The Trans Tasman Resources Limited application to mine sand in the South Taranaki Bight does not meet the requirements needed to safeguard the environment. See the reasons on this slideshow.
• Have TTRL used the best available information?
• Is the baseline data adequate for designing a fit-for-purpose adaptive management plan?
• Will the adaptive management and monitoring proposed adequately protect the environment?
NO
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The problem with sandmining in the South Taranaki Bight
1.
2. Ministry for the Environment report (2016): adaptive
management in relation to seabed mining:
‘it is clear that adaptive management cannot
compensate for a lack of baseline environmental
data or inadequate modelling. In the words of the
King Salmon Board of Inquiry, some information
gaps cannot “be simply filled by invoking adaptive
management”.’
3. • Have TTRL used the best available information?
• Is the baseline data adequate for designing a fit-for-
purpose adaptive management plan?
• Will the adaptive management and monitoring proposed
adequately protect the environment?
• Primary productivity
• Reefs
• Marine mammals
• Sea birds
Questions
4. Primary Production
• Large reduction in light: 10-40% over 704 km2 mining @ Site A
• Only provided averages of PP over Sediment Model Domain
• No modelling to assess PP downstream of mined area
• No measurements of primary productivity i.e. growth or
photosynthetic rate at all
• Monitor biomass using chlorophyll a: Photoadaptation?
• Not adequate to assess
knock-on effects within
foodweb
• Raises serious concerns
about impacts within the
wider ecosystem
5. Reefs
• Limited benthic sampling within the area of the plume
• Large sections within area of plume: not been surveyed
8. Reefs
• DOC GIS package indicates many reefs within influence of
plume:
9. Reefs
• South Taranaki Underwater Club, Karen Pratt & local fishermen
have reported many reefs within influence of plume
• High biodiversity values: CoastBlitz Patea (on NatureWatch NZ)
15. Reefs
• Inadequate baseline information on rocky reefs in application
• Large areas of plume not yet surveyed e.g. Graham Bank
• Missed the Crack (4 nautical mile long, close to mining area)
• Adequate baseline data is required at the application stage for
designing a fit-for-purpose adaptive management plan
16. Marine Mammals
• Multiple witnesses demonstrate: TTRL not used best available
info in application e.g. Torres, Slooten, val Helden
• Orca data in TTRL application inadequate: 6 sightings 25 years
• Project Hotspot: 84 orca sightings 1 year, 29 different days
17. Marine Mammals
• TTRL Habitat Model: Taranaki poor
to moderate habitat for orca
• Project Hotspot sightings and
observations: Taranaki good
habitat for orca
• Often observed actively feeding on
rays (50% of sightings ‘feeding’)
19. Marine Mammals
• Inadequate baseline information on marine mammals in
application
• Adequate baseline data is required at the application stage
for designing a fit-for-purpose adaptive management plan
20. Seabirds
• TTRL not used best available info in application (see NMMRS
submission & Cockrem evidence)
• TTRL used eBird: No sightings of little blue penguins in Taranaki
• Compare with NatureWatch NZ: 236 Taranaki little blue
penguin sightings
21. • Evidence: Waters off South Taranaki are important feeding
ground for little blue penguins:
• Observations from fishermen
• Tracking penguins from Motuara Island, Marlborough
Sounds (Poupart et al., accepted by NZ J. Ecology)
22. • GPS trackers
• Motuara Island
• Spring 2015
• Incubating eggs
• 11 of 14 penguins
tracked: swam to
South Taranaki
• Must be a reason
for this
Poupart T, Waugh S, Bost C, Bost C-A, Dennis T, Lane R, Rodgers K, Sugishita J, Taylor GA, Wilson
J, Zhang J, Arnould JPY. Variability in the foraging range of Eudyptula minor across breeding sites
in central New Zealand. New Zealand Journal of Zoology
23. Seabirds
• Two genotypes of little blue penguins (see submission)
• Only handful of large populations (>200) of NZ genotype
• Sediment plume: increased water turbidity and disruption to
food web: affect penguin foraging efficiency
• Sand mining: put further stress on struggling penguin colony at
Motuara Island, low breeding success
• Potential impacts at taxon level
24. Seabirds
• Inadequate baseline information on seabirds in application
• Available data indicates: shelf waters of South Taranaki
important feeding ground for ‘at risk’ little blue penguin
• Potential for impacts at the taxon level (NZ genotype)
• New Zealand Coastal Policy Statement: avoid adverse effects
• Decision Making Committee must favour caution and
environmental protection and decline this application
25. • Have TTRL used the best available information? NO
• Is the baseline data adequate for designing a fit for
purpose adaptive management plan? NO
• Will the adaptive management and monitoring proposed
adequately protect? NO
Questions
26. “It is not clear how long-term ecological impacts from
the mining will be separated and identified from
natural variability in order to trigger a management
response prior to tipping points being reached and
unacceptable impacts occurring”
NMMRS Submission
27. • Can TTRL correctly interpret the data and respond in
order to prevent long-term unacceptable impact from
occurring?
Additional question
28. “I have seen areas completely covered by more than 1 m of
sand and then within a year of the sand retreating, the reef was
healthy again with high species diversity and high abundances
of both intertidal seaweeds and animals. I took a photograph of
a section of reef at the end of Greenwood Road, Taranaki which
is a control site for the TRC in September 2003 and when I
returned to the reef in January 2014 the sand had receded and
the marine life was recovering which was supported by the
monitoring results. Ongoing ecological monitoring by the TRC
also concurs with this observation of sand inundation and
recession along the Taranaki intertidal coastline.”
Govier Evidence (para 182)
30. • Trend analysis shows a significant decrease in diversity at
Greenwood Rd Reef over 21 years, p20
• The sand adjusted trend indicates that this decrease in diversity
was related to an increase in sand accumulation
TRC Rocky Shore Report
31. TRC Rocky Shore Report
• TRC report concludes:
• Greenwood Rd is prone to periodic sand inundation
• Trend analysis indicates that there has been a significant
decrease in species richness and diversity at this site which
appears to have been caused by an increased sand supply
from the mountain, combined with oceanographic
conditions that shift this sand onshore
• In his evidence, Govier fails to recognise that ongoing periodic
sand inundation has resulted in a significant long-term decrease
in species diversity at Greenwood Rd Reef
• This example relates to naturally occurring events inshore
• Is the TTRL monitoring plan and adaptive management sufficient
to avoid similar misinterpretation re the offshore reefs?
32. • Have TTRL used the best available information? NO
• Is the baseline data adequate for designing a fit for
purpose adaptive management plan? NO
• Will the adaptive management and monitoring proposed
adequately protect? NO
• Can TTRL correctly interpret the data and respond in
order to prevent long-term unacceptable impact from
occurring? Concern
Questions
33. • Adaptive management will not adequately
protect given the inadequate baseline data
• Tipping points may be reached before a
management response is triggered
• The application is not in line with the
Information Principles of the EEZ Act and
policies of the New Zealand Coastal Policy
Statement
• The Decision Making Committee must
favour caution and environmental
protection and DECLINE this application
Conclusion