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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 TTR will be the largest dredger- consumer of heavy fuel oil, by


  1. 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 TTR will be the largest dredger- consumer of heavy fuel oil, by quantity ‘conservative for and time scale – as TTR, as based on it GRINDs ORE 50 million tonnes = which is hugely 27million cubic energy intensive, meters – so especially for includes downtime! magnetite No downtime = 70million tonnes Based on 35 p.a. years extraction & conservative assumption about France 1

  2. 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 Cost to convert away from HFO? My guess $45million Question put at Hearing to Shawn Thompson & not answered 2

  3. s59(5) Despite subsection (3), the EPA must not have regard to — (a) IMO CONVENTION trade competition or the effects of trade competition; or (b) Annex VI NZ hasn’t signed up to the effects on climate change of discharging greenhouse gases into the air 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) 16 super ships emit as much sulphur as the Aviation and shipping are excluded in Government’s world’s fleet of initiatives to reduce greenhouse gas emissions through cars the ETS 3 Maritime NZ ‘installations’ max $25million

  4. HIGH GRADE ORE SITES, MILLION OF TONNES EXTRACTED OVER THE LIFE OF THE PROJECT 35-42m 21-43m depth 241.57 depth 218.96 Diagram pg 9 IA 2014 25-36m Dianne Christina depth 19-25m depth 68 X2 27 10 years to D2 extract all 4 sites Christina Dianne D2 (3-5m) X2 Million tonnes 218.96 241.57 27 68 4

  5. SECTION 59(2)(D) & (2)(E • “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. Page 587 Hearing 22/2/2017 5

  6. S(4)(1) environment means the natural environment, including ecosystems and their constituent parts and all natural resources, of — Mr Holm, page 13 Transcript “ Work has been done on existing environment and potential effects” “baseline is not being used as a proxy for establishing the existing environment” 6

  7. 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) NO sub-tidal reef AN IMPACT ASSESSMENT MUST CONTAIN THE INFORMATION REQUIRED BY SUBSECTION (1) IN — (A) habitat mapping, SUCH DETAIL AS CORRESPONDS TO THE SCALE AND SIGNIFICANCE OF THE EFFECTS no food-web work (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 Bryozoan likely that macro-algal beds nursery ground for fish Provide same role as a coral occur at levels consistent with the EEZ (2012) sensitive reef, provide for biodiversity: 7 Abby Smith habitat criteria

  8. Unknown 8

  9. PLUME – dynamic movement by wave and Ignore as deemed insignificant: wind – using ‘average rate 1. Propellor Static tonnages used. turbulence/resuspension of discharge’ Doesn’t take into account ‘worse 2. Suction head 3. Erosion of km’s of mounds case’ increases occurring for x% of days. Ecological load under estimated by modelling NIWA PLUME MODELLING NIWA Beaker test No Project-site Lab tests 3D model HR Wallingford 1DV testing model I have prepared in-depth, Lack of experts/non- fully referenced, experts conducting a explanations of errors and detailed review of non- information gaps with redacted information re HRW – majority not plume modelling addressed 9

  10. Leather jackets : especially in ECO-SYSTEM association with rocky reef, feed on sponges and ascidians, juveniles recruit into Ecklonia Radiata plants Blue Cod : in association with light MPI Report foul ( reef edges , shingle/gravel and 125 biogenic structures, or sand close to Habitats rocky outcrops. Small cod significant association with bryozonas (Vooren for finfish Key 1975) and polychaetes & salps Food biological during spring habitats ‘ web CONNECTIVITY linkages Sustainable- = KEY Seas’ Juvenile snapper, terakihi , blue cod, ATLANTIS MODEL – Golden leatherjacket often associate with 3D floor structure & biogenic habits: Bay, Tasman Bay What factors bryozoans , sponges , kelp forests, influence horse mussels, seagrass abundance of scallops & No such MPI report expands on the findings of Hurst et al. (2000a), using information that has been published in the last 12 snapper years, including recent work both in New Zealand and overseas. We also include some new thinking and conceptual modelling done frameworks that have evolved since that time, for example around nursery habitats and migration dynamics by TTR 10

  11. SPONGES ARE AN IMPORTANT HABITAT & A ‘SPONGE GARDEN’ MEETS ‘SENSITIVE HABITAT CRITEREA RISKs: NO sponge expert evidence, NO survey work for sponges, Seives of NO DOC survey work for planktonic South Taranaki (other than the algae and N& S Traps) bacteria, filter 1,000 times their own weight, they consume much of the production of local algae Diametre of 1m = 80 years old 11

  12. Through their benthic-pelagic coupling, some of the densest sponge aggregations have a significant local or NZ Study: Any loss of regional impact on major biogeochemical cycles and food canopy, e.g. Ecklonia “phenomenal fluxes of webs radiate might have matter and energy from negative effects on sponges” sponge assemblages “significant local or and affect over regional impact on food biodiversity webs”: 1. A.J.M. Zainal, D.H. Dalby, I.S. Robinson 2. 2. Mon onitor toring m g marin arine e e ecologi gical c chan anges es on on th the e e eas ast c t coa oast o t of f Bah ahrain wi with th La Lands dsat at TM 3. Photogrammetric Engineering and Remote Sensing, 59 (3) (1993), pp. 415 – 421 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. 12

  13. nearshore spawning sites - social TTR transmission of knowledge (Warner 1988, 1990. locals DOC 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 survey 13

  14. Trevally fishing 14

  15. 5 53 7 50 42 46 20 15

  16. 8 2 60 2.6 12 3.7 RISK: Desk- top study based on ‘outside region dives’ & desk -top study – not reflective of South Taranaki 16

  17. 20 0.2 Common Roughy ‘rare’ according to NIWA! 17

  18. TRC cautionary note RISK: No diver transect survey work – understate algal cover 1 occurance Eklonia in the inner Radiata shelf 18

  19. TARANAKI REGIONAL COUNCIL SUBMISSION 19

  20. 20% reduction in TARANAKI REGIONAL COUNCIL water column PP over 704km2 20

  21. 2016: 2014: 31% 50% reduction reduction 21

  22. 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

  23. Lack of DEPTH IN METERS RISK: RISK: environmental 45% (av.) of 50% investment in depth tested for GEOGRAPHIC RISK: DEPTH PROFILES 2016 Christina & AREA NOT UNKNOWN – 11m? Test samples Dianne TESTED Pg 17 obtained in 8.4 Environmental 2013 with ‘old 7.8 risk technology’ 7.5 assessment equipment – for MfE (done no further work by NIWA) fails Metal done Metal to give Vopel’s testing testing cautionary 3 2 4 note – about samples: samples: limited depth 50% 22% and No 62% Metal 55% Metal geographic Cumulative 25% testing testing of depth sampling impact of depth NIL NIL tested tested assessment from copper release from Christina Dianne D2 (3-5m) X2 hull: 23

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