As Bob McLeod - precautionary principle s61(2) If, in relation to making a decision under this Act, the information available is uncertain or inadequate, the EPA must favour caution and environmental protection. S61(3) If favouring caution and environmental protection means that an activity is likely to be refused, the EPA must first consider whether taking an adaptive management approach would allow the activity to be undertaken. All risks should be covered by insurance. Private profit, social loss. General problem of lack of knowledge - https://www. niwa .co.nz/our-science/coasts/research-projects/all/physical-hazards- affecting-coastal-margins-and-the-continental-shelf/news/erosion Coastal erosion & sediment systems Rates of longshore transport are thought to be very large, but no one really knows. http://www. massey .ac.nz/~trauma/issues/2010-1/blackett.htm The Australasian Journal of Disaster and Trauma Studies Volume : 2010-1 Exploring the social context of coastal erosion management in New Zealand there is still uncertainty because of the lack of data on coastal processes Assessment of oceanographic & coastal processes 5. the South Taranaki Bight is poorly studied . there is no evidence to suggest that the proposed mining activity will increase or reduce these erosive influences 7. monitoring needs sound data to assess whether monitoring is showing adverse effects. eg Elephant Rock 7/09/2011 2/10/2013 20. Most sediment is derived from the Patea, Whenuakura, Waitotara and Whanganui Rivers, with a total yield of approximately 5,861,200 t/y - 27,000,000m3 (50m tonnes) pa over 20 years – a block over ½km cube 22. large amounts of sand move through the system. Hume et al. (2012, 2013) were unable to calculate a reliable sand budget due to uncertainties about the sources and movement of sand in the system. 44. A disconnection between the offshore areas where mining is proposed and the coast mean that mining is unlikely to cause shoreline erosion. - asserted twice (and also by Terry Hume for TTR para 57), but no evidence - if the systems are disconnected, how did so much ironsand get there from a supposed Taranaki source? - Coastal stability in the South Taranaki Bight - Phase 2 p34 An analysis by Lewis . infers that the [ironsand ridges] formation ceased about 9,000 years ago with rising sea level, when Plio-Pleistocene rock promontories around 25 km west of Wanganui began to act as natural barriers to the supply of ironsand macrofossils or carbon dating? Coastal stability in the South Taranaki Bight - Phase 2 p45 the patterns of deposition indicate that sediment of particle size similar to that on the beaches is not distributed far from the extraction site, and that the transport of sand to the shore from the extraction site (or a deficit therein) will take a lot more than 2 years. That is to say the model results suggest there is no evidence for a significant connection between seabed sand at the extraction site and sand at the shore. Use Elephant photo – 1930s sled barge uncovered 2004 Coastal stability in the South Taranaki Bight - Phase 2 2.4 The large size of the sand system and the distance offshore of the extraction means that any potential effects of extraction, while focussed inshore of the extraction site, are potentially spread over a large length of shoreline and therefore minimised. 27,000,000m3 pa x 20yrs / 100km coast (Taranaki-Kapiti) x 500m wide beach = 10.8m drop in 100km over 500m wide beach Fig 2-14 shows flood plumes moving north and west, but the text claims sand is moved the other way by wave energy – could storm events not fit average pattern? P42 Fig 4.6 shows the mining on the edge of a gyratory current – shows 2yr average not storm events Terry Hulme 53. while the analysis of the sediment budget is very useful in providing a picture of coastal processes and scale, in the South Taranaki Bight case it is of little value in predicting the effects of sand extraction on the shoreline because of uncertainties involved in the calculations of the budget terms Jt Statement on Coastal Stability 16. Though likely to be small, the pathways and magnitude of cross-shore sediment transport on inner shelf are unquantified/uncertain. EPA sediment plume model review 31. The lack of sample data coupled with the grid size used when carrying out this modelling makes it difficult to have confidence in the conclusions that have been drawn by TTR 33. Despite the lack of adequate sediment representation and the grid size used, the environmental impact risks at the work site and its surrounding areas are low and TTR does not intend to mine the areas where mud contents are high. Based on this understanding we are of the opinion that any additional sampling or model refinements are unlikely to change the outcome of the assessment. 40. sediment plumes produced by mining are likely to have dispersed considerably by the time they reach coastal waters TTR assurance that they won't work muddy areas – how to monitor and enforce? Assessment of effects on marine mammals 2. Habitat modelling of three cetacean species of conservation significance (Maui’s dolphin, killer whale and southern right whale) also predicted a low abundance of these species in the project area. 35. there is a potential for the proposed activities to reduce the area of habitat available to marine mammals. Table 2 Turbidity plumes - There is limited assessment of this potential impact in the marine consent application – [Assessment of oceanographic & coastal processes 6.] nickel within water discharged from the mining facility is likely to exceed recommended guidelines for the protection of marine organisms noise levels are also likely to deter marine mammals from coming too close to the facility Assessment of benthic ecology 56. sand ripples that occupy much of the PPA indicate a dynamic benthic environment Jt Statement benthic experts 27. Experts agreed that there is uncertainty in the rate of recovery of mined areas because an in situ recolonisation experiment proved impossible due to rough sea conditions . recovery was likely to be on the order of a decade. One other expert suggested it may take longer. - harsh environment = slow recovery? Pt 2 21. Shells from Tucetona laticostata accumulate on the surface of the seabed and provide a hard substrata for other organisms to grow on. - how long? ii The issue or difficulty with sentinel species monitoring here, is that for many of the species recorded from the region very little is known about species-specific sensitivity thresholds. precautionary principle s61(2) If, in relation to making a decision under this Act, the information available is uncertain or inadequate, the EPA must favour caution and environmental protection. EPA/TTR new - inexperienced co in pioneering field - had major impacts overseas Namibia, Kerala (India) carbon accounting - international locations 18%, submitters 442 Raglan / 2013 pop 2,736 = 16% - to be heard about 40 x 100km x 222g/km = 888kg – well over ½ a tonne - Skype / teleconference Taharoa once a month bulk tanker at mooring buoy..