more detailed information and decided the July EIA was the most logical starting point. It was at that stage we decided we should share it with all interested parties including the NGOs with whom we had been consulting, on the understanding it was incomplete information pending the finalisation of the 2014 EIA. CRP initially met specifically with representatives of g i Tahu in ay 24. 2013 although, because g i Tahu 's fishing interests are a part of the DWG, its interests have been represented through CRP's consultation with the DWG. 25. While some concerns were raised relating to potential cultural impacts, specifically on taonga species such as marine mammals, the focal point of discussions with g i Tahu was the potential environmental impact on its fishing activities. In particular, these concerns related to potential impacts on long-lining on the crest of the Chatham Rise and bottom trawling on the flanks of the Chatham Rise. In late 2013, g i Tahu provided CRP with a written summary of its areas 26. of interest and concerns. CRP responded to these questions in preparation for a meeting early in 2014. The 10 areas raised included what minerals were of interest besides phosphate, detail around any proposed Mining Exclusion Areas and information relating to the seabed environment and the impacts on fauna within the BPA, including proposals to avoid, remedy or mitigate the impacts of the activity in that environment. In February 2014, CRP provided g i Tahu with a full copy of the July 27. 2013 marine consent application and a EIA. Page 5 24806508
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