Download Cran, J - 110044 - Environmental Protection Authority

110044
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Email [email protected] (if smaller than 10MB). Please mark in the subject line:
‘Submission: (Your name), Chatham Rock Phosphate’
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Post to Chatham Rock Phosphate Ltd, Environmental Protection Authority, Private Bag 63002,
Waterloo Quay, Wellington, 6140.
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Deliver in person to Environmental Protection Authority, Level 10, 215 Lambton Quay,
Wellington.
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Fax (04) 914 0433 Please mark in the subject line: ‘[Your name], Chatham Rock
Phosphate Submission’
You must also send a copy to Chatham Rock Phosphate Limited at the same time that you send a
submission to the EPA. You can send this by:
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Using the online form. If you use the online form the applicant will automatically be sent a copy
of your submission.
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Email: [email protected]
Post to: Attention: James Winchester, Chatham Rock Phosphate Limited, C/-Simpson Grierson,
PO Box 2402, Wellington 6140, New Zealand
Deliver in person to: Attention: James Winchester, Chatham Rock Phosphate Limited,
C/- Simpson Grierson, Level 24,195 Lambton Quay,Wellington 6011, New Zealand
The application does not meet NZ’s obligations under international law, for example the United
Nations Convention on the law of the Sea 1982 and the Convention on Biological Diversity
1992. It will not enable NZ to protect and preserve the marine environment, and is not in
accordance with NZ’s duty to protect and preserve the marine environment. A precautionary
approach should be taken on this application.
The Chatham Rise
The Chatham Rise covers are a rich pristine area of ocean floor to the east of the South Island
stretching for some 1,000 kilometres. It is a highly productive marine environment home to a
rich biodiversity of life, some of which is unique to the area. It is recognised as NZ’s most
productive and important fishing ground, providing 60% of NZ’s fish catch. NIWA acknowledge
that there is inadequate knowledge of the extent of the biodiversity there and recommend
additional analysis.
The phoshorite nodules that CRP wants to extract in the mining process provide the hard
substrate habitat that is necessary for this unique life to survive. The result of mining will be
large dead zones in this area of the ocean, and potentially further into our ocean.
Removing the phosphorite nodules will result in significant irreversible negative effects to the
entire marine ecosystem on the Rise. CRP has failed to provide information on the long term
impact of this significant disturbance to the organisms living on the sea floor on the overall
health and productivity to the ecosystem. This lack of information should result in a refusal of
consent.
The Mining Operation
The mining equipment is destructive and has never been used by any other mining company in
the world. The seabed will be blasted with high pressure jets of water before being sucked up
the vessel where 85% of the seabed material will be discharged back the seafloor. The
sediment will spread for many kilometres and rise to the surface and the plume will create
impacts on zooplankton and other marine life by reducing light availability.
The Benthic Protected Area (BPA) – Marine Conservation Area
The BPA’s are areas of the ocean established in order to protect the benthic (life on the sea
floor) biodiversity and a conservation area in the sea. More than 80% of the area that CRP
wants to mine is in a marine conservation area. That will destroy some of the rare corals found
in this part of the Chatham Rise which are protected species as per the Wildlife Act. The BPA
areas are significant enough to be set aside for conservation and CRP should not be allowed to
mine those areas.
Dredge mining in this area would kill the entire benthic life in the mining area and permanently
destroy some marine communities that are only found in this area. This is an unacceptable
impact for NZ’s marine environment.
Critically, in the extensive area planned to be mined, removal of the phosphorite means that the
recovery of the benthic life in the area will not be possible. So these parts of the ocean may
never recover.
Impacts on Marine Life
All life in the ocean is interconnected – so destroying life on the seafloor impacts the entire food
chain. 85% of the material extracted by mining will be dumped back into the seafloor, it will be
dead material, biochemically altered, and it will create a damaging sediment plume (tail of fine
material) that may float in the ocean and impact much further than the direct mine site. Marine
life the way of the sediment plume will suffocate or starve to death.
This discharged material will likely indirectly kill the marine life in the higher food chain –
phytoplankton, zooplankton, and fish. This destruction will mean less food for the higher marine
mammals such as endangered whales, dolphins, sharks and unique seabirds some of which
are only found on the Chatham Islands. For example the impact on the 119 Orca could be
devastating due to their slow growing and late maturity rates.
The total impact on the collective food web is unknown and high risk and should not be allowed
Threats to Fisheries
There will be a significant detrimental impact on commercial fisheries, threatening one of NZ’s
most important economic inputs, and directly impacting on the Chatham Islanders primary
economy.
Impacts on the commercial fishing industry have not been adequately addressed or mitigated;
their existing use rights will be impacted by the large scale open cast strip seabed mining over
large areas for several decades with high probability to sever the bottom of the food chain,
creating adverse effects throughout the food web.
Tangata Whenua
CRP has not properly considered the principles of the Treaty of Waitangi, nor sought a peer
review of the application regarding how it is intending to avoid, remedy, or mitigate Maori
cultural matters. Thus the application fails to actively protect Maori interests in the use of their
lands and waters.
Economic Concerns
CRP has failed to take into account in their economic argument the costs for environmental
damage or the ecosystem in situ that should be balanced against the mining take. CRP, have
listed only the short term monetary benefits without accurately identifying the adverse costs to
the environment.
The largest part of the profits from the mining would go offshore – the short term monetary gain
for NZ is not worth the immediate and long term destruction. The company would make its
millions and leave NZ Chatham Rise with a trashed marine environment.
The negative impact on the Chatham Islands economy is potentially severe – it could destroy
their economy.
There is no insurance in the event of a disaster like an oil spill – so we could end up with
another Rena situation, with inadequate monetary protection should an unplanned event occur
in these wild pristine waters.
Consent Conditions and Monitoring Plan
CRP’s approach to consent conditions is inadequate in that they plan to monitor the impacts as
they go and adapt as environmental problems occur rather than plan to avoid, remedy or
mitigate before they start mining.
This is the wrong way round, and is inadequate because the baseline environmental information
provided lacks enough robust scientific information against which to monitor. So this adaptive
management approach will not work.
CRP intends to mine for 35 years. The mitigation planned for is only 5 years and is clearly
insufficient. There is an absence of good baseline data, so monitoring, adapting to and fixing
the damage isn’t practically achievable and CRP has failed to avoid, remedy and mitigate the
adverse effects adequately
This project is fundamentally experimental – mining the ocean at these depths is new in the
world, so the impacts are more than uncertain. By CRP’s own admission, this is an ambitious
project.
Scientific Uncertainty
Most of the scientific reports were based on, assumptions, flawed methodology and numerical
modelling with minimal site specific data..
The scientific reports provided by CRP highlights uncertainties and most state more modelling
and research for baseline information still needs to be done
There is an acknowledged absence of robust scientific information about the extent of the
biodiversity in the Chatham Rise along with a lack of robust information on the adverse effects
from the CRP mining operation.
Uranium and Other Concerns
The phosphate CRP is planning to extract contains uranium, cadimium, arsenic and heavy
metals which will be released into the marine ecosystem, with detrimental impact.
CRP has applied for the consent to last for 35 years that will impact on future generations.
NZ should be looking at smarter, greener alternatives to phosphate fertiliser for use in our
farming industry – phosphate is not good for the land and waterways.
In keeping with international law and conventions, we are supposed to be protecting our ocean
What is your
existing interest
and how may it be
affected by this
application?