it GRINDs ORE 50 million tonnes = which is hugely 27million cubic - - PowerPoint PPT Presentation

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

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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

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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 cars

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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 depth

Christina

Diagram pg 9 IA 2014

10 years to extract all 4 sites

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• “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

• ccur 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 Smith

7

Unknown

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HR Wallingford NIWA PLUME MODELLING PLUME – dynamic movement by wave and wind – using ‘average rate

• f discharge’

Ignore as deemed insignificant:

• 1. Propellor

turbulence/resuspension

• 2. Suction head
• 3. Erosion of km’s of mounds

Lab tests 3D model Static tonnages used. Doesn’t take into account ‘worse case’ increases occurring for x%

• f days.

Ecological load under estimated by modelling No Project-site testing NIWA 1DV model Beaker test

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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

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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

• wn

weight, they consume much of the production

• f local

algae Diametre of 1m = 80 years old

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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

• 1. A.J.M. Zainal, D.H. Dalby, I.S. Robinson

2.

• 2. Mon
• nitor

toring m g marin arine e e ecologi gical c chan anges es on

• n th

the e e eas ast c t coa

• ast 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.

“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

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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 survey

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nearshore

14

Trevally fishing

5 7 53 50 42 46 20

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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

• ccurance

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 COUNCIL

20% reduction in water column PP

• ver 704km2

2014: 50% reduction 2016: 31% reduction

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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.

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Christina Dianne D2 (3-5m) X2 7.8 8.4 4 7.5

DEPTH IN METERS

Metal testing

3

samples: 50% 62% 25%

• f depth

tested Metal testing

2

samples: 22% 55%

• f 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

• btained in

2013 with ‘old technology’ equipment – no further work done RISK: DEPTH PROFILES UNKNOWN – 11m? No Cumulative impact assessment from copper release from hull:

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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% sampled 25% sampled 22% sampled 55% sampled 0% sampled for D2 and X2

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“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

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“difficult to obtain samples ”

IMPACT OF IRON-ORE GRADE

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Watch condition 24 in terms

• f 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

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48 Tonne < 8microns 2014 Condition 5(b((ii) OUTPUT CONDITION “When averaged over the reported period the

• ccurrence 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 .

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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

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DOC s44 response

Pg 159 of my submission

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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 this

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Disagree that these are the worst case parameters

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“ 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

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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.pdf

37

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

• ffsets.

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% reduction

0.04mol 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 SPECIFY

41

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

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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

• re’ & the de-salination plant

ERROR: DISCHARGE FROM HYPERBARIC DISC FILTRATION IS NOT CLEAN.

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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

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Pg 758 submission