Resin and Wax Holdings Ltd

RESIN AND WAX HOLDINGS LTD

Resin and Wax Holdings Ltd Peat Extraction and Processing Project Resource Consent Application September 2019

TABLE OF CONTENTS

Chapter Page

INTRODUCTION 3

RESOURCE CONSENTS REQUESTED 4

SITE DESCRIPTION 4

DESCRIPTION OF PROPOSAL 16

CONSULTATION 33

DISTRICT & REGIONAL PLAN ASSESSMENT 35

ASSESSMENT OF ENVIRONMENTAL EFFECTS 42

SUMMARY 48

DESCRIPTION OF ACTIVITY

1 INTRODUCTION 1.1 Purpose of this Document This document comprises an application by Resin and Wax Holdings Limited (RWHL) to Far North District Council (FNDC) and Northland Regional Council (NRC) for grant of resource consents to extract and process Kauri peat in Far North for recovery of natural waxes and resin. 1.2 Background Resin and Wax Holdings Ltd (RWHL) is a New Zealand company planning to establish extraction and processing operation at Kaimaumau for recovering resin and wax product from kauri peat. The peat harvesting will be from several farmland sites in Far North. The processing plant will be located on land owned by the local Iwi Te Runanga o Ngai Takoto (Ngai Takoto)at Kaimaumau. RWHL have agreements with the farm owners and Ngai Takoto (at their Sweetwater property) for access to the resource. Ngai Takoto has agreed to provide land for the process plant at Kaimaumau property as part of their strategy to reclaim and derive income from their unproductive Kaimaumau land. The resin and wax project is seen integral to the Iwi’s plan to develop their land and has their full support. The project has significant economic benefits for the region. It will generate $60 million in export earnings when fully implemented and will provide full-time employment to 50 people of which 80%+ will be local hire. In addition, the iwi has plans for a housing development to accommodate construction and operating labour and future workers for their Kaimaumau development plans. A summary of the RWHL proposal is attached in Appendix A. The RWHL operation involves excavating the peat areas, solvent extracting the crude waxes and resins and refining them into finished products for shipment to export markets. The operation has three key elements.

i. the extraction of wet peat from the farmlands ii. the processing of peat to recover the natural waxes and resin iii. the return and restoration of spent peat to the same area from where it was extracted. Parts of the NT Kaimaumau property has been used in the past for a similar resin and wax extraction operations (Kaurex 1985). More recently parts have been cleared for kauri log extraction and other farming projects (Sovereign 2009). Over recent years large areas have also been affected by weed and exotic plant infestation including the spread of Sydney Golden Wattle. The other farms are individually owned and in close vicinity to the Kaimaumau plant site. Some of these are in productive use mainly for dry stock whilst some are underdeveloped but being repurposed for agriculture/horticulture purposes.

2 RESOURCE CONSENTS REQUESTED RWHL is seeking the following consents from Far North District Council (FNDC) and NRC (Northland Regional Council) to implement this project. Far North District Council

. Land use consent for carrying out the proposed activities inclusive of earthworks, vegetation clearance, land drainage, storage and use of solvents, noise emission, and site access, in terms of the District Plan rules on these matters and Section 9 of the RMA. Northland Regional Council

. Land use consent for vegetation clearance, land drainage and earthworks pursuant to the Regional Water & Soil Plan and Section 9 of the RMA; . Discharge consent to divert and discharge surface water from draining of the peatlands using existing drains to the lower Waiparera Creek and onto Rangaunu Harbour . Discharge permit for the discharge to ground of treated wastewater from ablution and kitchen facilities associated with the processing plant, in terms of the Regional Water & Soil Plan rules and Section 15 of the RMA; . Discharge permit for the discharge to ground of treated stormwater from outdoor storage, vehicle parking and other impermeable surfaces, in terms of the Regional Water & Soil Plan rules on this matter and Section 15 of the RMA; and . Discharge permit for the discharge to air of contaminants from the processing plant, pursuant to rules of the Regional Water & Soil Plan and Section 15 of the RMA. The completed application form is attached herewith this document.

3 SITE DESCRIPTION

3.1 The Sites The extent and nature of peat resource on the various sites including the NT Sweetwater property, currently in productive farmland and in proximity to the NT Kaimaumau site, are identified in the RWHL Project Overview Report and the Soil & Rock Assessment of Potential Peat Resources together appended as Appendix B. They are also explained in the RWHL Peat Excavation Management Plan in Appendix C. A Quickmap of the target properties (peat sites) is contained in Appendix D. Figure 1 shows the resource potential of the peat deposits in Far North while Figure 2a and 2b show the target farms for peat extraction in the Kaimaumau and Sweetwater areas. The NgaiTakoto farm is the largest site at Sweetwater and is shown in Figure 2c. Details on all the target sites is provided in Table 1.

Figure 1 –Potential Peat Resources – Pukenui to Awanui Source: Soil and Rock Report

Figure 2a – Target Peat Extraction Sites Kaimaumau

Figure 2b – Target Peat Extraction Sites Sweetwater

Figure 2c – Ngai Takoto property at Sweetwater for peat extraction (Northern Block Dairy 3)

Table 1 – Peat Extraction Sites Kaimaumau And Sweetwater (Excludes NT Kaimaumau Peat land)

No. Farm Legal Description Total Ha Peat Ha Peat Depth m Zoning

1 Honey Tree Farms Lot 2 DP 497050 Section 53 SO 55920 84 15 3 Rural Prod Section 55 SO 55920 Section 54 SO 55920

2 Petricevich Section 40 SO 36657 Section 18 SO 24801 Lot 2 DP 413761 70 45 3 Rural Prod Lot 2 DP 379754 Section 71 Blk 5 Opoe SD SO27091

3 Oretere Farms Ltd Lot 1 DP 120253 Section 51 SO22981 Section 96 SO29891 Lot 2 DP 120233 Lot 2 DP 379754 172 50-80 2 Rural Prod Lot 1 DP 405064 Lot 2 DP 405064 Section 30 Blk III Opoe SD

4 Jeremy White Section 50 SO 53927 Section 41 SO 37299 Pt Section 42 SO 335329 106 50 2-4.8 Rural Prod Lot 2 DP 336507 Lot 2 DP 198540

5 J R Jones Lot 1 DP 105102 88 30 2-3 Rural Prod Lot 2 DP 105102

6 Wayne Bratton Lot 1 DP 38694 32 20 3 Rural Prod

7 Bob/Kevin Campbell Lot 2 DP184379 Lot 1 DP 193585 Lot 2 DP196114 150 60 1.5 Rural Prod Lot 1 DP40152 Lot 3 DP 40152 Lot 1 DP 497050

8 Elbury Holdings Ltd Lot 1 DP 22761 340 Joe, Fionna, Logan King Lot 2 DP 13971 (200 Rural Prod Pt Section 26 SO 28799 K'maumau, 30-50 2 & Gen Lot 1 DP193586 140 Coastal Lot 1 DP 184379 Sweetwater)

9 Iwi - Ngai Takoto/ Te Rarawa Lot 2 2500 300 3 Rural Prod Sweetwater Farms DP 365143

Honey Tree Farms Ltd adjoins the NT property on the western side. Honey Tree Farms is a 16 ha block within 1 km of the process plant and accessible by existing vehicle tracks. It is zoned for rural production. Honey Tree are re-purposing and developing their land for an Avocado Orchard and have applied to NRC for water rights which has been granted. Drainage is through the Kaurex main drain which runs through the NT property to Waiparera Stream and in turn the Rangaunu Harbour.

Figure 3a : Honey Tree Farm Petervich Farms (total 70 ha) is 2-3 kms from Processing Plant. 45 ha is suitable for peat extraction.The property borders Honey Tree Farms and in close proximity to NT Kaimaumau block.

Figure 3b : Petricevich Farm

Oretere Farm contains 50 hectares of peat deposit within 1 km of the proposed process plant. Road access is already in place on a cooperative basis. Farm drains are also in place which can be easily upgraded to drain the block.

Figure 3c –Oretere Farm Jeremy White Farm has three farms totalling 106 ha. The peat deposit of interest is in the northern farm totalling 50 ha and is partly undeveloped. Road access may require upgrading for peat movement. Peat deposit 2-4.8m deep.

Figure 3d –Jeremy White Farm

The Elbury holdings peat deposit is in swampy paddocks on the western and southern side of the property. There are eight 4 hectares paddocks with 2m deep peat deposit. The balance of the

property is very shallow with a high sand pan. The land has a gradual fall towards the harbour. Feasibility of establishing drains being investigated. Raceways will be developed in some areas for truck movement. The property is being farmed in some areas while some parts are undeveloped.

Figure 3e – Elbury Holdings Ltd

The Campbell property has shallower peat deposit over a 50 hectares area and lies on the other side of the main highway going north. Peat depth is estimated at 2 m. Feasibility of drains and is being investigated. Raceways in place.

Figure 3f – Campbell Property

Wayne Bratton and JR Jones Farms are located in the Sweetwater area . The Bratton farm has peat areas close to the lake which is not used for productive/farming purposes.Kauri logs has been removed from this area in past. The Jones farm (88 ha) has approximately 30 ha of peat deposit suitable for extraction.

Figure 4a – Wayne Bratton and JR Jones Farms Sweetwater

Ngai Takoto Northern Block Dairy 3 is 999 ha block out of total 2454 ha Sweetwater Station jointly owned by Ngai Takoto and Te Rarawa . NT has 100% ownership of the Northern Block Dairy 3 and runoff. A sealed road through the middle divides the Northern farm and the Northen runoff. The peat extraction area of interest is on the western side which is largely undeveloped at present. The eastern side is developed into dairy farms.

Figure 4 b. Ngai Takoto Sweetwater Farms Dairy 3 and Northern Runoff ( Total 999 ha)

3.2 Summary of Identified Peat Deposits Figure 2a and 2b presented above summarise the identified target peat deposit on farms in the Kaimaumau and Sweetwater area. All peat deposit sites are in close vicinity of the processing plant ranging from 1- 3 kms for those located in the Kaimaumau area and 20-25 kms for those at Sweetwater. There are a number of other farms with peal deposits in the Far North besides the one identified and targeted who would be suitable candidates for peat extraction. Some of the farmers have agreed to extraction of peat on their farms and some want to wait and see the first extraction before committing. The list of farm sites may vary over the life of the project, but will be incorporated in future management plans.

Table 2 Summary of Identified Peat deposits available for Processing

Peat Deposit Location Property Peat Average Extractable Deposit Depth (m) volume dry peat Property Distance from Zoning Area (ha) (tonnes) Process Plant

Honey Tree Farms 1 RP 15 3.0 70.457

Petricevich 2-3 RP 45 3.0 207,225

Orotere Farm Lid. 2-3 RP 50 2.0 196,358

JW White 3-5 RP 50 2-4.8 237,158

JR Jones 20-22 RP 30 2.5-3.5 142,295

Wayne Bratton 20-22 RP 20 3.0 90,627

Elbury Holdings Ltd 2-3 RP 50 2.0 184,200

Campbell 3-4 RP 60 1.5 209,528

Ngai Takoto/Te Arawa 20-25 RP 300 3.0 1,359,399 Sweetwater

Total 602 2,697,246

3.3 Zoning All the sites are have “Rural Production’ zoning. The ‘Rural Production’ zone is ‘production’ oriented. The zones in the district plan are ‘effects’ based and do not have lists of specified land use activities. The activity status of the proposed peat extraction operation (like pastoral farming and forestry) is determined by the extent of its compliance with both the zone rules and ‘district wide’ rules.

3.4 Site Ecology

The target peat extraction sites are already largely in production with some undeveloped areas. The deposits are on land either developed or being re-purposed into farmland for agriculture or horticulture purposes. They do not have any indigenous vegetation and largely no flora or fauna that needs to be protected.

3.5 Site Hydrology

The extraction of peat from the proposed sites is expected to have minimal impact on the hydrological features of the sites as.

The peat soil deposits targeted for extraction are relatively shallow and no adverse effects arising from groundwater drawdown are anticipated outside of the peats, or extending beyond the surrounding sand ridgelines; The drainage within the sites is largely controlled by ‘agricultural’ drains, most, if not all, of which, discharge into the Rangaunu Harbour; The Aupouri aquifer underlies the sites and surrounding area; A number of the adjacent horticulture/farm properties have bores that extract groundwater from the aquifer; The site contains a number of smaller ‘secondary’ drainage features from the kauri gum digging era Drainage of the proposed excavation areas is not considered to be environmentally adverse on the scale of the proposed development and associated proposed drainage network, No effects on at risk aquifers or existing lawful groundwater users are anticipated, given that the proposed groundwater diversion is from perched water within the peat soils targeted for extraction. Adverse effects on neighbouring groundwater abstraction wells are also considered negligible due to the restriction of proposed groundwater drawdown to within the surficial peat deposits. Some existing drains are noted to be effectively draining peat deposits locally within some of the sites, with no apparent environmental issues. Excavation of additional drainage lines is predicted to have little to no effect outside of mining tenement. Excavation of drains will not breach the reported hardpan between peat soils and underlying sand due to potential for groundwater inflow to proposed excavations and drains; The rainfall records show large monthly variations, 7.7mm (Feb ‘13) to 280mm (Jan’11);

Land Use Past and Present

Extraction Site Current Future

1 Honey Tree Farm Being drained for future Repurposed for future horticulture Avocado Orchard

2 Petricevich Kauri logs removal in past. Farming – Agriculture or Farms – Dry Stock horticulture

3 Oretere Bulk of it cropped (maize) Cropping and dairy

4 JW White Agriculture – Dry Stock Agriculture – Dry Stock

5 JR Jones Dairy and dry stock Dairy and dry stock

6 W Bratton Some areas undeveloped. Dry Sell. Maintain current use Stock

7 Campbell Mainly dairy Dairy

8 Elbury Holdings Ltd

9 Sweetwater (Ngai Takoto/Te Arawa) Dairy plus partly undeveloped Horticulture. Avocado. Need to remove peat.

4 DESCRIPTION OF THE PROPOSAL

4.1 Background The Resin and Wax plant is designed to produce up to 8,500 T per annum of wax and resin finished product from peat. The plant will be built in stages with the first module to be of 2,100 T of finished product per year. The operation involves harvesting peat from the peat areas, preparing the peat, solvent extracting the peat to recover crude wax and resin, reinstating the spent peat, and refining the crude wax and resin into finished saleable products for shipment to export markets.

4.2 Extraction of Peat The extent (area) and nature (depth) of the peat resources from the different farm sites is summarised in table 4. Table 3 Peat Deposits Kaimaumau.and Sweetwater Farms

Vegetation Peat Depth Vegetation M3X1000 cover Dry Peat T Dry Peat T Peat Deposit Peat Deposit Ha m Cover feet Wet Peat M3X1000 Removal restoration Honey Tree 15 3.05 2.0 466 93 70457 61854 Petricevich 45 3.05 2.0 1372 274 207225 190647 Oretere 65 2.00 2.0 1300 396 196358 180649 Jeremy White 50 3.14 2.0 1570 305 237158 218185 JR Jones 30 3.14 2.0 942 183 142295 130911 Wayne Bratton 20 3.00 2.0 600 122 90627 83376 Campbell 50 2.44 2.0 1219 305 184200 170482 Elbury 50 2.77 2.0 1387 305 209528 111888 NTSweetwater 300 3.00 2.0 8998 1829 1359399 1264241

Peat Extraction Plan The peat extraction plan is covered in detail in the attached Peat Extraction Management Plan (Appendix-E).

The peat is covered by vegetation and has some windblown sand on the surface. Sand is ingrained in the peat and the peat sits on a hard sand pan bed. The water content of the peat is high - up to 100% on a dry basis. The extraction area will need to be drained before excavating to recover the peat. The peat is approximately 3 metre deep in most locations. It is proposed that the first stage of the peat operations is started with extraction from the Honey Tree Farm. This area has already been largely cleared and main drains exist for draining the peat. It is the closest site to the proposed process plant and farm track exists to cart the peat to the processing site. The deposit has high extractables (resin and wax). It is being currently re-purposed for Avocado orchard. Extraction The peat will be recovered after draining the selected area and removing the Sydney wattle and gorse vegetation. The area to be extracted will depend on the throughput of the process plant. It is estimated to be 5 ha/year initially rising to 20 ha/year as process plant capacity builds up. The vegetation will be cleared and drains established 200m apart. These initial drains will follow previous drains and take the water into existing drains. The new drains at 200m apart will reduce the water in the peat in the local area and will enable the handling of the peat. Lattice drains every 20 to 40m will connect to the main drains and form a rectangular extraction site and will be opened to drain the water from the peat into the existing major drains.. These drains can be blocked after the operation and allow the moisture to build up in the returned peat.

100 m

25 m 75 m 75 m

25 m 100 m 75 m 75 m

25 m 75 m 75 m

25 m

Figure 6 Drain pattern per Hectare

Peat Harvesting

The area to be harvested will be cleared of scrub and drained. The excavation will be carried out utilising large face shovels. Peat excavated from the field will be hauled to and dumped on a Grizzley. Stumps and large wood pieces will be mechanically raked off and passed through a Chipper. The roughly screened peat will be transported to drying pads. These drying pads will provide surge capacity between extraction and the processing plant which will operate 24 hours a day seven days a week. Screened peat will be reclaimed from the drying pads and delivered to the Damp Peat Storage. This will be a covered area where further drying takes place out of the rain. The air dried at ~35% moisture will then be fed to the feed preparation plant. This operation will be carried out by the harvesting crew in daylight six days per week and as required by the processing plant. Peat Preparation and Processing

Air dried peat from the drying pads will be rescreened at 20mm on a primary peat screen. The oversize, sticks , gum lumps and peat clods will be passed through a Lump breaker and recycled to the primary peat screen. Screened peat will be conveyed and distributed into the Screened Peat Silo. Peat will be drawn continuously from the Screened Peat Silo at the required rate to feed the main solvent Extractor Crown Mk IV controlled through a rotary valve. After extracting the resins and waxes from the peat the remnant peat will be remixed with the branches and material from the screens and returned to the area where it was taken from. The operation is small and the initial production unit will shift around 1200 cu.m per week rising to 5000cu.m per week as the production unit expands. The peat recovery operation will run during daylight hours weekdays and will not operate on weekends.

Equipment The equipment will be a small bulldozer to remove vegetation and a 30T digger to load the peat into the disc screen and tractors and trailers to cart to the drying pad. The digger needs to handle the kauri logs and will be oversized for this purpose. Tipping trailers with tractors will take 10cu.m per load of peat to the drying pad. Two trailers and two tractors will be required to be efficient for the digger. A separation disc screen will be needed at the peat extraction site to separate the peat from branches and woody material. This screen will have a small hopper, a screen and a conveyor to load the trailers.

Equipment used for extracting and transport of peat It is planned to stage the peat extraction process by management zones based on the identified peat areas to guide the excavation of the raw wet peat and its restoration after processing, The rate of extraction will be governed by the demands of the processing plant. In terms of land area approximately 5ha/year is estimated to be worked in the initial stages rising to 20-25ha/year as the capacity of the processing plant is expanded.

Learning Management (LM) is especially useful for extraction projects such as the proposed RWHL activity where the potential environmental impact is difficult to predict with certainty. Also due to variability of the natural environment, between different parts of the site and over time make prediction difficult. LM will build an iterative decision framework based on monitoring-evaluation- adjustment cycle to mitigate or remedy effects on the hydrology and ecology of the extraction areas. Although monitoring will come at a cost, the flexibility of this approach will make it more efficient to deal with uncertainties, minimise waste of resources and improve the environment outcomes. Data will be collected on the site hydrology including change in ground water levels in the adjoining reserve and conservation areas and characteristics (turbidity, colour etc) of the drained water discharge to Waiperera stream. Also grab samples will be taken to collect sediment samples to allow characterisation of any solid (peat fines from extraction) discharge and silting in the Waiperera stream. This will be compared against a baseline established before starting extraction.

Buffer from any conservation or wetland areas Although all the sites are in productive use one (Oretere Farm) contains areas of land marked as conservation area . Appropriate buffer will be provided between the extraction and conservation

areas as per Council rules for required separation between conservation land and wetland and area of activity.

4.3 Processing Operations A schematic of the RWHL process plant for recovery of resin and waxes from peat is shown in Figure 5 below. The input and output for the processing operation is summarised in the Beca block diagram Figure 6 . Details on the operation is provided in the Beca Study attached as Appendix J. Process Plant Siting The plant will be located on the south western edge of Ngai Takoto’s Kaimaumau property in the same location as the old Kaurex plant. The processing plant and associated drying and storage areas, along with facilities for staff, are to be developed on the south-western part of the site adjacent to the northern end of Norton Rd. The processing plant and associated facilities are expected to occupy an area of 130m by 200m or approximately 2.6 ha.

Figure 5 Plant layout Resin and Wax Kaimaumau

Fig 11 Process Plant Schematic

Fig 6 Process Plant Inputs and Outputs

Operations

4.4 Pilot Plant In order to test and optimize the process for extraction and recovery of resin and waxes from kauri peat RWHL has installed and commissioned a pilot plant for this purpose. The pilot plant is located at Kaitaia and in operation. The plant has been fully consented by Northland Regional Council. The process equipment for this temporary facility is housed in 20 foot containers as shown in figure below. It is expected the unit will operate for 12-18months. There are no air emissions or fluid discharge from this process..

Peat is removed from sites in Kaimaumau and trucked to the pilot plant in three 300kg peat baskets. The spent peat in the process is put back on the truck after use (still in their baskets) and trucked back to the original site. The spent peat is air-dried to remove any residual solvent before return. Residual solvent (butyl acetate) in the spent peat is very low (ppm) and is biodegradable.

As the solvents in this process are valuable the unit is designed so that no solvent leaves the system and escapes to atmosphere. Therefore, there is no emission stack in this process. The process uses cooling water for its condensers (by indirect contact) and this is the only fluid leaving the system. There are no air emissions or water discharge from the process itself. The equipment and layout, as displayed in figure 2, comply with and are designed according to the AS/NZS 60079.10.1 standard and HSNO regulations for flammable liquids (Class 3.1B).

4.5 Processing Plant Site and Operations The processing plant site and operations is described in the Beca report attached. The plant site location is on Norton Road, west of Kaimaumau settlement

Figure 7 Process Block Diagram The overall process comprises peat extraction, drying, storage, solvent extraction, solvent recovery, product separation and packing.

Peat is extracted and screened at the extraction location to remove large sticks and other debris. Peat is transported by tractor trailer units to the peat drying area.

Peat is screened a second time then dried in windrows on a pad and reclaimed and stored in covered bunkers. A bulk stockpile is envisaged to maintain a sufficient buffer to feed the extraction plant continuously and be decoupled from the peat harvesting, screening and drying operations. This will allow 5 day a week mining operations in daylight only and also allow for a seasonal harvest of dry peat to bunkers to allow flexibility during the wet winter months. Storing peat in a bunker minimises the risk of fire and dust nuisance and minimises the issue of stormwater runoff from the prepared peat.

Dried and screened feed material is fed from the dry peat bunkers to a feed hopper by a wheel loader. The material flows to a surge bin with a nominal capacity of 2 hours. Each extractor will have its own surge bin.

The peat will be metered into a counter-current extractor unit using a weigh belt. In the extractor, hot butyl acetate solvent at 80°C – 85°C is contacted with the peat. The mass ratio of solvent to peat is maintained at 3:1. The solvent moves counter-current to the peat in order to recover all the wax and resin. After leaving the extractor the spent peat is conveyed to the desolventiser where it is stripped of residual solvent using heat provided indirectly by steam. The spent peat is then conveyed from the processing plant to a spent peat pad and taken back by tractor trailer unit as a backload to the excavated area for reinstatement. The spent peat has physical characteristics largely similar to the fresh dry peat, along with some residual butyl acetate (ppm) solvent. This residual solvent will readily biodegrade in the natural environment.

The miscella (a mixture of solvent, wax and resin) from the extractor is concentrated to increase the wax and solid content using multi-stage evaporation. The evaporated solvent is cooled and recovered for re-use and recycled back to the process. The concentrated miscella is then further processed in a series of steps (treated with methanol and hexane) to separate and refine the resin, wax and asphaltene fractions.

The resins are extracted from the concentrated miscella by extraction with methanol. The resins are soluble in liquid methanol and go into solution. The solution is decanted, cooled and filtered to give a resin-rich liquid. The resin is separated by boiling off the liquid methanol under vacuum. Resin product is stored in heated, insulated storage tanks prior to drumming off.

The insoluble or the solid fraction after the methanol extraction contains the wax and asphaltenes. This is treated with hexane to remove the asphaltenes and progressively cooled to lower temperatures to yield different wax cuts (grades). Wax and asphaltene products are stored in heated, insulated tanks prior to drumming off.

Within the plant there will be solvent recovery systems for collecting process solvents and purifying them for reuse. All tanks and vessels within the plant will be vented into the solvent recovery system. Some solvent is lost as vapour discharge in the evaporation process, but all significant vents will be ducted to condensers and recovered. All the drains from the chemical process area will be collected and treated before discharge.

Molten wax and molten resin will be pumped from storage tanks to the packing shed for packing. Packing will be done on day shifts. The wax will be held in insulated and steam or hot water heated Wax Packing Tanks from where it will be drawn off to the drum filling line. Molten resin will be held in the Resin Packing Tanks from where it will be drawn off to the drum filling line. Asphaltenes will be packaged in a similar manner. Peat ex the desolventisers will be conveyed to a waste peat stockpile for wetting and reinstatement back into the peat extraction area . It will be as a backload on the transport bringing fresh peat.

4.6 Plant Site Access and Layout The plant site is accessed via Norton Road. The plant is located to the north of Norton road. See the site layout plan for the precise orientation of the plant site with respect to the road.

4.7 Plant Utility Services

4.7.1 Electricity Supply A transformer supply of 1 MVA capacity will be situated on the site road boundary. This will be expanded with a further unit for plant expansion. We understand the local transmission lines still have nominal capacity available that was utilised during the original Kaurex operations.(TBC Northpower)

4.7.2 Potable Water Potable water will be provided by rainwater caught from the utilities building and extraction plant building and treated for potable domestic uses.

4.7.3 Steam Steam will be raised in a diesel-fired package boiler initially (Stage 1). The nominal duty is expected to be of order 2 MW. The steam pressure will be of order 17.5 bar(g). For Stage 2 (expanded plant) steam will be raised in a peat or other biomass fired boiler on the opposite side of the plant to the general utilities area on the other side of the extraction plant. The nominal duty is expected to be of order 5 MW.

4.7.4 Refrigeration services Chilled glycol will be generated using an air-cooled package chiller located outdoors at grade. The nominal duty is 300 kWhr. Glycol will be stored in two 40 m³ insulated storage tanks adjacent to the

chiller unit. Tankage is sized for the stage 2 expansion and will not be required to be expanded later. In stage 2 a water cooled chiller with cooling tower is envisaged.

4.7.5 Cooling Tower A cooling tower in stage 1 and a second cooling tower in stage 2 are envisaged with duties of 2 MW and 5 MW respectively. These are located at grade in the utilities area.

4.7.6 Nitrogen Nitrogen for blanketing will be generated using a membrane nitrogen generator with a small surge storage vessel.

4.7.7 Fire Fighting Water Supply Fire-fighting water supplies will be supplied from a fire water pond located adjacent to the facility. The pond shall be sized based on the largest solvent vessels. Electric and standby diesel firewater pumps will be provided.

4.7.8 Plant Effluent Treatment A proprietary oily water effluent treatment package will treat any solvent-bearing water streams and/or any blowdown water streams before discharge to the local watercourse.

4.8 Management of Plant Wastes

4.8.1 Emissions to Air Process vents will pass via condensers using cold glycol to condense the majority of solvent vapours. Any remaining solvent vapours and foul air will be sent to either a flare or the power boiler system(s) for co-firing disposal. Some butyl acetate solvent (less than 0.05% by mass of the spent peat TBC) will be absorbed on the spent peat and returned for reinstatement (from where it was extracted) where it will bio-degrade. In stage 2 a fraction of the spent peat may be burnt in the biomass boiler after evaluation of its suitability.

4.8.2 Emissions to Air Expected emissions to water will be treated using a package wastewater treatment plant. These include any boiler and cooling tower blowdown, vacuum pump seal water and any plant spillages. Treated water will be discharged to the local watercourse.

4.8.3 Solid Waste Solid wastes are expected to include broken pallets, retired balage bags or wrappers, miscella filter waste, spent filter cartridges or elements and minor laboratory waste. In Stage 2 if a biomass boiler is retained, ash will also be produced that will be sent to landfill.

4.9 Internal Access Road and Site Landscaping

4.9.1 Hardstanding Hard standing areas will be minimised and areas left pervious where possible in compacted gravel. If dust nuisance is expected or encountered some areas may be concreted or asphalted where required. Truck turnaround areas will be concrete or asphalt.

4.9.2 Permeable areas Permeable areas will be variously graded and swaled to direct surface water flows to the stormwater pond.

4.9.3 Heavy Vehicle Access Heavy vehicles delivering solvents (in 20 tonne isotainers), diesel (by tanker), and 40’ containers of drums and pallets will access via a dedicated access way with controlled access. Semi-trailer side loaders will drop the 40’ containers under a canopy where drums and pallets can be unloaded under shelter. Table below shows the expected truck movements of isotainers, 40 foot containers and other trucks

Cargo Stage1 (trucks/week) Stage 2 ((trucks/week) Solvents 1 4 Diesel 2 - Products 3 11 Solid waste 1 3

4.10 Past Industrial Plant Soil Contamination There is no evidence of soil contamination from any previous industrial activity on the site. Much of the peat over 200 ha has been disturbed by swamp log recovery, but no chemicals were used to treat the peat in the ground.

4.11 Hazardous Substances Storage and Use

4.11.1 Diesel Diesel storage will be provided for the stage 1 boiler operation. This will require approximately 27 tonnes per week of diesel which will be stored in a similar petroleum vessel envisaged for the solvents. This vessel will be recharged by road tanker

4.11.2 Solvents storage and use The table below shows the quantities of solvent that are expected to be required for the operation Solvent Stage1 mt Stage 2 (Expansion) mt Butyl Acetate 110 450 Methanol 10 40 Hexane 50 190 Diesel 50 - Stage 1 Volume (t) Stage 2 Volume (t) Solvents will be stored in double-skinned proprietary horizontal vessels in an area located away from the extraction plant.

4.12 Access Road and Plant Construction Construction will require the delivery and placement of several package units including extractors, boilers, and solvent vessels and potentially pre-assembled pipe rack sections. The required craneage is expected to be able to be serviced by standard mobile cranes. Road access is via Norton Road. The plant is located to the north of Norton road

4.13 Fire Prevention Plan Dual fire water pumps with electric and diesel motors will be provided to supply high pressure and deluge firewater systems. Two ring mains will provide these services around the extraction and refining plant and the bulk solvent storage area. A fire-fighting pond initially estimated to be of volume 530 m³ will be required based on the volume of flammable solvents on site.

4.14 Plant Related Monitoring Strategy Effluent streams from the processing plant will be regularly analysed and monitored to ensure that the levels of contaminants are within the permissible levels and recorded. Plant operators will be trained to duly report any excursions and corrective action taken. Incidents of serious nature will be immediately reported to local authorities and fully investigated and new measures put in place to avoid such incidence in future.

Packing

Molten wax and molten resin will be pumped to the packing shed for packing. Packing will be done on day shifts. The wax will be held in steam heated Wax Packing Tanks from where it will be drawn off either to a Sack Filling Line or to the Wax Flaker (to be confirmed based on market requirements). Wax from will be packed in 20 kg multiwall bags in the bag packer. Molten resin will be held in the Resin Packing Tank .It will be drawn from the packing tank into the Twin Drum Resin Flaker .Solidified resin will be scraped and delivered to the Bag Packer where it will be packed into 20 kg multiwall bags and loaded onto pallets for shipment in containers.

Services

Services include high and low pressure steam, water treatment for boiler feed and potable water, cooling water, inert gas generation, refrigeration, compressed air and fire services. Steam will be generated at 10 bar and some of it is used for high temperature heating and motive steam for steam ejectors. The steam will be let down for process use and heating. All steam condensate will be returned to the boiler hotwell and make up water added. Make up water will be treated water from the water treatment plant. Bore water will be provided by two deep well pumps and used as supply for potable and process water and for additional makeup in the fire ponds. Fire and cooling water will be provided from the fire pond which will also act as the cooling pond. Water will be drawn from the pond using two cooling water pumps. A third pump connected to the plant essential electrical supply system will be maintained and connected to the essential exchangers to maintain supply during process upsets. The cooling water return after process duty will be via a cooling tower. The fire pond will also provide water for the high pressure fire hose ring main and a low pressure Deluge system. The fire system will have both electric and diesel driven pumps. Plant air and instrument air (oil and water free) will be provided by plant air and instrument air compressor. Inert gas for blanketing and for blowing resin and wax filters will be provided by an Inert Gas Generator using methanol as fuel. Solvent loss for economic as well as environmental reasons discharges from the processing plant will be minimal and monitored.

There are no catalysts used in the process.

Noise Some noise will be generated by rotating machinery in the plant pumps, fans etc. Noise level on all equipment will be controlled to the levels permitted. Due to the remote location and nature of surrounding country noise from the plant is not expected to create any adverse impact.

Resources

It is intended to extract and process 3.8 mill dry tonnes of peat or approximately 20 mill cubic metres of peat over a 30 year period. This will sustain a production of an annual production of 10,000mt of finished wax and resin over 30 years. Some of the extracted peat may be used as a fuel for steam generation. Water is required for the boilers and in the solvent processing plant for condensing the solvent vapours. The process does not use any process water. The losses are mainly evaporation in the cooling tower and boiler blowdown. The facility will be a small electricity user. Electricity will be bought from the grid.

4.15 Soil and Geotechnical Assessment An examination of the soil order maps of New Zealand (www.nzsoils.org.nz) shows that the greater Kaimaumau area and other peat areas in the Far North is underlain by both organic and podzol soil types. Organic soils are primarily comprised of decomposed wetland plants (e.g. peat). Podzol soils include accumulation of aluminium and iron oxides in association with organic matter and are typical of areas of high rainfall. Both soil types represent potentially viable underlying peat The region is predominantly relic dune deposits with interspersed swamp and lake areas. Review of available geological maps and reports showed the targeted area comprised “Unconsolidated to poorly consolidated sand, mud, peat and shell deposits of estuarine, lacustrine, swamp, alluvial, and colluvial origin” (GNS Science, 1996). Peat formation had occurred through establishment of kauri forest within low lying areas of older fore dunes during a period of low sea level, with forest collapse following subsequent sea level rise leading to thick accumulation of peat in inter dune hollows.

Geotechnical Assessment A geotechnical assessment of the plant site for construction of the plant and buildings etc was made by Riley Engineers for Kaurex in 1985. The location for the process plant under this proposal is the old Kaurex site and the geotechnical data and assessment stays relevant as little activity has taken place at the plant site and there has been no natural upheaval or phenomenon in the surrounding area. The geotechnical assessment concluded that liquefaction is not an issue at the site and unlikely to affect the proposed structure during the design life. The liquefaction potential was determined on the basis of five criteria – particle size, groundwater, sand density, confinement and dynamic excitation - which must be satisfied simultaneously for liquefaction to occur. At this site, although the particle size analysis of sand samples fell within the envelope of liquefiable sands, however, the other four criteria were not satisfied simultaneously with the particle size. Also an earthquake of sufficient intensity is required to produce the dynamic excitation causing liquefaction. The site was in Zone C (now Zone 1 NZS 1170:2004) giving the least severe earthquake intensity for a given return period event. This work also established that the most suitable foundation system for plant buildings would be use of pad footings beneath any structural column. It is proposed to house the main plant within a high steel portal frame structure which will be unclad and open to sides and constructed on a cut platform on the ridge.

The area surrounding the plant site consists of predominantly peat low lands dissected by sand ridges. The sand ridges are generally 2 m above level of surrounding ground. The ridge on which the plant will be located is the highest in the area being 5m above level of surrounding ground. A cross- section of the site shows a uniform sub-soil profile as shown in figure below.

5 CONSULTATION A number of meetings have been held with NRC and FNDC officers and Department of Conservation to explain the project and get feedback on their concerns and the best way to address these. RWHL are also working closely with Ngai Takoto as they finalise the plans for development of their land both at Kaimaumau and Sweetwater. A presentation has been made to the wider Iwi on the project RWHL have also consulted the neighbours who may be affected and have secured their consent for the process plant. RWHL continue to consult with DOC, Forest and Bird, NRC and FNDC to bring their plans to fruition.

Table 4 - Consultation

Party Reason Status Date advised Date Approval given

Te Rūnanga O Ngai Land Owner Agreement signed July 17 Jun 19 Takoto

Department of Kaimaumau title Number of July17 Conservation meetings held DoC, Dec18-Sep 19 Ngai Takoto and

RWHL Royal Forest and Bird Kaimaumau title Waiting for Mar-Jul 19 Society response

Ian Broadhurst Neighbour July 17 27 July 2017

Claude Ilton Neighbour July 17

HoneyTree (Tony Neighbour July 17 Hayward)

Katherine and Damien Neighbour July 17 30/8/17 Holloway

Aaron and Julian Neighbour Dec18-Feb 19 Bainbridge

Ian Fulton Neighbour July 17 30/8/17

Honey Tree Farms Land Owner Dec18-Feb 19 Feb 19

Oretere Farms Land Owner Dec18-Feb 19 6/3/19

Campbell Land Owner Dec18-Feb 19 Feb 19

Elbury Land Owner Dec18-Feb 19

Johnny Jones Land Owner Dec18 Feb 19

Jeremy White Land Owner Dec18 Feb 19

Petervich Land Owner Dec18-Feb 19 6/3/19

W Bratton Land Owner Dec18-Feb 19 Feb 19

6 DISTRICT AND REGIONAL PLAN ASSESSMENT A set of interrelated resource management documents required by the Resource Management Act and administered by the District and Regional councils outline the objectives, expected outcomes and rules governing development such as the proposed activities for the RWHL project. This includes

1. Far North District Plan 2. Northland Regional Council Regional Policy Statement 3. Regional Soil and Water Plan –Northland Regional Council The key rules impacting the RWHL project are summarised below. It is worth noting that whilst the FNDC plan seeks to promote sustainable management of natural and physical resources in the district it also explicitly recognises that the district needs “economic development in order to improve the well-being of its people” and believes it is important “to ensure that the plan avoids unnecessary intervention while requiring a satisfactory level of environmental protection”. The emphasis is on control on the effects of an activity which can be achieved by remedying or mitigating any adverse effects.

FNDC District Wide Rules (Whole Site)

Activity Rule Requirement Status

All excavation and filling that exceeds a 12.3.5.1 Permitted certain minimum volume requires a resource consent

Excavation and/or filling, excluding mining 12.3.6.2.3 provided that it does not Permitted and quarrying, on any site in the Rural exceed 20,000m3 in any Production Zone or Kauri Cliffs Zone is a 12 month period per site. restricted discretionary activity,

An activity is a discretionary activity if: (a) 12.7.6 The Council may impose Discretionary it does not comply with one or more of the conditions of consent on a standards for permitted or restricted discretionary activity discretionary activities as set out under When considering a Rules 12.3.6.1 and 12.3.6.2 discretionary activity application, the Council will have regard to the assessment criteria

Rural Production Zone Rules

Clearance of not significant indigenous 12.2.6 Compliance with specified vegetation and not within an indigenous standards wetland area

Clearance of indigenous vegetation that is 12.2.6.3.1 Not Specified Discretionary more than 10 years old and not within 20m

of an identified indigenous wetland

Earthworks of more than 5000m3/year 12.3.6.2 Not Specified Discretionary and/or cuts and fills more than 1.5m

Clearance more than 1ha/10 years of not 12.2.6 Not Specified Discretionary? significant indigenous vegetation more than 10 years old and not within 20m of any identified indigenous wetland areas

Earthworks of more than 300m3/year 12.3.6.2 Not Specified Discretionary and/or cuts and fills more than 1.5m in height

Clearance of vegetation that has not been 12.1.6.3 Not Specified Discretionary previously cleared and/or is more than 10 years old

Earthworks of more than 300m3/year 12.3.6.2 None specified Discretionary and/or cuts and fills more than 1.5m in height

Far North District Plan Rural Production Zone Assessment The ‘Rural Production’ rules in Chapter 8.6 of the FNDC plan are structured and are based around a number (12) of common ‘development standards’. The ‘development standards’ relate to primarily buildings and other matters. They do not affect the peat extraction activity. However the processing plant requires assessment against the relevant zoning and resource rules as a stand-alone activity involving buildings and including such matters as scale of activities, building height, and noise. This assessment is summarized below. Rules 8.6.5.1.1-12

RULE No. SUBJECT RULE COMMENTS/ASSESSMENT

8.6.5.1.1 RESIDENTIAL INTENSITY Residential Not Applicable development shall be

limited to one unit per 12ha of land.

8.6.5.1.2 SUNLIGHT No part of any building All buildings set 10m from shall project beyond a boundary and will satisfy 45 degree recession rule. plane as measured inwards from any point 2m vertically above ground level on any site boundary

8.6.5.1.3 STORMWATER MANAGEMENT The maximum Gross site area proportion of the gross 200mX300m=60,000m2. site area covered by Building and other buildings and other impermeable area impermeable surfaces =60mX70m=4,200m2 and proportion of gross site area

shall be 15%. 7%.Permeable areas will be variously graded and swaled to direct surface water flows to the stormwater receiving body Hard standing areas will be minimised and areas left pervious where possible in compacted gravel If dust nuisance is encountered some areas may be concreted or asphalted where required. Truck turnaround areas will be concrete or asphalt Roof water will be collected for domestic purposes, treated and filtered as required. Excess roof water will flow to stormwater

8.6.5.1.4 SETBACK FROM BOUNDARIES No building shall be All buildings will be set at erected within 10m of least 10 m from any any site boundary boundary

8.6.5.1.5 TRANSPORTATION Rural Production zone GBA for the process plant Traffic Intensity 5700 m2. Permitted Traffic (maximum daily one- Intensity factor (10/100m2 way traffic movement) GBA) is 570. The Average threshold for permitted Daily One Way traffic activity 60 if access via movement (Traffic Intensity State Highway. For Factor) will be much below minerals threshold 200. this. Heavy vehicles Discretionary activity delivering solvents (in 20 threshold more than tonne isotainers), diesel (by 200 for both categories. tanker), and 40’ containers Traffic Intensity Factor of drums 10 per 100 m2 GBA and pallets will access via a (Gross Business Area) dedicated access way with for Industrial Activities controlled access. Semi- trailer side loaders will drop the 40’ containers under a canopy where drums and pallets can be unloaded under shelter.The maximum frequency of isotainer, 40’ container and other trucks is as follows (trucks/week): Solvent-1,Diesel-2,Products- 3,solid waste-1 Total 7.Car parking for upto 20 staff on site at any one time will be provided in Stage 1. This will be provided with a separate access driveway isolated from heavy transport

8.6.5.1.6 KEEPING OF ANIMALS Any building, compound Not Applicable or part of a site used for factory farming or a cattery, shall be located no closer than 50m from any site boundary and 300 m in case of boarding kennel

8.6.5.1.7 NOISE All activities to ensure Noise levels will be that noise from the site controlled to levels specified shall not exceed the in rule 8.6.5.1.7 .Noise is following noise limits as generated by rotating measured at the machinery in the process boundary of site plant pumps , fan etc. There 0700 to 2200 hours 65 are no large rotating dBA L10 machinery such as compressors or steam 2200 to 0700 hours 45 turbines involved. dBA L10 and 70 dBALmax. Sound Due to location of the plant levels shall be measured and the nature of the in accordance with NZS surrounding country noise 6801:1991 from the plant is not expected to present any

problem. Peat extraction equipment will be operated during daylight hours Monday to Friday. Again due to the isolation of Kaimaumau site no noise problems are anticipated from extraction operations. If needed, noise suppression element will be added on engines of mobile equipment used for peat extraction. Also reference to wind vector diagram attached herewith Fig 4&5 show that prevailing winds will have the effect of directing noise emission from outside plant away from existing residences.

8.6.5.1.8 BUILDING HEIGHT The maximum height of The maximum height of a any building shall be structure on the process site 12m. is the extraction plant with a height of 15m. The structure itself is not an enclosed building .It will be open on all sides. The structure has a roof supported by steel columns with operating platforms at three levels. See attached Crown drawing

Fig 2. Although building height for permitted activity is 12 m Council can approve building height up to 15m as discretionary activity.

8.6.5.1.9 HELICOPTER LANDING AREA Helicopter Landing Area No helicopter landing area at least 200m from planned at this stage nearest residential boundary

8.6.5.1.10 BUILDING COVERAGE For Permitted Activity Total leased area from Ngai the total Building Takoto for the process site is Coverage of a site to not 200mX300m i.e, 6ha. See exceed 12.5% of the excerpt from lease gross site area agreement Fig3. Area needed for the process plant including future expansion is less 130m X 200m i.e 2.6ha. See attached site plan Fig1. Each grid measures 10mX10m. Building Coverage for stage 1 is 4%. With future expansion building coverage increases to 7%.

8.6.5.1.11 SCALE OF ACTIVITIES Total number of people Process and packaging engaged at any one facilities for rural industry period of time in exempt from rule. Total activities on a site to be process plant operating 8 persons per site or 2 personnel on site at any persons per 1 hectare of given time will be 20 net site area, whichever is greater. This number may be exceeded where persons are engaged in constructing or establishing an activity (including environmental enhancement) on the site. Processing and packaging facilities for farming, forestry, and any rural industry that is dependent primarily on the direct handling of raw produce is exempt from this rule

8.6.5.1.12 TEMPORARY EVENTS Temporary events Construction and permitted if activity has establishment phase of the duration of no more project is a temporary event than 2 days, operate which is allowed under Scale

between 6.30am and of Activities and 10pm and does not Transportation rules. involve assembly of 500 Construction activities when persons. TE need not establishing an activity are comply with traffic exempt from traffic intensity parking and access rules requirements

The rules governing Earthworks and Vegetation Clearance are specified in C.8.3.1-C.8.3.3 and C.8.4.2-C.8.4.3 of the Proposed Regional Water and Soil Plan.

NRC Regional Water and Soil plan

Activity Rule Requirement Status Earthworks is a permitted activity C.8.3.1 5000 square metres of Permitted provided: exposed earth at any one 1) the amount of earthworks at a particular time for all other areas location or associated with a project which is not specified complies with the thresholds Requirements are 1)erosion and sediment control measures are implemented; 2)batters and side castings are stabilised to prevent slumping 3)earthworks does not create or contribute to the instability or subsidence of land on other property, 4) divert flood flow onto other property, Earthworks not covered by permitted and C.8.3.3 Not covered under Discretionary controlled activity is Discretionary permitted or controlled activity

Vegetation clearance within 10 metres of a C.8.4.2 1)the area of cleared Permitted natural wetland or within 10 metres of the vegetation does not bed of a river or lake, and any associated exceed 200 square metres damming and diversion of stormwater and in any 12-month period, discharge of stormwater onto or into land and 2) vegetation is felled where it may enter water, are permitted away from rivers, lakes, and natural wetlands, , 3) vegetation, or debris is not deposited in a position where it could mobilise and: a) be deposited on other property, or d) damage receiving environments, downstream infrastructure and 4) any discharge of sediment

originating from the cleared area does not give rise to beyond a 20 metre radius of the point of discharge: a) any conspicuous change in colour or clarity, or b) rendering of fresh water unsuitable for consumption by animals. Vegetation clearance that is not a: 1) the area of cleared C.8.4.3 Discretionary vegetation does not 1) permitted activity under C.8.4.1 exceed the following 'Vegetation clearance and coastal dune thresholds in any 12 restoration within the coastal month period: hazard management area – permitted a) 200 square metres activity' , or within 10 metres of a 2) permitted activity under C.8.4.2 natural wetland or the bed 'Clearance of native woody vegetation – of a river or lake, or permitted activity' b) five hectares on highly erodible land if the cleared is a discretionary activity. area is replanted with woody vegetation within six months from completion of the clearance, or c) 5000 square metres on highly erodible land if the cleared area is not replanted with woody vegetation,

NRC : Regional Water & Soil Plan Land Drainage, Groundwater and Surface Water Related Activities

Activity Rule Requirement Status

The damming, diversion and discharge of C.4.1.1 2)any resulting land Permitted water associated with land drainage are subsidence or slumping permitted activities, provided: does not cause adverse effects on structures or infrastructure on other property, and 3) the discharge is in or from the same catchment in which the water would naturally flow, and 4) a new drain is not constructed within 15 metres of an existing wastewater disposal area.Not Specified

In an existing drainage district (refer I Maps C.4.1.6 Controlled |Ngā mahere matawhenua), the: 1) taking,

diversion and discharge of drainage water associated with the drainage of land, or

Land drainage or flood control work C.4.1.7 Discretionary (including new land drainage or flood control schemes and new structures within schemes), including:significant

None of the proposed activities are Prohibited Activity under the District and the Regional plans. Although the level or quantity of work in the proposed activities exceeds the levels specified as a Permitted Activity and its status deemed as Non-complying they are all activities which are allowed and discretionary subject to the District and Regional Council exercising its discretion in the matter of granting consents for the activity to proceed.

7 ASSESSMENT OF ENVIRONMENTAL EFFECTS

7.1 Overview of Effects The excavation of peat to remove the waxes and resins will be undertaken on the NT site at Kaimaumau and other farms in close proximity. The processing production plant will also be on the NTsite. Truck movements on site to transport the peat to and from the process will be on temporary roads on the site and only deliveries and final products will exit the site onto public roads. The industrial noise, movement and any windblown particles will be on site and with the prevailing SW wind will be blown onto the Kaimaumau site. The peat will be excavated as shown in the management plan, dried in windrows and then processed. About 80% of the dry weight of peat will be returned to the area it was taken from. There is some opportunity to contour the returned peat to make it more suitable for its next use – horticulture, agriculture or replanting. The site plan – fig 3 shows the location of the processing plant and the staging of excavating the peat. Specific Effects Mitigation

Excavation of peat stage 1 5ha/yr 80% of peat returned to its location Reduction of Exotic species – Sydney Golden Wattle. Average excavation depth 2m. Some areas may be deeper.

Drainage of peat Limited to the work area Water will be drained into the previous work area and then into

existing drains.

Peat drying The peat will be dried in wind rows and then moved into walled recovery areas to reduce wind blown dust

Trucking of peat to processing plant Will be on site and returned to excavation site

Recovery of kauri swamp logs These will be put aside for use by the Iwi and landowners

External trucking of product 6 trucks per week

Solvent and diesel supplies 3 trucks per week

Staff cars max 50 people Mixture of day and shift work

Diesel tank Stored and bunded as per FNDC practice

Solvent tank; Butyl Acetate, Methanol and Stored and bunded as best practice Hexane

Air emissions - combustion products from Combustion products will be dispersed via a boiler stack

- Fugitive gases Solvent gases will be collected and only minor fugitive emissions released

Factory structure Factory area ?sq m maximum of 3 stories high

Amenities building and office Single story building less than 100sq m. will be built to NZ building code

Wastewater from land area Piped to wastewater pond before discharge

Sewerage Septic tank which will be emptied as required

7.2 Permitted Baseline Considerations The proposed activities either comply with or are discretionary under the district and regional plans. Consents are required to build and operate the processing plant and drain the operational area of the peat excavation. Surface water from the peat extraction sites drain through the Motutangi and Waiharara Drainage District drain network to Rangaunu harbour.

7.3 Existing Environment Considerations The Kaimaumau area has wet peat and a number of drains to take water to the harbour outfalls. Some of the sites have been disturbed by past kauri log excavation. The sandpan under the peat is

hard and will not be disturbed by the excavation actions. All the sites are mostly in productive agriculture use with some undeveloped areas. Agriculture drains connect the sites to existing district drainage network.

7.4 Peat excavation and Rehabilitation Related Effects The peat excavation is described in the RWHL management plan report. The excavation is small scale using one hydraulic digger and tipping trailers to transport peat to the drying pad. The mine site is limited in area and will take peat from 5ha in stage 1 and 20 ha in stage 2 per annum. The peat will be drained to existing drains before it is taken to the drying pads. After processing 80% of the dry peat will be returned to the excavation site to be contoured for productive growth, or returned to original use which will be managed by the landowner. Limited overburden will be removed from the peat and the plant matter on the surface will be shredded. Both the overburden and the shredded plant material will be mixed with the returning peat to form the recovered surface.

7.5 Soil Conservation

7.6 Land Drainage and Hydrology The peat in the excavation area will need to be drained, but as shown in the hydrology report by Soil and Rock the drainage will be local – water does not flow easily through peat. The general area has a number of low sandy ridges and these separate the land into a hydrological mosaic which helps keeps any effect local to the area being drained. Studies by DoC (Hicks 2000), Soil and Rock (2016) and Williamson (MWWUG 2015) have all concluded the presence of an impermeable hardpan forming a barrier to water movement between peat and ground underneath. Any surface water is maintained in a ‘perched’ position held up by the sandstone hardpan beneath the peat. The removal of surface water is unlikely to cause any changes to groundwater levels. Surface water from most of the peat areas already drains via the existing drain net work to Rangaunu harbour. The outflow to the harbour will be drainage water of same quality and characteristics as is currently discharged albeit that the flow may increase. This is unlikely to cause any changes from present conditions at the harbour which is a large water receiving body.

7.7 Archaeological Sites The archaeological report shows some sites of previous gum digging, but no significant sites. These remnants of gum digging are scattered over the general area and the individual areas do not have any special attributes.

7.8 Cultural Values Part of the land for RWHL activities is owned by Ngai Takoto. There are some small areas of significance, including a burial area on the NT site. These will be identified with the Iwi and correct protocols identified.

7.9 Ecology and Water Quality The general water quality is shown to be low pH, low DO, opaque and coloured in most of the peat areas. All of these features are expected in water in a peat bog. These qualities are not conducive to a wide range of bird, fish or animal life and that is confirmed by observation. The area adjacent to the Kaimauamau swamp is a 900 ha scientific reserve managed by DOC. This reserve could be improved as a wetland if DOC works in conjunction with the Kaimaumau owners. The water quality across all sites is similar – coloured and low pH.

7.10 Landscape and Natural Character The peat sites are also mostly flat, farmland with some rolling hills.

7.11 Groundwater The catchment for both the NT site and the other farms is defined by the geology and the underlying Aupouri aquifier. Sand dunes and sand stone ridges isolate peat basins between sand dune boundaries. Sand stone layers cause perched water tables and also confine the aquifer (confine ground water below the sandstone)

7.12 Ecological

7.13 Dust Some dust will be generated on the different sites with the air drying of peat. This will be minimal since the peat is used with a moisture content of 35%. With a prevailing South Westerly wind the little dust will blow onto neighbours from most sites. Dust from transport of peat is not considered significant as the peat is transported wet to the site and water sprayed prior to return back to the excavation site.

7.14 Fire Prevention Fire is a known hazard with peat. The mining plan covers the fire plan and the plant will operate as a solvent regulated operation. All equipment will be specified with spark reduction safeguards. The operating plant has separation distance requirements for solvent storage and electrical operating switches. There will be no fires on site. The settling ponds from the plant will serve as the fire fighting water and appropriate pumps will be installed.

7.15 Processing Plant Related Effects The process plant is described in Section 4 of this document and in the Beca process operations report. The plant is an industrial process with associated staff facilities. The process uses valuable solvents and these are reclaimed in the process. Limited traffic will go to and from the site and most of the

vehicle movements will be on site taking the peat to and from the excavation site. The machinery is mainly pumps and conveyors which produce a low level noise. The process plant will run 24hr while all other operations will be daylight work. Water take and discharge and air discharge are covered under the other headings.

7.16 Storage of Solvents Process solvents will be stored on site in tanks. These will be bunded to contain any spills and designed to conform to FNDC standards for storage of flammable solvents.

7.17 Geotechnical Engineering and Natural Hazards The land is a hard sand pan covered by peat. The onsite access roads are mainly along natural ridges and tracks formed from onsite sand. The process plant has spread loading and foundations will allow for the geo technical engineering. The site will be close to Norton road cover an area of 200mx300m on land previously used as the manufacture site in 1985.

7.18 Historical Site Contamination Some of the site -approximately 150ha has been disturbed by previous owners – Sovereign Trust Ltd while recovering Kauri logs. This has changed the contour of some land and changed the flow of some drains. There is no history of other site contamination.

7.19 Built Character and Visual Amenities The process plant will be set back from the road and will have little visual impact from the road or for neighbours. The staff amenities and office will be single storey and the processing plant will have a steel frame. Both will be built to building code standard. The storage tanks will be on land adjacent to the process plant. Total storage on site allows for deliveries and usage and will total 40,000L. Process energy will come from a steam boiler. The combustion products will be dispersed through a chimney built to standard dispersion model requirements.

7.20 Traffic and Parking The excavated peat will be transported to the processing plant utilizing existing farm tracks by tractor trailers. Only a small portion will utilize public roads. They will carry the peat to the central drying pad adjacent to the plant and return the spent peat back for re-filling the excavated area. Some of the sites have farm tracks tracks already in place to transport excavated peat e.g Honey Tree Farm and Petricevich Farm. The transport of peat to the plant at Kaimaumau and return of peat for re-instatement is included in the RWHL Extraction plan appended to this document.

7.21 Other Traffic and Parking Cars for the 16 shift workers on the plant will come and go through the 24 hr shift cycle. The 30 day workers will have access to the plant and will need car parking. Stage 1 will have 15 day workers and require less parking. Service vans and trucks will be few, but will need site access. Product trucks will be about 3 per week and fuel and solvent truck will be about 3 per week. In stage 2 of process expansion the truck movements will increase by about four times.

7.22 Air Quality The main emission from the process will be combustion products from the boiler. This will be controlled to optimise heat recovery and a small chimney erected to disperse the combustion products. Other air emissions will be fugitive solvent escapes at low level. All solvents will be collected and returned to the process as they are valuable and affect process costs if they escape.

7.23 Discharges to Ground All waste water will be drained to settling ponds before discharge into current drains. All sewerage products will be collected in septic tanks and emptied on a regular basis.

7.24 Noise and Vibration The process plant noise is the hum of motors and pumps. There are no loud noises associated with the plant. The noise will be within the boundary noise conditions. The truck and on site movement of peat will be day work and within the day time noise requirements.

7.25 Lighting The process plant will be lit for night operation. This will low level and local lighting for operators. It will not affect neighbouring sites.

7.26 Fire Prevention Peat is a fuel and will maintain a fire. All activities on site will minimise fire risk, as pointed out in the Extraction and Production report. No open fires will be allowed on site and water in drainage ponds will be accessible to quell any accidental fires.

7.27 Economic and Social The area surrounding Kaimaumau is rural and is used for agrarian and horticultural growing. Housing density is low. The machinery that will be used for peat extraction is familiar to neighbours and used by them during the year. The process machinery is new and will give the opportunity for locals to learn new skills and will create up to 50 jobs in the area. Most of the product will be exported and earn approximately $60m/yr in exports. The total effect for Northland is significant from this new development and carries on the interest created by the pilot plant which is operating at Awanui.

8 SUMMARY

RWHL is proposing the development of at Kaimaumau to extract and process Kauri peat for recovery of natural waxes and resin. The RWHL operations include extraction of Kauri peat, processing of extracted peat to recover natural waxes and resin in purpose built processing plant and reinstatement of the spent peat post processing for rehabilitation of the extraction land.

The Kauri peat will be excavated from a number of farmlands in Far North in the general Kaimaumau and Sweetwater areas. Peat deposits are widely spread in the region. The process plant will be sited at the Ngai Takoto property at Kaimaumau.

The RWHL operations will be developed in stages with activity expanded to suit market demand. Initially the peat extraction will be from 5 ha/year of identified peat deposit with product output of 2100t/year rising to 25 ha/year and 8,500 t/year of product.

RWHL is seeking resource consent from NRC and FNDC for the planned activities to implement the project. This includes land disturbance and vegetation clearance, drainage, and discharge from the processing plant -air, stormwater and wastewater.

The potential effects of the proposal in respect to vegetation clearance, earthworks ( extraction and re-instatement, water abstraction and drainage, landscape, noise, hazardous substances, traffic etc are less than minor and little or no adverse impact on the environment is expected. Drainage and recovering of peat areas is widely prevalent in the district as owners have reclaimed land for productive purposes. Any adverse impact from RWHL activity can be appropriately managed, remedied or mitigated through consent conditions. The target peat deposit sites are in primary production or being re-purposed for development for horticulture and other use. Surface water from these sites, at present, is already draining in natural course through the existing drain network. The effect of modifying these drains for peat extraction will be minimal. The RWHL activity will only enhance the usage and environmental aspects of these sites.

RWHL has consulted with potentially affected parties including the Department of Conservation and Forest and Bird Society regarding the Project and that consultation will continue throughout the construction and implementation stages.

The project has clear positive effects on the economic, social, environmental and cultural wellbeing of people and communities through its contribution to the local economy and the provision of local jobs and other opportunities to Far North including housing activity for construction and permanent labour.

Overall, the proposal is consistent with the purpose and main principles of the RMA i.e. a. To create economic development by creating a business with export sales of $60m per year. b. Provide jobs for 60 people in Northland. Many employees will local people and training will be given to upskill operators. c. To protect and enhance the environment by reducing exotic weeds, providing productive land and enhancing the identified wetland at Kaimaumau. d. To improve Iwi assets and provide job opportunities. The jobs will give an opportunity for housing expansion in the Kaimaumau vicinity.

Consent No.: ...... Earthworks (Minor Effects) – AEE 6

Part B

Assessment of

Whangārei Office Phone: 09 470 1200 Environmental Effects – Fax: 09 470 1202 Kaitāia Office Phone: 09 408 6600 Waipapa Office Phone: 09 470 1200 Ōpua Office Phone: 09 402 7516 Dargaville Office Phone: 09 439 3300 Free Phone 0800 002 004 Earthworks Email [email protected] (Minor Effects) Website www.nrc.govt.nz

This application is made under section 88/section To: Consents Department 127 of the Resource Management Act 1991 Northland Regional Council Private Bag 9021 Whangārei Mail Centre Whangārei 0148

PART B – ASSESSMENT OF ENVIRONMENTAL EFFECTS Your application must include an Assessment of Effects on the Environment. This form is a guide to help you prepare it. An assessment of effects is required so that you and others can understand what happens to the environment when you undertake earthworks (i.e. building site works, roading and tracking, quarrying and mining). This will help you to propose ways to minimise those effects to the council’s satisfaction. The degree of detail required is in proportion to the scale of the environmental effects of your proposal. If the size of your proposed activity or the scale of its potential effects is significant, a report by a professional advisor in support of your application may be required. Please note that the word “environment” includes the surrounding coastal water, adjoining land, any surrounding resource users, and local iwi. The diversion and discharge of stormwater runoff from earthworks activities may also require permits from the council. It is advised that you make an appointment with an appropriate council officer to discuss your application prior to lodging it. This will help you supply all the required information at the onset and ensure the efficient processing of your application.

A. Description of the Proposed Activity

A.1 Describe the type of earthworks you propose to carry out. (use an additional sheet if required) The area to be harvested will be cleared of scrub and drained. The excavation will be carried out utilising large face shovels working from the floor of the sand base. Peat as excavated from the field will be hauled to and dumped on a Grizzley sieve . Stumps and large wood pieces will be mechanically raked off and passed through a Chipper . The roughly screened pit will be transported to concrete drying pads. These drying pads will provide surge capacity between peat digging and the processing plant which will operate 24 hours a day seven days a week. Screened peat will be reclaimed from the drying pads and delivered to the Damp Peat Storage. This will be a covered area where further drying takes place out of the rain. The air dried peat at ~35% moisture will then be fed to the feed preparation plant. This operation will be carried out by the harvesting crew in daylight six days per week and as required by the processing plant. (see attached page 1)

ASSESSMENT OF ENVIRONMENTAL EFFECTS AEE6 MAY 2018 (REVISION 6) Earthworks (Minor Effects) – AEE 6

A.2 How will the work be carried out (i.e. what machinery will be used)? A hydraulic backhoe will operate from top of the peat.Larger pieces of timber are selectively removed and the backhoe loads peat and smaller timber onto a disc screen. Rotating discs on this propel timber over the end of disc screen while comminuting the peat which drops between the disc shafts. The peat falls onto a conveyor which lifts it to discharge into the haul vehicle.

A.3 Who will be undertaking the work? The work will be done by local contractors. The area has a number of experienced crews in draining and excavating peat as farms have been developed and land brought to productive use

A.4 What date do you propose to start the earthworks? End of 2021

A.5 When do you expect to complete the earthworks? The earthworks will be on-going throughout the life of the operation (25 years+)

A.6 Will the work be carried out in stages? No Yes, describe each stage and indicate the number of weeks required for the completion of each stage. The staging is dependent on the expansion of the process plant and when new peat deposits are accessed. Initially in the early years peat will be sourced from farms in the Kaimaumau area starting with the Honey Tree and Petricevich farms. Expansion of the plant to full capacity will require securing peat from Sweetwater farms with Ngai Takoto Sweetwater farm providing a base load operation in that area. Other farms are likely to come on board once operation starts and will be assessed for inclusion.Stg1- Kaimaumau Stg2-Sweetwater Stg3-New Farms

A.7 What is the approximate volume of the proposed 140Km3 in year1 cubic metres earthworks? rising to 900 Km3 as plant is expanded to full capacity

A.8 What is the approximate area that the earthworks will affect? Initially extraction will square metres be limited to 5 ha/yr which will rise 25 ha/yr as the plant is expanded to full capacity

A.9 Describe any cut or fill batters, or both (include height of batter, depth of excavation or fill, slope of batter and extent) The peat seams are generally 3.0m deep with some 4.0m peat depth areas. The excavation area will be filled with the spent peat returned post processing mixed together with the vegetation removed to access the peat and top soil to contour the land. Supplement materials such as lime or other nutrients may be used during refilling to improve soil conditions for plant growth.

ASSESSMENT OF ENVIRONMENTAL EFFECTS 3 AEE6 MAY 2018 (REVISION 6) Earthworks (Minor Effects) – AEE 6 A.10 Will you be stockpiling any material? No Yes, describe the dimension, location and duration of stockpiles. The size of the stockpiles will be dependent on the feed requirement of the processing plant. It is envisaged that due to the wet weather during the winter months it will be difficult to excavate the peat and air dry it for processing. Stockpiles will be needed to cover this period as the process plant will be a 24/7 operation. Details will be provided in the Mine Management plan.

4 ASSESSMENT OF ENVIRONMENTAL EFFECTS AEE6 MAY 2018 (REVISION 6) Earthworks (Minor Effects) – AEE 6

If your proposed earthworks are associated with a minor quarrying or mining operation, provide the following details in A.11 to A.14, otherwise go to Section B – Site Details.

A.11 What is the volume of overburden to be removed annually? The overburden m³/year (vegetation) is generally 1.5 to 2 feet. For the first year it is expected to be 23 Km3 rising to 121Km3 at full capacity

A.12 How much of this material is to be retained within the quarry area? All of removed m³ vegetation will be retained and used for reinstatement of the excavation area

A.13 If overburden is to be removed from the site, please provide details of the likely placement of this material (e.g. sold offsite or spread on paddocks etc). Not Applicable

A.14 What is the estimated maximum volume of rock to be extracted per This will depend m³/year year? on plant capacity and the % wax and resin in peat. Initially it will be 120Km3/yr rising to 540Km3/yr at full plant capacity

B. Site Details

B.1 You must attach a map that shows the following: the location of the proposed earthworks showing any face heights and bench widths, access roads and tracks the legal boundaries of the property and the proposed separation distance from the proposed activity the location of any springs, wetlands and surface water resources (including coastal water) within 500 metres of the proposed earthworks

ASSESSMENT OF ENVIRONMENTAL EFFECTS 5 AEE6 MAY 2018 (REVISION 6) Earthworks (Minor Effects) – AEE 6 B.2 You must attach a detailed plan of the proposed earthworks which shows the: location and dimensions of any cut and fill areas location and dimensions of any proposed overburden dump site(s) location and dimensions of proposed sediment detention ponds, plus any other sediment control works (e.g. diversion drains) an indication of the proposed overland flow pathways of any surface runoff from all working areas areas of instability and areas affected by flooding

B.3 What is the topography of the area (e.g. flat, rolling or steep)? Flat to rolling

6 ASSESSMENT OF ENVIRONMENTAL EFFECTS AEE6 MAY 2018 (REVISION 6) Earthworks (Minor Effects) – AEE 6

B.4 What is the soil/rock type?

B.5 What type of vegetation currently covers the site? Wattle, Gorse and grass

B.6 Is the proposed site of the earthworks located in an area that is likely to flood (i.e. within a floodplain)? Yes No

B.7 What is the approximate catchment area draining onto or through the proposed earthworks site? m²

B.8 Is there a watercourse or wetland within 200 metres of the site? No, go to Section C – Assessment of Effects. Yes, provide details on the following.

What is the approximate distance of the watercourse(s) or wetlands from the site of the earthworks activity? metres What is the name of the watercourse(s), or the name of the stream into which it flows?

Does this watercourse flow for most of the year? Yes No

ASSESSMENT OF ENVIRONMENTAL EFFECTS 7 AEE6 MAY 2018 (REVISION 6) Earthworks (Minor Effects) – AEE 6

C. Assessment of Effects on the Environment

An assessment of effects should be proportional to the scale and significance of the proposed activity. Where the proposed earthworks could have an adverse effect on the environment, a detailed environmental assessment is required.

C.1 Affected Parties Will the proposed earthworks have an effect on any other people in the surrounding area e.g. land movements on adjacent properties, silt affecting downstream water users, or dust blowing onto other properties? No, why not? The areas for peat extraction are well away from neighbours and in farming areas.

Yes, provide details of the affected people/parties and how the proposed activity may affect them.

If written approvals are obtained from all parties that may be affected by the earthworks, and the effects of your proposed earthworks are minor, then the council is likely to process your application without public notification. If written approval cannot be obtained, suggest ways to reduce the effect on neighbours (mitigation measures).

C.2 Consultation If written approvals are obtained from all parties that may be affected by the earthworks and the effects of the proposed works are minor, then the council is likely to process your application without public notification. Written approvals regarding your proposal are normally required from the adjoining land owners/occupiers and others who may be affected by your works. Please see attached explanatory notes for details of who needs to be consulted. The council can supply you with written approval forms to aid you with the consultation. Have you consulted with any of the following potentially affected parties: Yes No Neighbours Other nearby people who may be affected Department of Conservation (if relevant) Fish and Game Council (if relevant) Local iwi (specify): Ngai Takoto Other (specify): Neighbours Any letters of concern/support or comment from persons consulted should be attached to this application form.

8 ASSESSMENT OF ENVIRONMENTAL EFFECTS AEE6 MAY 2018 (REVISION 6) Earthworks (Minor Effects) – AEE 6

C.3 Effects on Nearby Waterways Please ensure that all waterbodies (springs, streams, lakes and rivers) and/or wetlands within 200 metres of your proposed earthworks are shown on the location map. Measure accurately the distance between your proposed earthworks site and any waterbodies and show the distances on the map.

Are there any of the following in the waterbodies in the vicinity of the proposed earthworks activity? Present Yes No Obvious signs or known aquatic biota (e.g. eels, other fish, insects, aquatic plants)? Areas where food is gathered (e.g. watercress, eels, wildfowl) Waste discharges (e.g. dairy sheds, industrial, treatment plants) Recreational activities (e.g. swimming, fishing, canoeing) Areas of special aesthetic value (e.g. waterfalls) Areas of significance to iwi If you have answered Yes to any of the above, describe what effect the proposed earthworks may have and the steps you propose to take to minimise (i.e. mitigate) these effects (attach a separate sheet if necessary).

C.4 Effects on Land Are there any of the following in the vicinity of the proposed earthworks? Present Yes No Areas of indigenous vegetation or habitats of indigenous fauna Areas of significance to iwi Areas of slope instability If you have answered Yes to any of the above, describe what effect your proposed earthworks may have and the steps you propose to take to minimise (i.e. mitigate) these effects (attach a separate sheet if necessary):

10 ASSESSMENT OF ENVIRONMENTAL EFFECTS AEE6 MAY 2018 (REVISION 6) Earthworks (Minor Effects) – AEE 6

C.5 Are you proposing to topsoil and revegetate bare areas of land at the completion of earthworks? No Yes, propose details of the revegetation and time frames The excavated peat areas will be re-instated with wetted spent peat (peat after processing) and removed vegetation mixed with chipped branches, timber and decayed logs removed during peat extraction. The area will be dressed with topsoil and lime and other nutrients to improve pH and suitable for productive use as desired by the landowner.

C.6 Are you proposing any sediment retention or sediment control methods? No Yes, provide details of proposed control methods including dimensions Settling ponds will be used to trap sediments if warranted before water is discharged into existing District drainage network to not affect the downstream infrastructure.

C.7 Other Adverse Effects Will your earthworks have any other adverse effects on the environment (i.e. noise and dust generation)? No, why not? The peat is wet and saturated with water almost 100% moisture when it is extracted. It will be air-dried to 35% moisture on drying pads before sendint to the process plant. The fine wet peat is bound together in a cohesive state and unlikely to create dust. To minimise the effect any noise from the extraction machinery peat excavation will be done only during daylight hours five days a week monday to friday. Also most of the peat sites are remote away from any residential neighbourhoods.

Yes, how will these effects be mitigated?

C.8 Positive Effects What positive effects will the proposed earthworks have? The proposed earthworks will bring land to productive and better use with better environmental outcome than at present with waterlogging on most sites during winter months. The peat band sitting under the surface prevents water to drain out. More importantly it provides significant economic benefit to the local community in terms of new jobs and new business opportunities.The jobs will also have a positive social impact, because many fo the jobs will employ local people.

ASSESSMENT OF ENVIRONMENTAL EFFECTS 11 AEE6 MAY 2018 (REVISION 6) Earthworks (Minor Effects) – AEE 6

C.9 Alternative Earthworks Have you considered any alternative method or sites for the proposed earthworks? No Yes, provide details Initially the earthworks were proposed at the Ngai Takoto property at Kaimaumau which was a logical site for the proposed activity (proven resources, site of similar plant earlier and developed infrastructure). We have reduced the consent footprint on Kaimaumau and supplemented it with peat from farmland, which is in this consent.

C.10 Monitoring What, if any, monitoring do you propose to carry out to ensure that the proposed earthworks does not have any adverse effect on the environment? Depending on Consent Conditions specified by the Regional and District councils on grant of the consent for propsed activity and earthworks an Environmental Management Plan will be prepared and submitted to both councils prior to start of operations.

Please ensure that all of the relevant questions on this form have been answered fully.

If you have any queries relating to information requirements or wish to meet with a council consents officer, please contact the Northland Regional Council.

Northland Regional Council offices: Whangārei Office Dargaville Office Kaitāia Office Waipapa Office Ōpua Office 36 Water Street 42 Hokianga Road 192 Commerce Street Shop 9 Unit 10 Whangārei 0110 Dargaville 0310 Kaitāia 0410 12 Klinac Lane Industrial Marine Park Phone: 09 470 1200 Waipapa 0295 Ōpua 0200 or 0800 002 004 Phone: 09 439 3300 Phone: 09 408 6600 Phone: 09 470 1200 Phone: 09 402 7516 Fax: 09 470 1202 or 0800 002 004 [email protected] Fax: 09 470 1202 www.nrc.govt.nz

12 ASSESSMENT OF ENVIRONMENTAL EFFECTS AEE6 MAY 2018 (REVISION 6)

AEE Earthworks (Minor Effects)

Notes to Application

A.1 The peat resource is generally deposited in a series of basins separated by low sand ridges. The peat is typically cohesive and black and intermixed with sticks and timber. The Kauri resin (gum) occurs sometimes in pockets in the peat but with small pieces throughout. The occurrence is random. The waxes in the deposit come from Kauri tree leaves and are disseminated throughout the peat. The percentage of extractable material is generally about 8% of dry weight of peat. Interspersed in the peat is timber having dimensions greater than 300 mm. These could constitute 10-15% of peat deposit. This is a factor to be considered in extraction of peat. Part of this timber is large stumps and partially decayed logs. An important factor in the excavation is that the peat overlies a firm sand basement. This base provides a firm bearing surface for equipment to operate on. The surface undulates with some hollows dropping below drained water table level. These then fill with water.

B.2 A detailed peat extraction plan will be submitted to council for approval prior to commencement of any peat excavation operation.

10 September 2019

John Cunningham FIChemE, FIPENZ, BE, ME, Dip BIA, CENG, CScI

Director

RWHL

Proposed Peat Extraction Management Plan

This report has been prepared for extraction of Kauri peat from a number of farmland properties at Kaimaumau and Sweetwater in the Far North including the Ngai Takoto (NT) property at Sweetwater. The extracted peat will be processed in a purpose built plant to recover resin and wax products contained in the Kauri peat. The process plant will be sited at the Ngai Takoto property at Kaimaumau. The peat extraction areas are all in close proximity to the process plant. The spent peat will be returned to the same area from where it was extracted for reinstatement.

Peat Reserves in Far North

Resin and Wax Holdings (RWHL) had commissioned Soil and Rock Consultants (S&R) to carry out a geological assessment of other potential peat deposits in close proximity to the Ngai Takoto property at Kaimaumau.

The objective of the investigation was to identify other peat reserves in Far North (on Non NT land at Kaimaumau). Specifically, it was to identify

(i) Potential suitable peat deposits of around 300+ hectares (ii) Peat deposits of 3m+ depth for economic extraction

The presence of deposits of kauri peat and gum in the area is well established. The study area was limited to within 20km of Kaimaumau extending from Pukenui in north, to Awanui in south.

S&R used a two stage evaluation to identify, categorize, delineate and assess the resource potential. First was a thorough review of all previous research and existing data relating to peat and gum lands in the area which included (i) existing geological maps and data sets (ii) Land Information New Zealand (LINZ) data sets (iii) Geological and/or geotechnical investigations (iv) Historic aerial photographs and gum-digger maps (v) Land-use & planning maps.

Following this, a number of areas were identified to potentially contain sufficient peat reserves. These zones were defined as areas up to 300 hectares (Ha) with peat thickness of 3m or more. S & R developed a geological model and overlaid LINZ and land use data sets to identify and rank potential areas.

Application of the geological model showed that the region is predominantly relic dune deposits with interspersed swamp and lake areas. The geological maps and reports showed the targeted area comprised “Unconsolidated to poorly consolidated sand, mud, peat and shell deposits of estuarine, lacustrine, swamp, alluvial, and colluvial origin” (GNS Science, 1996). Peat formation had occurred through establishment of kauri forest within low lying areas of older fore dunes during a period of

low sea level, with forest collapse following subsequent sea level rise leading to thick accumulation of peat in inter dune hollows.

Figure 1 show potential areas identified. These were categorized in two.

Category A: Areas of Holocene sands and loams, swamp deposits, most likely containing peat. These areas vary from a few hundred to several thousand m2. The potential areas were classified by the area first and then by the possible depth of deposits.

Category B: Less likely to contain suitable peat and the gum

The second stage of the study comprised fieldwork (Intrusive Assessment) to determine depth of potential peat reserves and economic viability of peat deposits (determined through laboratory assay).

To assess the above a number of test pits were excavated. Geological/geotechnical logging was completed on all test pits and bulk samples collected. Trenches previously excavated for other purposes provided additional visible and accessible locations for evaluation.

Fieldwork was carried out in two areas ([1] Elbury Holdings – Kings Block, [2] Petricevich Farm & Radojkovich Farm). An additional walkover assessment was carried out of an existing agricultural drain (i.e. exposed peat long-section) across a third area (Honey Tree Farms) located to the east of Petricevich/Radojkovich blocks. Fieldwork included:

Mechanised test pit excavations (28 in total; up to depths of 2.3m) o Elbury Holdings (Kings Block) – 15 test pits; o Petricevich/Radojkovich Blocks – 13 test pits; Geostatistical delineation of potential peat deposit thickness; Collection of peat samples for assay- laboratory analyses Assessment of recorded peat depths was undertaken using the kriging geostatistical gridding method in Surfer v.13 (Golden Software), which provided contours of observed peat thickness. The stratigraphic model outputs were used to derive approximate volumes of mapped peats within the two investigation areas using the Grid Volume function. In summary,

Identification of peat reserves in excess of approximately 300ha: o Several peat reserves have been identified in close proximity to Kaimaumau o The area of identified Category A peat reserves varies between approximately 15ha to 250ha; Peat deposits with an anticipated depth of 3m or more: o Intrusive sampling confirmed variable thickness of peat across three blocks (Elbury, & Petricevich / Radojkovich); o Areas of peat in excess of 2m thickness likely through the shown areas.

Method of Extraction

The peat is covered by vegetation and has some windblown sand on the surface. Sand is ingrained in the peat and the peat is on a sand bed. Sand is a factor in any extraction process. The water content of the peat is high - up to 100% on a dry basis - and the extraction area will need to be drained to recover the peat.

The peat is generally approximately 3m deep .

Extraction

The peat can be recovered after draining the selected area and removing the wattle, gorse or other vegetation. The area to be extracted will depend on the throughput of the plant, but is likely to be between 5 and 25 ha per year.

The vegetation will be cleared and drains established 200m apart. These initial drains will follow any previous drains and take the water into existing drains network. Drains will be

connected every 20 to 40 m behind the operating extraction area so that the recovery will be from a rectangular area.

The peat will need to be separated from the branches and logs – likely to be a disc screen and then put on trailers and carried to the drying pad. The peat will dry to around 40% moisture in several days if left open to sun and natural wind.

After extracting the resins and waxes from the peat the remnant peat will be remixed with the branches and material from the screens and returned to the area where it was taken from.

The operation is small and the initial production unit will shift around 1200 cu.m per week rising to 5000cu.m per week as the production unit expands. The peat recovery operation will run during daylight hours and not be required on Sunday.

Drainage

Drains at 200m apart will be opened to drain the water from the peat into the existing major drains. This will reduce the water in the peat in the local area and will enable the handling of the peat. Lattice drains every 20 to 40m will connect to the main drains and form a rectangular extraction site. These drains can be blocked after the operation and allow the moisture to build up in the returned peat.

Equipment

The equipment will be a small bulldozer to remove vegetation and a 30T digger to load the peat into the disc screen and tractors and trailers to cart to the drying pad. The digger needs to handle the kauri logs and is oversized for this purpose.

Tipping trailers with tractors will take 10cu.m per load of peat to the drying pad. Two trailers and two tractors will be required to be efficient for the digger. Peat from farms further away from the extraction plant will be transported by truck and trailer to the extraction plant

A separation disc screen will be needed at the peat extraction site to separate the peat from branches and woody material. This screen will have a small hopper, a screen and a conveyor to load the trailers.

The drying pad will need a front end loader to wind row the peat and provide efficient drying. A further screen will be required after the drying pad to remove sticks and debris from the peat. The peat will go onto a conveyor to feed the operating plant. The spent peat will exit the production plant and be returned to excavation site and be remixed with the debris at the site.

Drying pads

The peat needs to be dried from the excavated 90+% moisture down to around 40% for efficient extraction of resin and wax. Previous practice shows that this is best achieved by

wind rowing and using natural wind and sun to pry the peat. The operation takes 3 to 5 days, depending on the weather. Most of the water will be evaporated by the action of sun and wind.

The drying pads will have around 2000 cu.m to 8,000 cu.m on them –a small pile of damp peat.

Fire control

Peat is a combustible product when dry and there have been fires at Kaimaumau in the past. The major fire control precautions will be:

a. The drains at the excavation site provide natural fire breaks to control any are of fire. b. All machinery will be fitted with fire suppressions systems similar to those used in coal mines. c. The dried peat will be damp at 35% and will reduce the fire danger, insitu peat has moisture contents at over 90% which will significantly reduce the potential ignition of the peat d. A strict no smoking policy will be enforced at the mine site e. For any general fires monsoon buckets will be contracted to douse any fires.

Reinstatement of land

The land will be contoured to allow the development by the land owner. This may involve land suitable for agribusiness and horticulture or other productive uses. Most of the sites are already in production or being developed. The rate of extraction is slow initially at 5 ha p.a rising to 25 ha p.a. as plant expands, but it is important to plan the outcome for the, landowner’s future plans.

Peat Extraction Plan

50.00

40.00

30.00 Hectares

20.00

10.00

0.00 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Year

Honey Tree Petricevich Oretere Jeremy White JR Jones Wayne Bratton Campbell Elbury Ngai Takoto Sweetwater

Extraction Plan Peat Hectares Years 1-25

Year Honey Petricevich Oretere JW JR W Campbell Elbury Sweetwater Total Tree White Jones Bratton NT 1 4 4 2 4 4 3 8 8 4 18 18 5 24 24 6 4 17 10 31 7 23 10 33 8 23 10 33 9 2 13 10 25 10 10 15 25 11 10 15 25 12 10 15 25 13 5 21 26 14 5 21 26 15 10 15 25 16 10 15 25 17 4 23 27 18 11 15 26 19 9 17 26 20 14 15 29 21 14 15 29 22 14 15 29 23 12 15 27 24 12 15 27 25 12 15 27 Total 15 45 65 50 30 20 44 36 302 607

Earthworks Year 1-15

Wet Peat Extraction plus Wetted Peat plus Total Earthworks vegetation removed vegetation restored Removal plus Refilling (‘000 M3) (‘000 M3) (‘000 M3) Year 1 140 111 251 Year 2 140 111 251 Year 3 279 221 501 Year 4 641 528 1,169 Year 5 865 712 1,577 Year 6 948 793 1,740 Year 7 960 806 1,765 Year 8 960 806 1,765 Year 9 914 755 1,669

Year 10 933 771 1,705

Year 11 933 771 1,705 Year 12 933 771 1,705 Year 13 962 797 1,759 Year 14 960 796 1,756 Year 15 933 771 1,705

Transport of Peat to Processing Plant from Various sites Years 1-15

Year Peat Deposit Peat (wet) Movement via Mode No of trips Farm Track (FT)/ Mt/day Public Rd Unit X trips

1 Honey Tree 150 FT Tractor Trailer 2X10

2 Honey Tree 129 FT Tractor Trailer 2X8

3 Honey Tree 205 FT Tractor Trailer 4X6

4 Petricevich 386 FT Tractor Trailer 6X8

5 Petricevich 421 FT + Kaimaumau Tractor Trailer 4X8 Rd Truck Trailer 2X4

6 Petricevich 452 FT + Kaimaumau Tractor Trailer 4X8 +Orotere+NT Rd Sweetwater Truck Trailer 2X5

7 Orotere+ Sweetwater 457 FT + Kaimaumau Truck Trailer 4X6 Rd

8 Orotere+ Sweetwater 457 FT + Kaimaumau Truck Trailer 4X6 Road

9 JWhite+ Sweetwater 578 Kaimaumau Rd Truck Trailer 4X8

10 JWhite+ Sweetwater 681 Kaimaumau Rd Truck Trailer 4X9

11 JWhite+ Sweetwater 474 Kaimaumau Rd Truck Trailer 4X6

12 JWhite+ Sweetwater 525 Kaimaumau Rd Truck Trailer 4X7

13 JWhite+ Sweetwater 627 Kaimaumau Rd Truck trailer 4X8

14 JJones+ Sweetwater 627 Kaimaumau Rd Truck trailer 4X8

15 JJones+ Sweetwater 627 Kaimaumau Rd Truck trailer 4X8

Geological Assessment - Peat Resources SH1 Waiharara (Pukenui to Awanui), Far North District Job No. NL18020 | Dated: 2 April 2019 Job Ref: NL18020 2 April 2019 (Draft – E) Page 2

GEOLOGICAL ASSESSMENT OF POTENTIAL PEAT RESOURCE AREAS STATE HIGHWAY 1 WAIHARARA (PUKENUI TO AWANUI), FAR NORTH DISTRICT

Job Number: NL18020

Name of Project: Geological Assessment – Peat Resources

Client: Resin & Wax Holdings Ltd

Lauren Coup, BSc (Earth Science) Primary Author: Junior Engineering Geologist

Sean Berry, MSc (Geology) Co-Author / Reviewer: Hydrogeologist / Engineering Geologist

Zeljko Viljevac, MSc (Geology) Authoriser: Senior Hydrogeologist / Engineering Geologist

Document Version: DRAFT – Version E

Printed: 2 April 2019

Author Signature:

Reviewer Signature:

Authoriser Signature:

Distribution List Version Quantity Issued to Date DRAFT – E PDF Resin & Wax Holdings Ltd 2 April 2019 DRAFT – E PDF + file hardcopy Soil & Rock Consultants (file copy) 2 April 2019

COPYRIGHT: The information presented in this document is the property of Soil & Rock Consultants. Use or copying of this document in whole or in part without the previous permission of Soil & Rock Consultants imply a breach of copyright.

Desktop Geological Assessment - Peat Resources (DRAFT) SH1 Waiharara (Pukenui to Awanui), Far North District Job Ref: NL18020 2 April 2019 (Draft – E) Page 3

Contents

1. Introduction ...... 4 1.1. Project Brief & Scope of Work ...... 4 1.2. Limitations ...... 5

PART A: DESKTOP ASSESSMENT ...... 6 2. Site Description ...... 6 3. Project Background ...... 6 4. Geological Background ...... 6 4.1. Detailed Geology ...... 10 4.2. Targetable Material ...... 12 5. Other information ...... 12 5.1. Christie & Barker (2007) ...... 13 5.2. NIWA (2017) ...... 13 6. Data & Assessment ...... 14 7. Resource Potential ...... 15 7.1 Resource Depth ...... 17 7.2 Field Investigation ...... 17

PART B: INTRUSIVE ASSESSMENT ...... 18 8. Preliminary Intrusive Assessment ...... 18 8.1 Elbury Holdings ...... 19 8.2 Petricevich / Radojkovich Blocks ...... 20 8.3 Honey Tree Drain Walkover ...... 21 9. Stratigraphic Assessment ...... 22 9.1 ELB Stratigraphic Model ...... 22 9.2 PET Stratigraphic Model ...... 23 9.3 Peat Volumes ...... 25 9.4 Laboratory Test Results ...... 26 9.5 Conclusions ...... 26 10. References ...... 27

Appendices Appendix A: Drawings Appendix B: Testpit Logs

Desktop Geological Assessment - Peat Resources (DRAFT) SH1 Waiharara (Pukenui to Awanui), Far North District Job Ref: NL18020 2 April 2019 (Draft – E) Page 4

1. Introduction

In response to a request from John Cunningham and Narendra Deva from Resin & Wax Holdings Ltd (RHWL; The Client), Soil & Rock Consultants (S&RC) have undertaken a Geological Assessment of potential peat resource areas between Pukenui and Awanui, in the Far North District of New Zealand.

The specific objective of this project was established following a Scoping Meeting and additional correspondence with the client. A broad area of interest was outlined with preference of selected areas in closer proximity to the current Kaimaumau Peatlands Project, as this is intended to be an expansion of current consented operation.

By locating, combining and analysing numerous data sets and integrating past research, a number of areas have been determined to potentially contain sufficient peat reserves and are highlighted for further investigation by the client. As proposed, these zones were defined as areas up to 300 hectares (Ha) with anticipated peat thickness of 3m or more.

Land Information New Zealand (LINZ) data sets were combined with layers detailing protected areas, swamp, river and lakes within the specified area. Additionally geological and soil maps were incorporated with previous investigations and gum digging operations in the region reviewed in order to establish viable locations for additional investigation.

1.1. Project Brief & Scope of Work

The Scope of Work as discussed with the client is to identify three (3) or more potential peat reserve areas, of approximately 300 hectares (ha) or more each, with an anticipated peat thickness of 3m or more, for further investigation and ground-truthing.

As such, the scope of work has been undertaken in two phases: Phase 1 (Report Part A / Sections 2 to 7) is restricted to a desktop assessment based on primarily publicly available information, including: • Existing geological maps and data sets; • Land Information New Zealand (LINZ) data sets; • Geological and/or geotechnical investigations; • Historic aerial photographs; • Historic gum-digger maps;

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• Land-use & planning maps (re: accessible land areas).

Phase 2 (Report Part B / Sections 8 & 9) comprises intrusive assessment across two (2) areas of interest: • Mechanised test pit excavations (28 in total; Report Section 8) up to depths of 2.3m below present ground level (bpgl); o Elbury Holdings (Kings Block) – 15 test pits; o Petricevich/Radojkovich Blocks – 13 test pits; • Geostatistical delineation (Report Section 9) of potential peat deposit thickness; • Collection of peat samples on behalf of the client for assay/grade laboratory analyses (Report Section 9.4)

To assess, and provide recommendations on the above, the following scope of works has been undertaken: • Obtain & compile relevant known data sets; • Research & obtain additional (e.g. historic) information; • Develop a pseudo-regional geological model & overlay with LINZ and land-use data sets; • Identify & rank potential areas meeting client criteria for further investigation; • Undertake limited high-level/preliminary intrusive fieldwork and assessment of potential peat resource thickness / volume within the identified areas; • Preparation of reporting & client briefing on findings.

1.2. Limitations

This report has been prepared for the sole benefit of our Client, Resin & Wax Holdings Ltd with respect to the particular brief given to us. This report is to be used by our Client, or the Client’s appointed Consultants, and may be relied upon by territorial authorities where required, however has not been prepared in support of any Resource Consent.. The data and/or opinions contained in this report may not be used in other contexts or for any other purpose without our prior review and agreement.

The recommendations given in this report are based on a desktop assessment and a limited intrusive of site data from discrete locations. Inferences about the subsoil conditions have been made, but cannot be guaranteed. We have inferred a geological model that has been applied for our assessment, however variations in ground conditions from those described in this report could exist across the site. Should conditions encountered differ to those outlined in this report we ask that we be given the opportunity to review the continued applicability of our recommendations.

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PART A: DESKTOP ASSESSMENT 2. Site Description The area evaluated in this desktop study is located in the Far North District, centred on the clients existing project area in Kaimaumau, and extends from Pukenui in the north, to Awanui as the southernmost boundary. The study area boundaries are more-or-less within 20km of the Kaimaumau, as shown in Figure 1 (over page). A number of conservation and scientific reserves are located within the study, primarily to the north and east of Kaimaumau, and west of Awanui, in addition to minor areas around some watercourses.

Generally, the study area is comprised of elevated dunes predominantly utilised as forestry land along the western part of the study area, and undulating sections of farmland across predominantly alluvial ground along the eastern side. Low lying swamp areas are relatively unutilised as the soft ground impedes access and are typically too wet to support crops in the absence of significant drainage.

3. Project Background

Previous desktop and field investigation work has been undertaken within the Kaimaumau Peatlands Project area (reference 16325) in order to establish viability of re-establishing extraction and processing undertakings which were halted in 1987. This was confined to a particular section of the current study area, however it provided ample relevant information relating to the entire area as well as a number of valuable literary resources. Due to the hydrological aspects of this preceding work, a large area surrounding the Kaimaumau Peatlands was also assessed.

Many years prior to this reestablishment of peat extraction and processing there was historic investigative work done on this area in relation to both the extraction of peat and kauri gum, as such the soils in the area were assessed in relation to their preservation qualities and composition.

4. Geological Background

Reference to available current geological maps (https://data.gns.cri.nz/geology/; 1:250k series Geological Map 1 – Kaitaia, GNS Science, 1996) shows that the region is predominantly relic dune deposits with interspersed swamp and lake areas. While there is some variation in the dunes due to their deposition, of particular significance to this project are depositional areas between the sand ridgelines that have been infilled by organic materials, specifically kauri deposits. Sections in closer proximity to swamp areas have shown a higher prevalence of these deposits in respect to both area and depth.

Desktop Geological Assessment - Peat Resources (DRAFT) SH1 Waiharara (Pukenui to Awanui), Far North District Job Ref: NL18020 2 April 2019 (Draft – E) Page 7

Figure 1: Desktop Assessment Area

(Data Sources: LINZ Topo50 & Data Service)

As detailed on the GNS website, variation in lithology can be attributed to proximity to the coast, as the majority of the Holocene sand deposits are deposited through Aeolian processes. An overview of regional geology is shown in Figure 2.

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Figure 2: Regional Geology (GNS Science, 1:250k series)

Pukenui N

Kaimaumau Early Pleistocene Parabolic dunes & inter-dune peats

Holocene dunes

Awanui

Late Pleistocene to Holocene alluvial plains

(Data Sources: http://data.gns.cri.nz/geology/; Open Street Map overlay)

In relation to identifying similar material as that current proposed for extraction at the clients Kaimaumau operations, further reference has been made to previous reporting by S&RC (Ref. 16325, AEE Proposed Peat Extraction - Norton Rd, Kaimaumau, Rev. C dated 18 August 2017) in relation to identified geological strata deemed desirable in that area. Local geological units previously identified as being economically viable material at Kaimaumau are within lithologic codes eQd and Q1a, as shown in Figure 3.

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Figure 3: Kaimaumau Geology (GNS Science, 1:250k series)

Lithologic Codes Tauranga Group Q1a - Unconsolidated sand, mud & peat Kariotahi Group Q1dM - Loose sand (mobile dunes) Q1dF - Loose sand (coastal foredunes) Q1dP - Sand (fixed parabolic dunes) N eQd - Poorly cemented coastal foredunes & clay rich sand soils Q1dM Q1dF

Q1dP

eQd

Q1dF eQd Q1a eQd

Approximate viable Kaimaumau area

(Data Sources: http://data.gns.cri.nz/geology/; LINZ Topo50-AU26 overlay)

With respect to the desktop phase of the current assessment area, peat soils targeted for extraction within the Kaimaumau investigation area (and their stratigraphic relation to sand ridgelines) are indicated as belonging to the Kariotahi Group. However, with respect to the local geology shown in Figure 3, the area of proposed extraction is mapped as being unconformably overlain by Tauranga Group materials. This same stratigraphic relationship is observed elsewhere within the study area, particularly within the area directly south of Kaimaumau on the western side of the Rangaunu Harbour (i.e. south of Kaimaumau). Reference to available soil order maps of New Zealand (www.nzsoils.org.nz) indicates that the greater Kaimaumau area is underlain by both organic and podzol soil types. Organic soils are primarily comprised of decomposed wetland plants (e.g. peat). Podzol soils include accumulation of aluminium and iron oxides in association with organic matter and are typical of areas of high rainfall.

Both soil types (i.e. organic & podzol) represent potentially viable underlying peat, and are approximately correlated with the distribution of fs (and to some extent hp) geologic units described in Section 5.1 (1981, DSIR; Houhora Sheet N6).

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4.1. Detailed Geology

In order to refine potentially extraction areas with respect to the distribution of geological strata, further reference has been older geological information, as presented in Table 1. Reference to older information has been included on the basis that successive geological maps typically incorporate and synthesis existing information, often reporting at a simplified scale and/or stratigraphic separation (i.e. mapping at higher scale tends to combine “lesser” units for simplification and viewability; alternatively, revision at the same scale may combine stratigraphy into current nomenclature).

Table 1: Available Geological Maps

Date Scale Publisher Title 1953 1:235,440 (4 miles to an inch) DSIR Soil Map of New Zealand – Sheet I 1961 1:250,000 DSIR Geological Map of New Zealand – Sheet 1 (North Cape) 1979 1:100,000 DSIR NZMS 290 Sheet N 02/03 (North Cape-Houhora) 1980 1:100,000 DSIR NZMS 290 Sheet N 04/05 (Ahipara-Herekino) 1980 1:100,000 DSIR NZMS 290 Sheet O 04/05 (Kaitaia-Rawene) 1981 1:63,360 (1 mile to an inch) DSIR Geological Map of New Zealand – Sheet N6 (Houhora) Table Notes: DSIR: Department of Scientific & Industrial Research (New Zealand Geological Survey)

Of particular interest to the desktop phase of the current assessment, and in relation determine of similar deposits as encountered within the Kaimaumau extraction area, is detail provided on Sheet N6 (Houhora, DSIR 1981), as shown in Figures 4 and 5.

Figure 4: Delineation of Kaimaumau Project Geology

(Data Sources: DSIR, 1981, Geological Map of New Zealand, Sheet N6 (Houhora); LINZ Topo50-AU26)

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Figure 5: Detailed Local Geology

(Data Sources: DSIR, 1981, Geological Map of New Zealand, Sheet N6 (Houhora); LINZ Topo50-AU26)

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4.2. Targetable Material

Review of available geological maps (and associated literature) reports that currently targeted materials within the Kaimaumau project area are designated a map code Q1a (Figure 3), with a broad definition of “Unconsolidated to poorly consolidated sand, mud, peat and shell deposits of estuarine, lacustrine, swamp, alluvial, and colluvial origin” (GNS Science, 1996).

Older geological maps (DSIR, 1981) provide further refinement, and closer resolution of distribution, of units comprising the current Q1a map code. In relation to Kaimaumau deposits, areas currently identified for extraction are predominantly mapped as former map code fs, being described as Holocene “swamp deposits” of the Aranuian Stage (Hawera Series).

Further review of literature associated with the N6 Houhora map sheet (Hay, R.F. 1981: Sheet N6 Houhora [1st Ed.], Geological Map of New Zealand, notes [24 p.], DSIR) reports additional information in relation to potential gum/resin bearing strata, detailed as follows.

Formation Historic establishment of kauri forest within low lying areas (deeply dissected streams) of older foredunes during a period of low sea level, with forest collapse following subsequent sea level rise leading to thick accumulation of peat (map code hp – interdunal flat and lake deposits) in interdune hollows. Further formation of interdunal swamps, and accumulation of peat deposits (fs) has occurred in association with deposition of younger foredunes during the same period of sea level rise.

Kauri Gum or Resin The presence of deposits of kauri gum and/or resin bearing peat strata across the area is historically well established, and specific reference is made to the clients current Kaimaumau area. Further reference is made to a potential operation within “Pannikin Flat … approximately 1.6km west of Houhora”, however neither exact location nor projected extracted volumes are reported.

5. Other information

In supplement to available geological information (maps and associated literature), a search of other publicly available information has found the following previous reports of relevance: • Christie & Barker, Mineral resource assessment of the Northland Region, New Zealand. GNS Science, 2007;

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• NIWA, Swamp kauri resources of Northland, prepared for Ministry of Primary Industries (MPI Technical Paper No: 2017/01), 2017.

5.1. Christie & Barker (2007)

As with geological literate, specific reference is made to the existing Kaimaumau project area (p.48; Motutangi- Kaimaumau deposit), with depths of up to 6m.

Further reference is made to “four (4) small deposits (less than 5 m thick) of peat in the Hikurangi area”, and includes a figure (Christie & Barker, 2007; Fig. 68) of “Location of known kauri gum deposits”. Information presented in the figure indicates an area of Swamp deposits and peat (Late Quaternary) that approximates the mapped distribution of geological strata coded hp and fs in the 1981 DSIR Houhora (Sheet N6) map (Section 4.1), and extending southward to the Awanui area.

5.2. NIWA (2017)

As with reporting by Christie & Barker, reference is made to the distribution and location of historic gum digging activities. Figure 6 below presents a partial reproduction of the Gumfields of New Zealand map modified from that prepared by A.W. Smith (1952, unpublished PhD thesis).

As with previous references, identified (historic) gumfields largely overlap with the mapped distribution of geological strata coded hp and fs. It is noted that gumfields map annotation for “quantities extracted – large”, is concentrated well defined around the immediate Kaimaumau area (including the current Kaimaumau project area which is still considered viable by the client.

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Figure 6: Detailed Local Geology

(Data Sources: NIWA, 2017, Swamp kauri resources of Northland (Fig. 3; reproduced in part)

6. Data & Assessment

Literary sources were utilised to provide background information on the lithology and geology of the area. Historic research combined with relatively recent work in the area produced the contextual understanding of the site. In addition to this, pre-emptive research during the fee proposal stage of this project was also reviewed and has been further developed and refined specific to the assigned area through the implementation of maps.

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A number of maps were correlated and compared with notable sections of similarities despite variation in age and level of detail.

The inclusion of data sets provided further detail, particularly by outlining protected areas which were subsequently excluded from further investigation, promoting application of resources to viable areas.

7. Resource Potential

Through the correlation of all aforementioned resources, potential areas have been highlighted as two categories. These categories are primarily based on historic stratigraphic map codes, however the potential within each unit is considered to be corroborated by both anecdotal information (previously worked gum digging areas) and supplementary geologic literature,

Category A (Sheet N6 [Houhora] Map Code fs): Areas of Holocene sands and loams, swamp deposits, most likely containing peat. The areas vary from a few hundred to several thousand m2. The potential areas were classified by the area first and then by the possible depth of deposits. Field investigation will be required to confirm economically viable deposits. The approximate distance from the existing Kaimaumau plant location varies from as little as 2 km to approximately 15km. The economics of exploitation may be assessed when the deposits are assessed for potential peat content & assayed to the specification of the client.

Category B (Sheet N6 [Houhora] Map Code hp): Less likely to contain peat and the gum, however because of very large areas it is considered worth at least a broadly investigating and confirming the findings by means of field investigation.

The mapped distributions of the Category A and Category B, across the required desktop assessment area, are presented in Drawing NL18020/1 (Appendix A). Of particular note is cluster of Category A areas located within 5km of the existing Kaimaumau project.

Figure 6 presents a portion of drawing NL18020/1. Approximate Category A areas as noted in Figure 6 are presented in Table 2.

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Figure 7: Potential Peat Resources

(Data Sources: LINZ Topo50-AU26 overlay)

Table 2: Potential Category A Peat Areas

Number Approximate Area (ha) Number Approximate Area (ha) A1 89.7 A6 62.1 A2 190.4 A7 68.6 A3 15.6 A8 34.9 A4 29.5 A9 15.0 A5 247.1 A10 23.7

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7.1 Resource Depth

As indicated by the client an average depth of 3m+ would likely be required for any identified resource area, in order to provide sufficient volume as to make individual areas commercially viable for extraction.

With references to geological literature (Section 4), peat deposits in this area are understood to have accumulated within the troughs between individual dune structures. Based on a dune slope of no less than 10˚ from horizontal (angle of repose; θ), geometric calculations (tan θ = h/b) indicate that a peat deposit of 34m width is sufficient to achieve a theoretical maximum depth of 3m.

On the basis of the above, any width greater than 34m could be assumed to have a depth of 3m+ (i.e. 50m total width - 34m = 16m width at 3m+ depth). Notwithstanding, the angle of repose of sand typically varies between 15˚ to 30˚ (<45˚ where wet), corresponding to width sufficient to achieve 3m depth of approximately 22.4m (θ=15˚) and 10.4m (θ=30˚).

Geometric simplification does not however account for potential variations in subsurface topography between dunes crest (i.e. shallow buried dunes within peat deposits), and can only be confirmed on a site-by-site basis by means of intrusive investigation.

7.2 Field Investigation

On the basis of the first phase desktop assessment (Part A) it was recommended that high level field reconnaissance (i.e. Preliminary Intrusive Assessment) be undertaken prior to mobilisation for extensive intrusive testing/sampling in relation to any detailed resource delineation.

High level field reconnaissance was recommended to comprise the following: • Excavation of testpits at nominal spacings of approximately 100m, either along transects aligned perpendicular to the peat deposit (i.e. extending between confining dune crests), or across staggered grid; • Spacing of transect lines at no more than 500m; • Excavation and geological/geotechnical logging of testpits to the base of the peat deposit (inclusion of collection of samples for assay analyses where required by the client to confirm economic viability);

S&RC considered that a minimum of one (1) day of investigation would be required to undertake a high level intrusive assessment of any individual areas of primary interest (depending on area size, ease of site access, weather conditions, available equipment etc).

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PART B: INTRUSIVE ASSESSMENT

8. Preliminary Intrusive Assessment

Following completion of the desktop information review, and after discussion with the client, further investigation (Preliminary Intrusive Assessment) has been undertaken by Soil & Rock Consultants in January 2019, for two areas identified by the client as satisfying resource potential, site accessibility, and proximity to the proposed process facility for the wider project area. The primary objectives of the Preliminary Intrusive Assessment have been to provide clarification with respect to the following: • Depth of potential peat reserves and their presence along a transect; • Evaluating the geometry of dune structures; • Overall depth of interdune/ alluvial deposits; • Composition and economic viability of peat deposits (to be determined through laboratory testing).

In order to assess the above attributes a number of test pits have been excavated. Geological/geotechnical logging has been completed on all test pits and bulk samples collected. Trenches previously excavated for other purposes provided additional visible and accessible locations for evaluation

Fieldwork was primarily in relation to the two areas ([1] Elbury Holdings – Kings Block, [2] Petricevich Farm & Radojkovich Farm) presented in Table 3 below, and as shown in Figure 8. An additional walkover assessment was carried out of an existing agricultural drain (i.e. exposed peat long-section) across a third area (Honey Tree Farms) located to the east of the Petricevich/Radojkovich blocks.

Table 3: Investigation Areas – January 2019

Title Area Site Area GPS Site Name Legal Title Hectares (ha) ID

Lot 1 and Lot 4 DP 22761 192.3433 [1] Elbury Holdings 199.6072 ELB Lot 2 DP 13971 7.2639 [2a] Petricevich Lot 2 DP 365143 and Section 18, 33, 40 Block IV 72.8336 Block Opoe Survey District 119.1802 PET [2b] Radojkovich Fee Simple, 1/1, Lot 1 and Lot 3 Deposited Plan 46.3466 Block 40152

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Figure 8: Investigation Areas – January 2019

(Data Sources: LINZ Data Service; https://data.linz.govt.nz/)

Intrusive field investigation was carried out on the 22nd (Petricevich/Radojkovich Blocks) and 23rd (Elbury) of January 2019, and involved a total of 28 test pits up to depths of 2.3m below present ground level (bpgl). Summaries of investigation across each area are presented in the following sections. Geological test pit logs are presented in Appendix B.

8.1 Elbury Holdings

The investigative work on the 23rd of January 2019 was undertaken across the Elbury Holdings (Kings) block. Excavation and analysis has been completed in 15 locations to a maximum depth of 2.0m. Observed peat

Desktop Geological Assessment - Peat Resources (DRAFT) SH1 Waiharara (Pukenui to Awanui), Far North District Job Ref: NL18020 2 April 2019 (Draft – E) Page 20 thickness ranged from 0.0m to greater 2.0m, and exceeded the test pit depth in 5 locations. Alluvial thickness ranged from 0.4m to 1.9m. A summary of recorded alluvium depths and peat thicknesses is presented in Table 4.

Table 4: Elbury Holdings Investigation Summary

Easting Northing Test Pit Depth Alluvial Depth Peat Thickness Location NZTM (m) ELB-02A 1619746 6133757 0.8 0.2 - 0.8 0.4 ELB-03 1619871 6133476 1.0 0.0 - 1.0 0.7 ELB-03A 1619859 6133440 1.0 0.0 - 1.0 0.7 ELB-04 1620050 6133304 0.6 0.2 - 0.6 0.0 ELB-05 1620229 6133126 1.0 0.3 - 1.0 0.0 ELB-05A 1620200 6133113 1.2 0.1 - 1.2 0.9 ELB-06A 1619625 6133339 2.0 0.15 - 2.0 0.85 ELB-07 1620048 6133646 1.3 0.1 - 1.3 0.7 ELB-08 1620218 6133477 1.6 0.2 - 1.6 > 1.4 (1) ELB-09 1620396 6133299 1.0 0.1 - 1.0 > 0.9 (1) ELB-10A 1620382 6133036 1.0 0.1 - 1.0 0.6 ELB-10B 1620434 6133044 1.0 0.1 - 1.0 0.5 ELB-11B 1620623 6133073 1.05 0.1 - 1.05 > 0.95 (1) ELB-12 1619488 6133755 2.0 0.0 - 2.0 > 2.0 (1) ELB-13 1619541 6133502 2.0 0.0 - 2.0 > 2.0 (1) Table Note: (1) Peat deposits present at base of excavation – excavated terminated due to maximum reach of excavator

8.2 Petricevich / Radojkovich Blocks

The investigative work on the 22nd of January 2019 was undertaken across the Petricevich and Radjkovich blocks. Excavation and analysis has been completed in 13 locations to a maximum depth of 2.3m. Observed peat thickness ranged from 0.0m to greater than 2.0m, and exceeded the test pit depth in 5 locations. A summary of recorded alluvium depths and peat thicknesses is presented in Table 5.

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Table 5: Petricevich / Radojkovich Investigation Summary

Easting Northing Test Pit Depth Alluvial Depth Peat Thickness Location NZTM (m) PET-01 1617526 6135573 2.2 0.0 - 2.2 > 1.9 (1) PET-02 1617525 6135772 2.3 0.0. - 2.3 > 1.1 (1) PET-03 1617525 6135971 1.0 0.0 - 1.0 0.0 PET-05 1617725 6135774 2.0 0.25 - 2.0 1.5 PET-06 1617723 6135973 2.0 0.0 - 2.0 > 2.0 (1) PET-07A 1617644 6136172 2.0 0.0 - 2.0 > 1.6 (1) PET-08 1617925 6135976 0.8 0.0 - 0.8 0.0 PET-08A 1617863 6136007 0.6 0.0 - 0.6 0.0 PET-09 1617816 6136198 2.0 0.0 - 2.0 0.0 PET-11A 1618190 6136318 1.7 0.0 - 1.7 > 0.3 (1) PET-13 1617446 6136596 0.8 0.0 - 0.8 0.2 PET-14 1617660 6136572 1.0 0.15 - 1.0 0.3 PET-15 1617545 6136633 2.0 0.0 - 2.0 1.6

8.3 Honey Tree Drain Walkover

The Honey Tree Farms northern boundary drain has been utilised as a further information source, and has been evaluated with incremental GPS locations and photography. This has enabled correlation with the test pit observations to demonstrate the overall inter-dune peat structure (i.e. paleotography) within this region. No excavation was attempted at this location as the previous excavation provided sufficient exposure of underlying lithology.

Chart 1 presents the long-section paleotopography (i.e. peat depth) along this drainage feature.

Chart 1: Peat Depth - Honey Tree Farms Northern Boundary Drain (50x Vert. Exaggeration)

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9. Stratigraphic Assessment

Assessment of recorded peat depths has been undertaken using the kriging geostatistical gridding method in Surfer v.13 (Golden Software), which has provided contours of observed peat thickness on the basis of linear interpolation. It must be noted that presented contours (i.e. isopaches) are mathematically inferred, and actual site conditions may vary.

Interpolation is based on discrete observations (i.e. individual test pit locations), and has been projected beyond the boundaries of the investigation grid (i.e. convex hull) by way of incorporating a “zero thickness” boundary (i.e. zero thickness of alluvium/peat) along the observed/mapped extent of the inter-dune alluvial deposits.

9.1 ELB Stratigraphic Model

Contour plans derived from intrusive investigation across the Elbury Holdings area (c.f. Section 8.1) are presented in Figures 9 (Alluvial Thickness) and 10 (Peat Thickness). Project Peat thickness (Figure 10) has not been projected beyond the site boundary.

Figure 9: Elbury Holdings – Alluvial Thickness

(Data Sources: LINZ Data Service; https://data.linz.govt.nz/)

Desktop Geological Assessment - Peat Resources (DRAFT) SH1 Waiharara (Pukenui to Awanui), Far North District Job Ref: NL18020 2 April 2019 (Draft – E) Page 23

Figure 10: Elbury Holdings – Peat Thickness

(Data Sources: LINZ Data Service; https://data.linz.govt.nz/)

9.2 PET Stratigraphic Model

Contour plans derived from intrusive investigation across the Petricevich / Radojkovich area (c.f. Section 8.2) are presented in Figures 11 (Alluvial Thickness) and 12 (Peat Thickness).

As with the ELB stratigraphic model Project Peat thickness (Figure 12) has not been projected beyond the site boundary. Due to the wider topographic expression of the “inter-dune alluvial plain” (i.e. greater separation distance between relic dune ridges) and the spread of investigation locations, contours of alluvial thickness have also been restricted to within site boundaries to avoid over-projection of geological information.

Desktop Geological Assessment - Peat Resources (DRAFT) SH1 Waiharara (Pukenui to Awanui), Far North District Job Ref: NL18020 2 April 2019 (Draft – E) Page 24

Figure 11: Petricevich / Radojkovich – Alluvial Thickness

(Data Sources: LINZ Data Service; https://data.linz.govt.nz/)

Desktop Geological Assessment - Peat Resources (DRAFT) SH1 Waiharara (Pukenui to Awanui), Far North District Job Ref: NL18020 2 April 2019 (Draft – E) Page 25

Figure 12: Petricevich / Radojkovich – Peat Thickness

(Data Sources: LINZ Data Service; https://data.linz.govt.nz/)

9.3 Peat Volumes

On the basis of stratigraphic model outputs (Sections 9.1 & 9.2), the Grid Volume function has been used to derive approximate volumes of mapped peats within the two investigation areas, as presented in Table 6.

Table 6: Calculated Peat Volumes

Site Name Calculated Volume (m³) Mapped Area (ha) Average Thickness (m)

[1] Elbury 752,870 75.00 0.55 + [2] Petricevich / Radojkovich 222,402 29.92 0.75 +

Desktop Geological Assessment - Peat Resources (DRAFT) SH1 Waiharara (Pukenui to Awanui), Far North District Job Ref: NL18020 2 April 2019 (Draft – E) Page 26

With respect to volumes and average thicknesses across the ELB and PET areas presented in Table 6, it is noted that in a total 10 locations (5 at ELB, 5 at PET), the depth of peat exceeded the termination depth of the test pit. Review of available information indicates that these locations are along the centre line of inter-dune peat basins, and so consequently it is anticipated that thicker peat deposits are likely to be encountered near the centre of each area.

Inferred extents of areas where thicker peat deposits may be expected to be encountered have been approximately delineated where appropriate, and are shown as dashed lines in Figure10 and Figure 12.

9.4 Laboratory Test Results

[TBC by client]

9.5 Conclusions

On the basis of the assessment presented herein, and with respect to the brief/requirement from Resin & Wax Holdings Ltd, the following conclusions are made:

• Identification of potential peat reserves in excess of approximately 300ha: o With reference to Table, several peat reserves have been identified in close proximity to the Kaimaumau project area; o The acreage of identified Category A peat reserves varies between approximately 15ha to 250ha; o Intrusive field testing and site observations indicate that the spatial extent of inferred peat deposits varies to that shown in geological literature. Consequently, it is anticipated that some areas may exceed the inferred mapped acreages as shown in geological literature; • Peat deposits with an anticipated depth of 3m or more: o Intrusive sampling has confirmed a variable thickness of peat across three blocks (Elbury, & Petricevich / Radojkovich); o Due to constraints on available excavation equipment, field investigation test pits were limited to a maximum depth of approximately 2m, however proved peat thicknesses vary between 0.2m to greater than 2.0m, across both investigation areas; o Areas of peat in excess of 2m thickness are inferred to align through the main axis of the interdune peat deposits as shown on Figures 10 and 12. Deeper peat deposits may be anticipated through the shown areas.

Desktop Geological Assessment - Peat Resources (DRAFT) SH1 Waiharara (Pukenui to Awanui), Far North District Job Ref: NL18020 2 April 2019 (Draft – E) Page 27

10. References

Desktop Geological Assessment - Peat Resources (DRAFT) SH1 Waiharara (Pukenui to Awanui), Far North District