methodology - evaluation of effects - epa · 2019. 4. 6. · wellbeing framework which has been...

South Taranaki Bight Iron Sand Extraction Project Trans-Tasman Resources Limited October 2013 Marine Consent Application

Impact Assessment Exclusive Economic Zone and Continental Shelf (Environmental Effects) Act 2012 203

10. METHODOLOGY - EVALUATION OF EFFECTS

Introduction

This section of the IA describes the methodology adopted herein for identifying and evaluating environmental effects attributable to TTR’s activities. The following four stage process was adopted, with each stage is briefly described in the following sections.

I. Identify potential effects II. Determine significance of each effect III. Consider mitigation measures IV. Address residual impacts

Stage I: Identify Potential Effects

All environmental effects likely to arise from both routine operations and unplanned events have been assessed in this IA in terms of the following broad categories:

Nature of Impact Duration of Impact Scale of Impact Type of Impact Negative Temporary Local Direct Positive Short-term Regional Indirect

Long-term National Cumulative.

Permanent International Trans-boundary

In all cases evaluation has been made relative to extraction across the entire project area. In some cases, such as evaluation of pit infilling and mound deflation, consideration has been given to particular scenarios (such as extraction and re-deposition at the ends of “lanes”), and plume modelling has been based on extraction at the shoreward end of the applications area and extraction at the seaward end to provide the full range of likely outcomes for predictive purposes.

Stage II: Determine Significance of each Effect

General

Following identification of all possible effects, and associated design-based mitigation measures, it is common practice in preparation of Environmental Impact Assessments to evaluate effects in terms of a risk analysis based around consideration of the likelihood of occurrence of the effect and its associated consequences. Such an approach is appropriate for effects which are variably present, such as ecological effects which can vary with distance and over time. This approach has been adopted for ecological impact assessment in relation to TTR’s Project as described below. However, this approach is not necessarily appropriate for all effects, particularly those physical and social effects which will be present continuously as a consequence of a particular activity. In that case the use of the “likelihood” construct becomes redundant and the focus for risk assessment falls on the evaluation of “consequence” alone. This IA adopts an holistic “expert opinion” perspective for such areas as set out below.

Effects on the Physical Environment

In this IA, physical effects have been addressed from the “expert opinion” perspective. In general the quantitative physical effects are used to inform evaluations in terms of seascape, natural character, visual amenity, ecology and social effects. For “end-point” physical effects (such as coastal erosion and effects on surf breaks) “expert opinion” consideration is given to assessed worst-case scenarios, with effects described in terms of their assessed , qualitative value using the following terms as appropriate:

Very minor Minor Insignificant Significant



Effects on Seascape, Natural Character and Visual Amenity

The “Seascape, Natural Character and Visual Amenity” Evaluation adopted a formal methodology based to a large extent on the Best Practice Guidelines prepared by the British Landscape Institute67.

Topic areas were discussed in terms of the nature of the proposed activity and its magnitude of effect (size/scale, duration/reversibility and cumulative effects). The sensitivity of the receiving environment was also discussed in terms of viewer characteristics and environmental conditions relative to the project and its effects.

The combination of the magnitude of the project relative to the sensitivity of the “receptors” (people and the biophysical resources) provided the basis for the significance of effects assessment, which relied on a word scale rather than a numerical scoring or the weighting of criteria. The seven point scale, developed by the New Zealand Institute of Landscape Architects68 (NZILA), was adopted as the basis for the assessment. These seven categories of significance are:

Extreme Very High High Moderate Low Very Low Negligible

Finally in order to summarise the levels of significance in a resource management context, the following four point scale was adopted, where major and moderate are representative of significant effects and minor and negligible are representative of effects which are not significant:

Major Moderate Minor Negligible

Ecological Effects

Ecological effects have been addressed on the basis of a risk assessment and management protocol adapted from “AS/NZS ISO 31000:2009 Risk Management”69, and a rationale set out in MFE (2011)70, a report prepared for the Ministry for the Environment setting out the findings of an expert risk assessment of activities in the New Zealand exclusive economic zone and extended continental shelf. The detailed approach is set out in Appendix 6 of this IA.

In summary the approach adopted involves identification of ecological effects, consideration of the consequences of activities, the likelihood of that consequence occurring and the confidence with which the conclusion is reached. Subsequently a Risk Score is calculated as the product of consequence and likelihood, with Risk scores expressed as:

Low Moderate High Extreme

67 Guidelines for Landscape and Visual Impact Assessment 3rd Edition (2013). Produced jointly by the Landscape Institute and the Institute of Environmental Management and Assessment and supported by the English Heritage, Scottish Natural Heritage and Natural Resources Wales. 68 Best Practice Note 10.1: Landscape Assessment and Sustainable Management (2010). NZILA Education Foundation. 69 “AS/NZS ISO 31000:2009, Risk management - Principles and guidelines” 70 MFE (2011) “Expert Risk Assessment of Activities in the New Zealand Exclusive Economic Zone and Extended Continental Shelf “NIWA Client Report No: WLG2011-39, September 2011, Published in May 2012 by the Ministry for the Environment, Publication No: CR 124.



Effects on the Social Environment

Evaluation of effects on the Social Environment was undertaken according the Social Wellbeing Framework which has been developed around social indicators work in the OECD and Ministry of Social Development71. In this context the following assessment criteria have been adopted and were used in the TTR assessment.

Minor Moderate High Extreme

Stage III: Consider Mitigation Measures

Mitigation is aimed at preventing, minimising or managing negative effects to as low as reasonably practicable (termed “ALARP”)72, and optimising and maximising any potential benefits of the Project.

Consideration of effects across the range of subject areas needs to take into account opportunities for avoiding, remedying or mitigating adverse environmental effects. These are commonly referred to as mitigation measures and many have been incorporated into the proposed TTR project design as described in Section 15 of this IA. The above evaluation has taken these design-based mitigation measures into account.

Stage IV: Address Residual Impacts

Following the identification of potential environmental impacts (Stage I), their significance (Stage II), and the implications of potential design-based mitigation measures (Stage III), it is important for the Impact Assessment process to consider the significance of residual impacts that will remain, after mitigation measures have been incorporated, and whether some form of monitoring or measurement might be justified.

In this IA, TTR’s “design” mitigation measures have been incorporated into project design so all effects evaluated are residual impacts after accounting for design mitigation measures. However, the evaluations do not take account of identified “post-design” mitigation measures set out in Section 15 of this IA. Accordingly physical, ecological and social effects are expressed in this IA as “pre-mitigation” assessments. Dealing with Uncertainty in the Assessment of Effects

Assessment of environmental effects is a process that deals with future predictions. Inevitably uncertainty will arise between the predictions made and what will actually happen during the course of the Project. However, the nearshore dredging in the depths proposed for the TTR process is widely practiced, the sources of impacts are well-understood and the areas of interaction with the receiving environment have been well-characterised overseas. Inferences can be made through prior experience.

Predictions set out in this IA have been made using best available information and analytical tools and techniques. Where the sensitivity of a resource to any particular activity is unknown and the magnitude of impacts cannot be predicted with full certainty, TTR’s specialist advisors have used their professional experience to judge the level of significance of any such impacts.

71 Buchan D and Baines J, 2012, Training in Social Impact Assessment (sponsored by the Environment Institute of Australia and New Zealand) 72 As Low as Reasonably Practicable (ALARP) is the point at which the cost and effort (time and trouble) of further risk reduction is grossly disproportionate to the risk reduction achieved.



This page has intentionally been left blank



11. EFFECTS ON THE PHYSICAL ENVIRONMENT

Effects on Waves and Surfing

Introduction

Sand extraction will involve developing large pits in the seabed and then returning the de-ored sand to the seabed, where it will partially fill the pits and also form mounds. Pits and mounds on the seabed have the potential to alter the direction of wave approach and wave height at the shoreline and therefore longshore transport and patterns of erosion and accretion at the shoreline, depending on the scale of the operations.

Near shore wave modelling was undertaken to simulate the effects on nearshore wave conditions of TTR’s sand extraction and re-deposition operations. Eight hypothetical configurations of the seabed were intended to represent some possible states of the seabed during the proposed mining operations. These included some representing “worst case” conditions consistent with TTR’s mining strategy, notably “case 1”, which consisted of a remnant 8-9 m mound at the SW end, and a remnant 9-10 m pit at the NE end of every lane in all three mining blocks, both of 300 m width, with all remaining mined areas returned to 1 m below their initial level. Other cases represented lesser levels of disturbance, at intermediate stages in the mining operations.

The complete set of hypothetical bathymetry modifications was tested using a set of scenario–based simulations, and each compared with a “baseline” simulation using unaltered bathymetry.

Waves

It was observed that the maximum effects considered over the whole of the study area will occur in the immediate vicinity of the dredged pits and mounds. Most of the cases tested produced local changes in wave height of up to 20-30 cm, or 7-12%. These were closely correlated with changes in mean period, which were all less than 0.5 seconds for case 1, and less than 0.25 seconds for all other cases (with a reduction by less than 0.1 seconds in the vicinity of Patea, and an increase by less than 0.05 seconds to the west).

The difference in significant wave height for the worst case scenario (Case 1) is shown in Figure 78. The figure shows that seabed modifications due to sand extraction produce increases in wave height (red colours) north of Patea of the order of 100 mm, while the blue colours indicate wave heights decreased by the order of 100 mm focussing on Patea. In this case, the majority of the extraction blocks consist of a 1 m deep depression, with a deeper pit at the NE end and a mound at the SW end, but on average the extraction areas have increased depth. The net result is a pattern of reduced heights (by some 100 mm) for waves in the down-wave shadow of the extraction areas, while heights are increased (by around 100 mm) on the northwest and southeast sides of this shadow area.

There is a more amplified version of this refraction effect in the vicinity of the deeper pits at the NE end of the lanes and some focussing effects over the mounds at the SW ends. Those wave components refracted away from the initial direction continue to propagate in a wide range of north-eastward and south-eastward directions.

The large spatial extent of the affected extraction area in this particular bathymetry case means that the effects on wave conditions are also quite widely spread. In other cases with more localised seabed modifications, the wide directional spread of the refracted waves acts to reduce the energy of this refracted component as it travels shoreward, so it makes a relatively minor contribution to the sea state further shoreward, on top of the incident waves travelling generally north-eastward that bypass the extraction area.



Figure 78: Difference between significant wave height for case 1 and existing bathymetry, over the model domain, for environmental scenario 6 (2.4 m high waves from the SW). Note: The locations of the extraction areas are marked in grey. Beaches surveyed in related studies are named. The 10 m isobath (depth contour) is marked by a black line.

A full description of the effects associated with all the 8 modified bathymetry scenarios is provided in NIWA (2013l).

The maximum changes in significant wave height predicted for the eight bathymetry modification cases and reported as the difference in wave height between the baseline and modified bathymetry are summarised in Table 30. Cases 1 to 6 all show maximum changes in wave height over all environmental scenarios, and over the whole modelling domain.

In the full model domain and seawards of the 10 m contour the maximum changes are 0.2 to 0.3 m in wave height or 7 – 12%. Some local effects, nearer to the sand extraction areas, are larger than effects seen at the 10 m isobath.

Extraction case Full domain

H max (m)

Full domain

H max (%)

10 m isobath

H max (m)

10 m isobaths

H max (%)

1 0.282 11.3 0.104 8.6

2 0.222 8.3 0.042 3.6

3 0.284 12.7 0.044 3.3

4 0.263 7.1 0.046 4.1

5 0.219 7.2 0.050 4.5

6 0.249 7.2 0.016 1.3

7 0.173 6.0 0.021 1.8

8 0.092 4.1 0.009 0.8

Table 30: Maximum changes in significant wave height predicted for the eight bathymetry modification cases.

Note: Changes are expressed in absolute terms (metres) and relative terms (%), either over the full model domain or along the 10 m isobath.



The changes in wave characteristics due to extraction are much smaller at the 10 m isobath, which is about the seaward edge of the surf zone, than the changes further offshore. The magnitude of change as a percentage of the baseline value show changes in significant wave height and mean period remain less that 8.6% for the maxima in case 1 bathymetry modifications, 4.5% for other cases, while average changes are less than 3.5% for case 1, or less than 1.5% for other cases. Case 1 is a worst case situation where large pits and mounds occur at the start of every lane. This assumes that the pits will not infill and the mounds will not slump or be eroded by waves and currents to any degree over the time that it takes to mine the whole area (perhaps 10 years). Changes in wave direction are 1 – 2 degrees at most, which is insignificant when compared to the variability in wave approach throughout the year.

The overall conclusion from the scenario-based modelling is that the proposed sand extraction operations will have only minor effects on wave conditions by refraction (bending the wave path) and diffraction (lateral dispersion of wave energy) and locally by shoaling (changing the wave height) as the waves pass over the modified seabed.

Effects on Surf Breaks

Effects on surf breaks arise from changes in the wave climate. The changes in wave directions mostly follow the changes in wave heights. Given the location over 20 km offshore of the closest breaks, changes are likely to be insignificant. Due to the process of refraction over this distance, wave crests will likely be realigned to the seabed contours offshore of the breaks to a similar direction as they would without the presence of the seabed modifications.

The changes in wave height along the coast at the 10 m contour are less than 100 mm for waves 3 m high. Therefore impacts on wave heights are considered insignificant with respect to impacts on surfing quality.73

Figure 79: Change in height of 3 m waves from the WSW, 16 s period

Effect of Presence of FPSO on Wave Climate

Finally, scenario-based tests were also done of the effect on nearshore wave conditions (particularly on the 10 m isobath) arising from mooring the FPSO off the coast. It was found that in the worst case some vessel orientations produce wave height changes of up to 15 mm on the part of the coast near Patea, and (other) orientations that produce wave height changes of order 5 - 10 mm on the western part of the coast. Relative to the baseline mean values, these correspond to changes in the order of 0.8% and 0.4%, respectively. The wave height increases on the western coast are associated with wave reflections off the vessels,

73 Ecoast Marine (2013) “Potential Effects of Trans-Tasman Resources Mining Operations on Surfing Breaks in the Southern Taranaki Bight” Memo 21 July 2013.



which were conservatively assumed to provide 100% specular reflection, which is likely to be an overestimate.

Pit filling and Mound Deflation

The planned sand extraction operations in the South Taranaki Bight will result in changes in seabed morphology that will take the form of elongated “lanes” about 1 m deep, with worst case assumptions of mounds and pits at different ends of the lanes. The key question addressed in this section of the report is this: what will be the fate of the pits and mounds over time?

Estimates for pit filling and mound deflation were developed for worst case assumptions for pit depth of 10 m and mound height of 9 m, in water depths of 20 m, 35 m and 50 m. The time series of waves and currents for driving the calculations were extracted from the South Taranaki Bight model of waves and currents (NIWA 2013j).

The model predicts that for a 10 m deep pit and a 9 m high mound, at 50-m water depth, it will take around 500 years for waves and currents to reduce the pit volume by 90% (around 300 years for 50% reduction). The model predicts that, at the same depth, it will take around 350 years for 90% of the mound to be deflated (150 years for 50% deflation).

For the same pit and mound dimensions, Infilling and deflation will be faster at 35-m water depth, being 100 years for 90% infilling of the pit (50 years for 50% infilling), and 20 years for 90% deflation of the mound (10 years for 50% deflation).

Residual pits and mounds will only occur at the ends of extraction “lanes”. In these circumstances, it is likely that pit depths and corresponding mound heights will be significantly smaller than the worst case assumptions above. Consequently pit filling and mound deflation will take place in significantly shorter timeframes than set out above.

Effects on shoreline stability and sediment transport

Interference with coastal re-nourishment causing erosion

Sand extraction causing shoreline erosion by interfering with the nourishment of the coast by sand that might be moving onshore from the inner shelf is considered unlikely given the dis-connection between the offshore resource and the coast. Refer to Section 6.5.5

Interference with wave attack angles

NIWA model simulations show that there will be small changes in wave height – both positive and negative, but, averaged over many incident waves and extraction scenarios; this will be unlikely to affect shoreline erosion (see Figure 78 above).

Changes to Coastal Physical Environment

Introduction

This section considers how TTR’s activities will potentially interact with the coastal environment in terms of the following matters:

Adverse effects on natural landforms, physical drivers, erosion, geomorphic character, influences that humans have and/or are having on the coast.

Adverse effects on public access to the marine environment. The deposition of substances to the foreshore and seabed (such as mud deposition on the

beaches from the dredge plume). Adverse effects on physical drivers and processes that cause coastal change – waves and

longshore and cross shore transport Adverse effects on the risk of accelerated coastal erosion or accretion along the region’s

coastline. Modifications to natural hazard processes.



Whether the effects of climate change and associated sea level rise will affect any of the above.

Effects on natural landforms and geomorphic character

Studies were made of the natural landforms and geomorphic character along the 140 km long stretch of coast between Opunake and Whanganui.

The near vertical sections of 30 to 50 m tall cliffs along 70% of the coast owe their geomorphic character to their geology and uplift by tectonic activity and the natural processes of waves attack, weathering and gravitational failure that cause them to erode. Their character will not change with sand extraction. What could potentially change is the rate of erosion of the cliffs if the buffer of beach sands and gravels at their toe is stripped away from the base of the cliffs by the sea – either because the sand supply from the offshore shelf is reduced or because more wave energy is focussed onto the shore.

The beaches at the base of the cliffs owe their geomorphic character in part to their environmental setting. Sand is able to “park-up” in re-entrants on the shoreline (e.g., the small valleys where streams emerge on the coast) where there is some protection from wave energy provided by the re-entrant. These beaches are able to survive even large storm events when waves overwash the upper part of the beach and reflect off the cliffs eroding sediment above high tide level. They rebuild during calmer periods when low swell brings sand ashore.

Sand also accumulates at river mouths such as Patea, where the flood and ebb of the tide traps sand forming sand bodies known as tidal deltas. Further south, where the beaches front low lying topography e.g., Waiinu, sand dunes form where sand is blown inland over low terrain by the strong prevailing SW winds. These environmental settings and their associated geomorphic features are common around the world and their overall geomorphic character will not be affected by offshore sand extraction.

Besides environmental setting, the geomorphic character of beaches around the world is determined by tide range, grain size and wave climate (or more specifically breaker height at the shore).

The grain size of sediment on the beaches is unlikely to change with sand extraction offshore. The medium-coarse sands and gravelly sands forming the beaches have as their primary source river inputs and cliff line erosion (providing the coarser material), and also sand being fed in from the sea. The composition (the proportions of sand and gravel) of the river and cliff sediment inputs will not change with sand extraction offshore.

NIWA observations show that under existing conditions the grain size of sediment on the beaches changes as fresh sediment is delivered to the beach by rock falls and slumping of the cliffs. This material is then broken down by the waves and distributed along the shore. Sand extraction and subsequent processing of the seabed sediment to extract the iron ore will result in slightly finer sand size material being returned to the seabed. However there is little connection between sand at the extraction site, some 22 to 35 km offshore, and that on the beaches. For these reasons, extraction is unlikely to significantly affect the grain size of sediment on the beaches which in general are formed of coarser material (medium to coarse sands). The slope of beaches is primarily determined by the grain size, so if grain size does not change then the slope of the beach will remain unchanged.

Sand extraction offshore will affect the wave climate at the shore to varying degrees depending on the location and scale of seabed modifications (pits and mounds). Initial analysis of waves modelling of the effects of sand extraction on waves reaching the shore suggests the changes in waves characteristics are mostly small (changes in wave height of the order of about 100 mm and changes in direction less than 1 degree) which will have no influence on beach state and geomorphic character.



Effects on public access to the marine environment

If sand extraction operations were to cause erosion of the shore and access ways then public access to beaches could be hindered for vehicles and bikes.

All of NIWA’s studies suggest that coastal erosion will not change significantly in the future with sand extraction offshore and therefore public access to the marine environment will not be hindered. However, continual cycles of cut and fill on the beaches due to natural events will hinder access from time to time as they have in the past.

Effects on deposition of substances to the foreshore and seabed

The plume modelling (NIWA 2013j) demonstrates that the very fine sands and muds (silt + clay size material) generated by sand extraction operations drifts primarily south east from the dredging site and that some of it accumulates on the seabed in the nearshore in the region of Patea and Whanganui. The issue addressed here is “Will this make the beaches muddy?”

NIWA modelling results are presented in terms of maps of the suspended sediment concentrations (SSC) associated with the plumes from the extraction operation. Figure 80 shows near-bottom concentrations for Source (A) at the landward end of the mining operation, mapped as the model median and 99th percentile of the SSC time series at each model grid point, evaluated over the final two years of the simulation. The 99th percentile (indicating where the SSC is less than the given value for 99% of the time) is chosen as a robust indicator of the high end of the concentration distribution and the median represents typical values.

Figure 80: Bottom concentration of mining-derived sediment (source A)

Note: The source location is indicated by a black, open circle at the north end of the extraction area. Top plot shows median (50th percentile) suspended sediment concentration; bottom plot shows the 99th percentile.



The figure shows the plume has highest SSC values at the source – determined as 10–20 mg/L (median) and 100 mg/L (99th percentile). Highest values at the coast are 6–10 mg/L (median) and 60-100 mg/L (99th percentile). The plume footprint has approximately the same shape on the bottom as at the surface, but the surface concentrations are far less than those near the seabed.

NIWA observations made during the beach profile monitoring show that very energetic wave conditions at the shore during storm events continually rework sand in the beach. During the 12-month long beach monitoring period we never observed mud layers on the beaches, nor was it observed in pits dug in the beaches where we would expect to see evidence of historical mud deposition preserved. NIWA grain size analyses found that the mud content of the beach sediment was everywhere less than 1%. There was a complete lack of mud on the beaches despite that fact that river flood events deliver 2 million m3 of fine sediment and turbid water to the shoreline and adjacent to beaches surveyed.

In summary, very fine sands and muds generated by sand extraction operations will not make the beaches muddy. While sediment plumes from extraction operations will reach the shore the absence of mud from existing beach sediments, even close to the sites of river inputs, indicates that if deposited on the beaches fine sediment will be quickly winnowed from the beach sediment by wave action and transported offshore, not building up on the beach.

Effects on currents and cross shelf sand transport

Throughout the study area the prevailing current flows in a direction (NW to SE) that parallels the shoreline and shelf depth contours. Currents reach speeds of 0.3 - 0.4 m/s at peak flow of the tides and large current speeds of around 1 m/s were measured on a number of occasions during periods of high winds. During strong winds, currents could set in a constant direction for more than 24 hours; during calm conditions, currents reversed approximately every 6.2 hours with the tides re-asserting dominance. The currents deviate locally in the vicinity of the large shoreface attached and unattached ridges on the seabed. Bathymetric irregularities such as the pits (to 10 m deep) and mounds (to 9 m tall) at the extraction sites could form features of the order of several kilometres long and 0.5 km wide, and of a similar size to naturally occurring ridges on the seabed. While producing a localised effect on currents, they are not expected to impact prevailing or ambient currents and flow characteristics.

Currents on the inner shelf are the principle mechanism for driving sediment toward the shore and the surf zone (the area of breaking waves in the nearshore) where wave dominated currents transport sediment back and forth along the shoreline and also in the offshore and onshore direction beaches. Sand coming ashore by this mechanism can nourish the beaches. The potential source of seabed sands to nourish the beaches extends well beyond the sand extraction area and is potentially vast. If for instance, seabed sands were supplied from the entire seabed within the 30 m isobath, then assuming an average width of seabed to the 30 m isobath of 20 km, then over the 120 km of coast under consideration the potential seabed area that can supply sand to the shoreline is of the order of 2,400 square kilometres. If the onshore flux added over the whole 120 km long study shoreline amounted to a significant component of the littoral budget, then extraction over an 8 km wide (in a NW – SE direction) sand extraction zone would only intercept a relatively small proportion of the onshore flux from about of this zone. If pit infilling is very slow then the amount of interception will be even less.

A key question is the nature of the connection between seabed sediments in the extraction area and the surf zone, and is seabed sand in the area of the extraction operations some 22 to 35 km off the coast a significant source for sand on the beaches? And, if it is, will sand extraction diminish the supply to the beaches and promote beach erosion?

While the principle current direction is strongly shore parallel there are only very weak cross shore flows. This suggests that sediment transport will predominantly be back and forth along that principal axis rather than across the shore. Long (2-year) model simulations incorporating tide, wind and oceanic forcings show that the time-averaged water movements at the extraction site are very weak and of the order of 1-2 cm/s and are directed primarily SE, deviating only locally from that path as currents are steered about large ridges on the



seabed. Between the project area and the shore, the mean current is very weak (<1 cm/s) and directed towards the shore between Hawera and Patea, while further east of Patea it is directed more to the east. The net current patterns suggest only a weak connection between sands at the extraction site and sediment at the shoreline.

The 2-year model simulations that were run with the plume model over a patch of sand in the extraction area show that while sand at the extraction site gets lifted into suspension reasonably often, it is primarily advected to the SE and it doesn’t travel far before it is deposited again. The patterns of distribution of both the suspended sediment transport and deposition indicate that seabed sediment is not distributed far from the site, and that the transport of sand to the shore from this site (or a deficit therein) will take a lot longer than 2 years.

In summary, it would appear that there is little connection between seabed sediments in the extraction area and the surf zone, and seabed sand in the area of the extraction operations some 22 to 35 km off the coast is not a significant source for sand on the beaches. This suggests that sand extraction will not have significant effects on sand supply to the beaches and will not promote beach erosion.

Effects on Waves

The proposed sand extraction operations will result in pits, elongate depressions (lanes) and mounds in the seabed. The effects of these on wave conditions were addressed by nearshore numerical wave modelling as described in Section 11.1.1 above, with the conclusion that the proposed sand extraction operations will have minor effects (discounting case 1) on the physical driver of waves by refracting (bending the wave direction) and shoaling (changing the wave height) them as they pass over the modified seabed. The changes in both wave height and direction are very small.

A second approach was then applied in which 12-month simulations were carried out to address likely changes under a more extensive range of environmental conditions, and to allow for assessment of possible changes in nearshore sediment processes over longer timescales. This was applied only to the case 1 bathymetry modification scenario. Results were similar to the scenario-based approach, confirming that the bathymetry modifications due to sand extraction will have only very minor effects on the wave characteristics landwards of the extraction site and that the range of variability in the differences associated with the bathymetry changes is considerably less than the corresponding natural range of variability in baseline values.

Effects on longshore transport

Longshore transport is the process by which waves arriving at an angle to the shore drive sediment along the shore and is a primary mechanism for supplying sand to beaches from alongshore sources. Statistics derived from the 12-month model simulations were used to evaluate a criterion for “accepting” or “rejecting” a potential sand extraction site based on a range of one-half the standard deviation (+0.5 s) about the mean (m) of the longshore transport potential. The analysis showed that for the case 1 (worst case situation in terms of potential effects on the shore), the differences in longshore wave energy flux and sediment transport potential as a consequence of the proposed extraction lie well within the envelope of one-half a standard deviation of the natural longshore transport potential. That is to say, such a minor change means that the extraction proposed by TTR for the case 1 situation meets the criterion for “accepting” a sand extraction site.

Effects on risk of accelerated coastal erosion and accretion

Beach profile surveys and observations made at eight sites between Ohawe and Kai Iwi, spanning a stretch of about 70 km of coast show that the beaches are very active. The level of the beach fluctuates up and down 1 – 2 m and the beach face shows excursions back and forth of about 10 – 40 m over time scales of weeks and months in response to erosion during storm events and the calmer periods of beach building in between. These fluctuations occur under natural conditions (no extraction) as a consequence of this environmental setting.



For a shoreline of this character, that experiences a wide variety of wave conditions and large variability in sediment transport rates and changes in sand storage on the beaches, the level of acceptable impacts from sand extraction offshore should be relatively high, compared for instance to a shore that experiences a more limited range of wave conditions. Changes in wave characteristics due to pits and mounds on the seabed resulting from sand extraction operations some 22 – 35 km offshore have been shown to have no significant influence on the wave climate in the nearshore. Also the extraction site has been shown to have no significant connection with the coast in terms of sand supply. It follows that sand extraction offshore will have no significant effect on the beaches in terms of the natural processes of erosion and accretion which under natural conditions are highly variable.

Sediment Plume and Sediment Re-Suspension

Introduction

TTR’s operation will result in suspended-sediment plumes and sediment deposition on the seabed that may cause environmental effects on the ocean environment. Dispersed sediment plumes could also reach the near-shore coastal environment. TTR therefore commissioned NIWA to undertake modelling to predict likely “plume” effects74.

Sediment models predict the suspended sediment concentration (SSC), and expression of the mass of sediment per unit volume, normally expressed in mg/L. However many of the potential effects of suspended sediment involve the interaction of the sediment particles with light. These effects include the visual appearance of sediment from above the water, reduction of underwater visibility and reduction of underwater light levels. These aspects are considered separately in Section 11.6 of this IA.

Methodology

Hydro-dynamic modelling was undertaken to estimate the concentrations and deposition rates of sediments released from TTR’s iron sand extraction operation. This modelling was undertaken using the ROMS ocean model75, based on nested model grids comprising an outer grid covering Cook Strait at a resolution of 2 km and the and a pair of alternative inner grids, one covering South Taranaki Bight and the other a smaller area on Patea Shoals, both at 1 km resolution with the option of refining them to 500 m if necessary (Figure 81).

The modelling system was first used to simulate currents for a 1000-day period. Tidal and sub- tidal modelled currents were compared with measured currents from ten instrument deployments. For tidal currents, agreement was very good. For sub-tidal currents, agreement was good, and comparable with what has been achieved in other similar modelling studies.

Simulations were undertaken using the sediment modules of ROMS to predict the likely extent of sediment plumes, predominant drift directions for the plumes and spatial patterns of suspended-sediment concentrations and deposition thickness of sediment on the seabed. The model tracks sixteen sediment classes, four representing sands and coarse silts derived from the seabed, two representing river-derived silts and clays, and ten representing sediment released from the iron sand extraction operation, ranging from very fine sands to fine silts and clays.

74 NIWA 2013j: “South Taranaki Bight Iron Sand Extraction Sediment Plume Modelling Phase 3 studies” NIWA Client Report No: WLG2013-36 August 2013 75 ROMS is a widely accepted ocean/coastal model with optional embedded models of suspended-sediment and sediment-bed processes.



Figure 81: ROMS grids.

Notes: (a) Outer and inner grids; (b) Inner grid with bathymetry (coloured surface), coastline (yellow), 12 nautical mile (22.2 km) territorial limit (thin white line), project area (thick white line), ADCP sites (dark blue), river locations (blue) and towns (black).

The model was used to simulate natural sediment processes in the area. Comparisons with remote-sensed data and in situ time series showed that the model reproduces observed SSC levels reasonably well. Comparison with acoustic backscatter estimates of near-bottom SSC showed that the model over-predicts the rate of sand re-suspension at some locations and under-predicts it at others.

The output of sediment (or in one case, freshwater) from TTR’s iron sand extraction operation was represented with three sources:

1. The suspended source, representing fine sediment (grain size < 90 µm) introduced into suspension via two discharge streams: the overflow from the hydro-cyclone de-watering system and the de-ored sand discharge.

2. The patch source, an area of 3 × 2 km representing one year’s discharge of de-ored sand, including a small amount of fine material.

3. The freshwater source, representing freshwater used to rinse the iron sand concentrate and discharged from hyperbaric filters.

Of these three sources, the suspended source has the greatest impact in terms of the extent and magnitude of the concentrations in the sediment plume.

Two source locations were considered, at the inner end (A) and outer end (B) of the project area.



Nearfield input parameters were derived from CFD modelling (Section 2.10.4 of this IA). A fundamental assumption was that fine sediments would be released from the top 300 - 500 mm of re-deposited tailings, with fine material associated with deeper re-deposited sediments remaining in-situ.

Suspended Source –de-ored sand discharge and hydro-cyclone overflow

11.5.3.1 Suspended Solids Concentrations

The suspended source was introduced in a simulation of 1000 days on the South Taranaki Bight domain, with the source operating for 800 days (with 20% down-time) and statistics calculated over the final two years. The analysis of SSC focussed on the median and 99th percentile, comparing values for natural sediments, mining-derived sediments and the combination of the two. There are conceptual complications in carrying out these comparisons, owing to the effects of the sediments on the flow and the interactions between different sediments. These issues were investigated in terms of time series of surface SSC at two sites: a nearshore site near the Whanganui River and an offshore site 8 km from source location A. At the former site, natural sediments dominated over mining-derived sediments; at the latter site, the mining-derived SSCs were larger than the natural SSC levels.

Plumes from the suspended source extended to the east-southeast from both source locations, reaching the coast between Patea and Whanganui and with a long tail of low concentrations following the coast towards Kapiti. For source A the highest surface concentrations occurred at the source location and were 2.5–5 mg/L (median) and 10-20 mg/L (99th percentile).

For source B the plume was located further offshore and the concentrations somewhat lower. In both cases the plume of mining-derived sediment contributed significantly to the total SSC within a few kilometres of the source but was insignificant relative to the natural SSCs near the coast.

Results are set out in Figure 82 to Figure 85, for Source A. Outputs for Source B are presented in Appendix 7.



Figure 82: Median near-surface concentration of suspended sediment from Source A.

Notes: a) Natural SSC; b) mining-derived SSC; c) natural plus mining-derived SSC. Black lines indicate the project area and the 22.2 km territorial limit. An open circle in panels b and c indicates the source location.



Figure 83: 99th percentile near-surface concentration of suspended sediment Source A.

Note: a) Natural SSC; b) mining-derived SSC; c) natural plus mining-derived SSC.



Figure 84: Median near-bottom concentration of suspended sediment from Source A.




Figure 85: 99th percentile near-bottom concentration of suspended sediment Source A.




11.5.3.2 Deposition

Deposition from the suspended source was characterised by two statistics: the maximum 5- day deposition which represents the maximum amount of material accumulated over any 5-day interval (Figure 86); and the maximum 365-day deposition (Figure 87).

As with SSC, for both short-term and long-term scenarios, the deposition footprint of the mining-derived sediments is distinguishable from the natural background in the vicinity of the source, but near the coast there is only a minor change in deposition rates in comparison with the natural rates of background sediment deposition.

Figure 86: Maximum 5-day increment in sediment bed thickness - Source A.




Figure 87: Maximum 365-day increment in sediment bed thickness Source A. Note: a) Natural SSC; b) mining-derived SSC; c) natural plus mining-derived SSC.



Recovery Simulation

A “recovery” simulation was set up to investigate the sequence of events when the suspended source is turned off (i.e. when extraction ceases). After 800 days of simulated extraction operation there is an extensive patch of deposited mining-derived sediment up to a thickness of 10 mm near the source and around 2–3 mm in a secondary maximum between the Whanganui and Manawatu Rivers. Over the following two years this extraction derived “patch” is eroded away (Figure 88) and the associated near-bottom SSCs reduce considerably (Figure 89).

Sands move away from the initial patch location for a distance of up to 10 km over two years. There is no extensive plume of suspended sediment.

Figure 88: Thickness of mining-derived sediment for the recovery simulation.

Note: a) Snapshot at the time the release stops; b) Snapshot 365 days after the release stops; c) Snapshot 700 days after the release stops.



Figure 89: 99th percentile of near-bottom SSC for the recovery simulation.

Note: a) For the period 0–365 days after the release stops; b) For the period 365–700 days after the release stops.

Freshwater Source

Concentrations of freshwater in the plume from the freshwater source are low, with the 99th percentile concentration less than 0.1% (Figure 90). Values are low, so that the effect of the freshwater in depressing salinity will not be significant. To estimate the concentration of any dissolved substances in the freshwater, the values in Figure 90 can be scaled once the concentration of that substance in the freshwater stream is known.



Figure 90: Statistics of surface freshwater concentration from the freshwater source.

Note: a) median. b) 99th percentile.



Effects on Optical Properties

The ROMS sediment model predicts the suspended sediment concentration, i.e. the mass of sediment per unit volume, normally expressed in mg/l (Section 11.5 above). However many of the potential effects of suspended sediment involve the interaction of the sediment particles with light. These effects include the reduction of underwater light levels (light penetration), reduction of underwater visibility (visual range) and visual appearance (colour).

Light penetration is important for the ability of phytoplankton and plant life to photosynthesise.

Vertical visual range is important to organisms that view the water from above, such as birds foraging for prey, whereas horizontal visibility is important for sighted prey and predator organisms, such as fish. Both visual range aspects are relevant in human perception and recreational use (underwater visibility for diving).

Water colour is an important attribute in human perception and it strongly influences aesthetic appeal and suitability for recreational use. Within the water the change in colour at any given depth could also be important to photosynthetic organisms, adapted to the quality of light they receive.

TTR commissioned NIWA to investigate the effects of TTR’s activities on the optical properties of the STB as described in NIWA (2013k)76. The main findings of the investigation were:

1. The sediment plume from iron-sand mining will impinge on the STB region and shoreline and so will affect light penetration, visibility and colour of the coastal and near-shore waters. The modelled optical effects are predicted to diminish with distance away from the mining discharge site. Mining discharge is likely to change the optical properties about 4-5 fold. The median spatial ‘footprint’ propagates in a West-East direction (an ellipsoid 50 km in length by 20 km wide), with diminishing effect over about an 800 km2 area.

2. The colour and clarity of ambient near-shore waters of the STB (less than about 5 km from the coast) are highly variable over time and space in response to river plumes and wave action (MacDonald, Gall et al. 2013). Usually, these near-shore waters contain relatively (to offshore) high SSC and have high light attenuation characteristics. Therefore ‘sensitivity’ of these nearshore aquatic ecosystems to optical and visual impacts on these waters are expected to be low.

3. A person standing on the beach is likely to be able to see about 5 km out to sea. It is likely that the mining plume would not normally be discernable from the beach given high natural variability and typically high SSC closer than 5 km from the shore. From the top of a 30 m cliff top, a person could see about 20 km offshore and is likely to sometimes be able to see a mining plume. The inner edge of the proposed mining area (site A) is about 23 km offshore and the outer edge of the proposed mining area (site B) is about 34 km offshore. Whether a plume is observable from a cliff top depends on background concentrations of SSC, viewing conditions (including atmospheric visibility, wave height) and the movement and settling of the plume.

4. It is likely (on most occasions) that the plume would be visible from ocean colour satellites, aircraft and watercraft in the vicinity. The mining plume would appear as a brighter, greyer (muted colour) patch of water, diminishing with distance from source. Optical monitoring of plume-impacted waters seems feasible using ocean colour satellite sensors. The modelled optical data will be useful for assessing the ecological effects, or environmental impact, of reduced visibility (and therefore reduced reactive distance of fish and aquatic birds) and reduced light penetration (affecting benthic algae and phytoplankton) – plus some shift in light quality.

Specific outputs are provided in relation to the main axes of the anticipated sediment plume (Figure 91).

76 NIWA (2013k) “Optical effects of an iron-sand mining sediment plume in the South Taranaki Bight region”, NIWA Client Report WLG2013-45, May 2013



Figure 91: Approximate positions of relevant transects, alongshore and through the main axes of the plume.

Graphical outputs are provided below in relation to:

Suspended sediment concentrations (Figure 92) Euphotic depth - the depth at which light for photosynthetic organisms (phytoplankton,

algae, and benthic plants) has declined to 1% of surface value. (Figure 93) Secchi depth – measure of vertical visibility (Figure 94) Horizontal visibility (Figure 95) Red reflectance – measure of change in water colour (Figure 96) Median surface satellite true-colour – measure of change in indicated colour (Figure 95)

In all cases the alignment of results follows the main axes illustrated in Figure 91 - South to North (Hawera), West to East (Whanganui)), and in the nearshore environment (within about 2 km) alongshore (Hawera-Foxton). Boxplots enclose 50% of the data around a median (25th to 75th percentile), with bars extending to 90% (5th to 95th percentile). All points outside this range are highlighted red. The seafloor is indicated by the black line.



Figure 92: Surface suspended sediment concentration (SSC) transects under natural and mining conditions.



Figure 93: Euphotic zone depth (the depth of 1% surface light) transects under natural and mining conditions



Figure 94: Vertical visibility depth (Secchi) transects under natural and mining conditions.



Figure 95: Horizontal visibility distance (black disk) transects under natural and mining conditions



Figure 96: Red reflectance transects under mining and natural conditions.



Note: Tiles show Munsell standard colour descriptors

Figure 97: Modelled median surface satellite true-colour tiles under natural and mining conditions following main axes of sediment plume

Effects on Seascape, Natural Character and Visual Amenity

Introduction

Boffa Miskell (2013b) provides a detailed evaluation of the effects of the TTR Project on seascape, natural character and visual amenity. Effects in these areas can be categorised as follows:

Visual effects from specific viewpoints and viewing audiences. Effects on natural features and natural landscapes (being defined and/or special or

significant landscapes/seascapes and features). Effects on natural elements, natural patterns and natural processed (the natural

character of the coastal environment).

Each of these matters is discussed below

Effects Assessment Context

In considering an application for a marine consent, section 59 requires the EPA to take into account the effects on the environment of allowing the activity, which in addition to effects in the EEZ, also includes effects that may occur in New Zealand77 and effects that are not regulated under the EEZ Act78. The EPA must also take into account the “nature and effect” of other marine management regimes79. The Resource Management Act 1991 (RMA) is a marine management regime80 which applies in the coastal environment.

77 section 59(2)(a)(ii) and section 59(2)(b)(ii) 78 section 59(2)(b)(i) 79 section 59(2)(h) 80 section 7(2)(l)



Therefore, as the Project is taking place in the EEZ, but the marine/seascape related effects of the Project will be apparent both within the EEZ and the CMA, the RMA provides helpful and relevant guidance to assist in assessing the effects that will occur in the New Zealand coastal environment. In that respect, the “nature and effect” of the RMA and RMA documents is that they do not provide tests that the Project is bound by, however they do provide guidance in assessing the effects of the Project that occur in the coastal environment. This approach has been adopted in this assessment of effects on seascape, natural character and visual amenity.

Visual Effects

Visibility mapping using the Zone of Theoretical Visibility (“ZTV”) approach was undertaken to determine the extent and pattern of potential visibility of the operational shipping associated with the Project. The FPSO will be at different locations at the mining site over the operational phase of the Project and therefore two locations were selected for the ZTV mapping: the shoreward limit of the Project area (22.2 km offshore), and at the centre of the proposed Project area (28 km offshore). Figure 98 to Figure 101 below show the potential visibility of the FPSO from both locations.



Figure 98: Zone of Theoretical Visibility from 12 Nautical Miles FPSO Deck Height: 15 m asl Observer Height: 2 m agl



Figure 99: Zone of Theoretical Visibility from 12 Nautical Miles FPSO Deck Height: 55 m asl Observer Height: 2 m agl



Figure 100: Zone of Theoretical Visibility from centre of Application Area FPSO Deck Height: 15 m asl Observer Height: 2 m agl



Figure 101: Zone of Theoretical Visibility from centre of Application Area FPSO Deck Height: 55 m asl Observer Height : 2 m agl



While the visibility of the FPSO will be high from marine areas within 10-15 km of the vessel itself, the visual effects are assessed as being low overall and are unlikely to be perceived as being visually intrusive or adverse. Even though the FPSO is large and its associated and smaller support vessels will also be present, and in some cases may be visible from the coastline for extended periods of time, the surface marine activities associated with the Project are considered to be minor overall and where visible, will likely be seen as an “appropriate” working seascape activity.

While visibility from aircraft has not been specifically modelled, it is likely that these occasional and intermittent views will not be significant and the operational vessels will likely be viewed as a focal point and feature in the seascape. The visual effects of the plumes associated with the mining activity are discussed in Section 11.5 of this IA.

Boffa Miskell (2013b) undertook a detailed evaluation of all of the locations identified by the TRC as areas of high amenity value; areas and sites of outstanding coastal value; and areas identified in the 2004 Inventory of Coastal Areas of Regional or Local Significance, with attention to the following sites:

Ohawe Beach Waihi Beach Manawapou/Tangahoe Kakaramea Beach Patea Beach and River Mouth Whenuakura Estuary Waipipi Dunelands North and South Traps Waverley Beach Waitotora Estuary Waiinu Beach and Kai Iwi Beach

For all these areas, the visibility of the Project will vary and in general, and where visible, will be seen as a distant and background offshore activity within an expansive seascape setting. The visual effects of the surface marine activities are assessed as being minor and will not be adverse nor will they appear to be visually intrusive from the recreation and amenity areas identified by the TRC.

There will be two types of night lighting associated with the offshore vessels, namely navigational safety lighting and operational lighting. While navigational lights can be on permanently or intermittently, it is unlikely the navigational lights, in most instances, would be visible from the coastline. Operational safety lighting will be continuous and will be more apparent from coastal locations due in part to its extent, its elevation and the need to adequately ensure safe on board operational activity. While specifics of the lighting or its intensity are not currently available, it will largely be above the 15 m deck level albeit directed downwards onto working area. Under favourable weather conditions it is likely to be visible from some coastal locations in the Patea to Hawera area. There are however, few public roads or residences located on the coast where operational lighting will be seen to be particularly or intrusively visible.

Effects on Natural Features, Landscapes/Seascapes

The TRC defines the following areas in the South Taranaki Bight as “outstanding”:

Whenuakura Estuary North & South Traps Waverley Beach Waitotara Estuary Waiinu Reef



TRC Regional Policy 4.1 requires that these areas be managed in a way that gives priority to the avoidance of adverse effects on the outstanding coastal values within each area.

Boffa Miskell (2013b) assessed the outstanding areas identified in the TRC Regional Plan as follows.

Whenuakura Estuary The particular values of this estuary located approximately 3.5 km to the south of Patea are primarily ecological and include the estuaries relatively unmodified state, its habitat for the threatened Caspian tern, rare variable oyster catcher and Royal spoonbill, its path for migratory birds, its whitebait spawning on the northern bank and its dune swale frog populations. The estuary also includes sites of spiritual significance to iwi including the site of a kainga (village) and a pa site. There will be little, if any effect of the Project on these identified outstanding values.

North and South Traps The particular values identified for these two offshore areas are the unusual pinnacle feature on a sandy coast, the large seaweed (Ecklonia) forests and the abundant and diverse marine life associated with these outstanding marine features. Given the location of the traps it is unlikely there will be any adverse effects on these values or the outstandingness of these features. While there may be variations in suspended sediment plume concentrations from the Project, these are likely to be relatively minor and will not adversely affect the special features and values of the traps. Sediment plumes and their potential effects are discussed further in Section 11.7.5 of this IA.

Waverley Beach The Waverley Beach coastal landforms have been identified as an outstanding natural landscape. These very distinctive features of caverns, ravines, tunnels and blowholes which create a unique landscape/seascape feature extend over a distance of 8 km. The proposed Project will have no adverse effect on this outstanding natural seascape feature.

Waitotara Estuary This relatively unmodified estuary has high natural values and important cultural and historical associations related to early European settlement in the area. The particular natural values of the area include its habitat value for threatened birds including the Australian bittern, New Zealand shoveller and the black swan, migratory wading birds (Royal spoonbill, banded dotterel), and international migratory birds (eastern bar-tailed godwit). Sub-fossil totara stumps in the estuary are a particular feature of the estuary and the area is also an important whitebait spawning area. The TTR Project will have no adverse effects on this outstanding natural feature or its particular and distinctive estuary values.

Waiinu Reef The Waiinu Reef is made up of limestone outcrops extending from mean high water springs to several km offshore. The hard rock reef contains many well preserved fossils of oysters, toheroas, cockles, paua and barnacles. The reef also contains abundant marine life forms and has important cultural associations associated with fishing and gathering kaimoana. The effects of the TTR Project will have no adverse effect on the outstanding natural feature or its characteristic values.



Analysis was made in terms of NZCPS Policy 15(a) which seeks the avoidance of adverse effects on outstanding natural features, landscapes/seascapes in the coastal environment. The Project by its remote offshore location effectively avoids direct adverse effects on the identified outstanding natural features, landscapes and seascapes in the South Taranaki Bight. In addition, and with respect to NZCPS 15(b) which seeks to “avoid significant adverse effects and avoid, remedy or mitigate other adverse effects in the coastal environment”, the Project was found to achieve these objectives. Boffa Miskell (2013b) concluded that, through its ongoing iterative scoping and design phases the Project has sought to avoid or minimise adverse effects particularly in terms of confining the seabed mining footprint, reducing operational sediment discharges, and minimising the re-deposition of de-ored sands to previously disturbed seabed area.

Where there may be effects as a result of variations of suspended sediment concentrations from offshore generated plumes from the Project, Boffa Miskell (2013b) concluded that the effects of these are not likely to be significant in the inshore and nearshore marine areas.

The visual and natural character effects of sediment plumes are discussed further in Section 11.7.5 below.

Sediment Plumes

As noted in Section 6.12.3 of this IA, coastal sediment plumes in the South Taranaki Bight are a distinctive seascape feature, even though the appearance, patterns, extent and frequency vary considerably over any particular day and over particular periods of time.

TTR commissioned NIWA to model the natural concentration and deposition rates of the levels of sediment released from the Project (Section 11.5 of above). These modelling predictions along with photographic records and field observations provided the background for a visual assessment of sediment plumes in the South Taranaki Bight seascape.

Analysis was undertaken in terms of distance bands from the coast at 1.5 km (inshore), 5 km (nearshore) and 10 km (offshore). These distances were selected based on distances up to 1.5 km being representative of foreground views, 1.5 to 5 km being middle-ground views and 5 to 10 km being representative of background views. Views to distances beyond 10 km from the coastline are considered to be relatively indistinguishable in terms of sediment plume patterns and colour. The horizon line from the beach is generally in the order of 5 km distant.

Boffa Miskell (2013b) provides a detailed analysis of modelled suspended sediment values for each of the identified significant sites and areas on the coast between Ohawe and Whanganui relation to the distance zones noted in above. In undertaking this analysis, Boffa Miskell (2013b) took into account advice from NIWA81 that where there are minor differences in the higher natural sediment concentration levels compared to the lower combined sediment concentrations this difference can be attributed to the following factors:

The sediments in the model affect the currents, though normally by a small amount, by altering the water density and also the bottom roughness (which affects bottom drag). Any change, however small, in a model like this, then affects the transport processes, which can have a large effect on the concentration at any

81 NIWA (2013l) “South Taranaki Bight Iron Sand Mining Nearshore Wave Modelling Phase 4 Studies” NIWA Client Report No: HAM2013-091 August 2013



given point in space and time. In the sense the model – like the real world – displays “chaotic” behaviour.

The different sediments, once deposited on the bottom, then compete with each other during re-suspension. It appears that overall (and with exceptions) the introduction of mining-derived sediment tends to reduce the concentration of suspended natural sediments.

Findings are summarised as follows in relation to median SSC levels in the distance bands noted above:

Within 1.5 km Median SSC levels vary, with the influence of river inputs being evident in the naturally derived sediment plume maps. While specific values at the 1.5 km band vary from 8.7 mg/l off vicinity Waiinu Beach, they increase further north with the highest values (17.1 mg/l) occurring adjacent to Kakaramea Beach to the north of Patea. Mining derived sediment within the 1.5 km area is low with values generally being below the 0.6 mg/l level. Within the 1.5 km zone the combined natural and mine derived sediment does not vary greatly with the median values at the 1.5 km distance band being less than those for the naturally derived sediment levels.

5 km band Median natural SSC ranges from 2.5 mg/l to 7.1 mg/l, with mining derived contributions ranging from 0.1 mg/l offshore from Ohawe Beach, to a maximum of 0.7 mg/l at the North and South Traps.

10 km offshore Natural SSC values vary from 1.0 mg/l to 4.4 mg/l. Mining derived values of up to 1.2 mg/l occur offshore from the Waipipi Dunelands. At 10 km offshore all sites between Castlecliff Beach and Kakaramea Beach the mining derived sediment plumes show an increase of between 0.5 mg/l (Waihi Beach) to 1.9 mg/l (Waitotara Estuary) over natural levels. Based on the appearance of these plumes, relative to colour differentiation, the visual effects of the differences between natural and the combined levels of suspended sediment will be minor and in most cases difficult to detect.

Visual effects of sediment plumes from recreational boats will be evident and highly variable depending on weather conditions and the offshore location of the vessels. There will however be observable visual effects in terms of surface sea colour change and pattern in the distant offshore waters in the immediate vicinity and to the east of the mining activity in what is currently a dark blue-green water area. The colour range within the plume is likely to range from dark blue-green to a lighter blue-green colour extending over a distance of some 35-40 km to the east of the mine site. From this point, which is approximately 10-15 km offshore, the plume then becomes a “milky” colour until it blends into the background offshore levels to the east off Waiinu Beach to a more brown-green colour as it extends towards the Whanganui River mouth area.

While the size and pattern (scale) of the sea surface colour change is extensive and significant in its seascape context, its significance in terms of recreational/amenity values is likely to be lower, given the relatively low levels of recreational activity that occur within the affected marine area. Notwithstanding this, the visual effect of the TTR-derived sediment plume is considered to be moderate to high overall from marine based locations within or in close proximity (3-5 km) of the plume. The sediment plume will however, only be evident during the extraction operations and accordingly this effect in the blue-green marine area is reversible.



Visual effects will be most apparent from recreational and commercial aircraft, and while these effects will be variable and dependant on weather conditions, they will tend to be experienced by transient viewers who in many instances will have no direct relationship with the area. In many instances, the visibility and the offshore pattern of the mining derived sediment plumes are likely to be seen as a feature and focal point in the South Taranaki Bight seascape. While the overall appearance and scale of the mine derived sediment plume will be most apparent from aircraft, given the characteristics of the viewing audience, the visual effects are assessed as being generally in the moderate to low range.

In terms of visible cumulative effects, the mining derived sediment will not add appreciably to the natural or background levels within the inshore and nearshore marine areas. There will however, be increased visual effects in terms of the offshore and distant offshore marine areas where currently there are no visible sediment plumes under most conditions. From the coastline cumulative effects are not likely to be particularly visible. From some marine areas, cumulative effects may be apparent, however, given the limited extent of views and the variability of the plume, cumulative effects are not likely to be perceived as being significant or adverse. From aircraft cumulative effects will be most apparent and are likely to be widespread in extent.

Effects on Natural Character

As noted in Section 6.12 above, natural character in its RMA context is a term used to describe the “naturalness” of the coastal environment in terms of its natural elements, natural patterns and natural processes. Unlike the terrestrial environment which has been modified by land use and development activities, the marine environment has undergone little physical change or modification and consequently displays high levels of natural character both in terms of its biophysical and visual attributes.

From a visual perspective there are few modifications to the marine component of the South Taranaki Bight seascape other than the harbour training walls at the mouths of the Whanganui and Patea Rivers and relatively isolated and contained beach settlements. The Kupe Platform, which is beyond the CMA, is particularly visible from parts of the coastline on clear days. Accordingly, the seascape in visual terms is relatively consistent and “pristine-like” in appearance, other than where it adjoins the coastline in several locations. In its biophysical context there are however, distinctive natural patterns and processes occurring throughout the marine environment.

Boffa Miskell (2013b) considered natural character in terms of matters NZCPS Policy 13(2) (a) to (h) insofar as they relate to subsurface marine elements, patterns and processes. Policy 13(2) of the NZCPS 2010 acknowledges that:

Natural character is not the same as natural features and landscapes or amenity values and may include such matters such as:

(a) natural elements, processes and patterns; (b) biophysical, ecological, geological and geomorphological aspects; (c) natural landforms such as headlands, peninsulas, cliffs, dunes,

wetlands, reefs, freshwater springs and surf\breaks; (d) the natural movement of water and sediment; (e) the natural darkness of the night sky; (f) places or areas that are wild or scenic; (g) a range of natural character from pristine to modified; and (h) experiential attributes, including the sounds and smell of the sea, and

their context and setting. While many of the marine related biophysical matters listed in NZCPS Policy 13(2) are integral to natural character, they have been specifically considered by other specialists commissioned by TTR as set out elsewhere in this IA. Boffa Miskell (2013b)



evaluated these technical findings using the matters set out in NZCPS Policy 13(2) for guidance, with broad findings summarised as follows (major and moderate are representative of significant effects; minor and negligible are representative of effects which are not significant).

Offshore Vessels Given the distance between the viewing points and the vessels, in conjunction with the contextual nature of the surface water activities, the overall significance of the offshore above water activity is judged to be minor.

Natural Features and Landscapes/Seascapes

Based on the identified amenity and recreational activities that occur on the coast and within the inshore/nearshore areas of the CMA, the overall significance of effect is judged to be minor.

Sediment Plumes While mine derived sediment plumes in coastal locations will not generally be visible, sediment plumes in the distant offshore South Taranaki Bight area will, as a result of the iron sand mining operation, be evidence in the dark blue-green surface waters that area currently free of sediment plumes. Given the variability of the plumes and the restricted transient nature of experiencing them, the overall significance of effect is judged to be moderate.

Natural Character Excluding the biophysical/ geomorphological component of natural character, the overall significance of effect is judged to be in the minor category. The exceptions to this are the effects related to NZCPS Policy 13(2)(b) “biophysical, ecological, geological and geomorphological aspects” which include the direct effects of the mine pits and mounds on the sea floor and the time frames in which this area is predicted to recover. The effects on the seabed are not visible, nor are they likely to have significant effects beyond the immediate vicinity of the extraction area, the effects on natural character are likely to be perceived by some as a significant perceptual issue. Therefore, while there will be negligible effects on the inshore and nearshore coastal waters or the coastline as a result of TTR’s offshore activities, the effects at and in the vicinity of the extraction area are likely (subject to what mitigation measures are developed) to be major.

Noise Effects

Introduction

Underwater noise generated by the TTR Project has the potential to affect the underwater environment for fish and marine mammals such as dolphins, porpoises and whales. Particular consideration is given here to potential effects on dolphins and whales given the heightened interest in these animals on the New Zealand coast, even though surveys have indicated a paucity of such animals in the vicinity of the Project area (Section 6.11.4).

It is noted that information available on acoustic characteristics of marine mammals relies on international research and is not related specifically to the iron sand extract area. However, a similar pattern of noise effects is expected in the area as found internationally and overseas data has been adopted for this evaluation in the context of the best available information.

Hegley (2013) presents the findings of an acoustic evaluation of TTR’s proposed operation based on a comparison of published marine mammal acoustic characteristics against the noise predicted from TTR’s extraction activities. Findings are summarised as follows.



Cetacean Acoustic Characteristics

As a basis for understanding the impact of TTR Project noise it is important to understand the ability of marine mammals to hear the sound.

Figure 102 shows audiograms82 of three dolphin species and three whale (odontocete) species found in coastal waters off northern Europe. The audiogram of the Harbour Porpoise has been used here as a provisional surrogate for the Hector’s dolphin as both species are similar in their physiology and sound repertoire. It is noted the Hectors dolphins are unique from other dolphins in that they produce very few sounds and those that they do are basically clicks that are short in duration and very high-frequency around 120 kHz. They do not whistle either like Bottlenose dolphins to communicate. Instead they just change their rate of clicking. Also shown on Figure 102 is the frequency range where the majority of the noise is from iron sand extraction is predicted.

Figure 102: Exemplary Audiograms of Odontocete Species (in Hegley 2013)

Figure 102 shows that all audiograms exhibit the characteristic U-shaped form with relatively high thresholds at and below 1 kHz and areas of best hearing in the ultrasonic range (>20 kHz). That is, the hearing ability of these mammals is

82 Effects of offshore wind farm noise on marine mammals and fish Frank Thomsen, Karin Lüdemann, Rudolf Kafemann and Werner Piper July 06, 2006 – in Hegley 2013



relatively poor below about 1 kHz, which is that part of the sound spectrum where the majority of noise from dredging typically occurs i.e. in the 125 Hz – 1 kHz region.

In simple terms, at 1 kHz the hearing threshold of these underwater mammals is 80 dB and 100 dB at 500 Hz so any sound below these levels is unlikely to be heard.

Figure 103 shows reported hearing thresholds for bottlenose dolphins and white whales (Beluga)83. This illustrates a similar pattern as shown above.

Figure 103: Hearing Thresholds for Bottlenose Dolphins and White Whales48

Marine mammals tend to be adapted for living in noisy underwater environments, and typically have hearing thresholds that are much less sensitive than those adapted for the atmospheric environment, such as humans84. For this reason marine species are able to tolerate much higher levels of noise.

The frequencies used by porpoise (and assumed to be similar for Hector’s dolphin) are:

83 Testing the Hearing of Whales and Dolphins, Information by Wesley R Elsberry and Diane Blackwood 2003 in Hegley (2013). 84 Assessment of Tidal Current Turbine Noise at the Lynmouth site and predicted impact of underwater noise at Strangford Lough. Report No. 628 R 0102 by Mr S J Parvin, Mr R Workman, Mr P Bourke and Dr J R Nedwell 10th May 2005 in Hegley (2013).



Low frequency sounds at 1.4 – 2.5 kHz for communication Sonar-clicks (echolocation) at 110 – 140 kHz Low-energy sounds at 30 – 60 kHz Broadband signals at 13 – 100 kHz

As set out above, Hectors dolphins produce very few sounds and those that they do are basically clicks, short in duration with a frequency of around 120 kHz.

While the hearing of the dolphin and whales is optimal between about 10 – 100 kHz they can hear to relatively low frequencies, providing the noise level generated is relatively high. As an example, for the sound to appear as loud for the dolphin at 1 kHz as at 10 kHz it would need to be approximately 40 dB louder at 1 kHz than 10 kHz. As dredging noise is generally toward the lower end of the hearing threshold for dolphins and at the lower end of their vocalisation range the effects will be less than if the sound had been above 10 kHz.

The frequency range used by Baleen whales is relatively wide and they generally vocalise in the lower frequencies, between 10 and 4000 Hz. The TTR operation will not cause interference at these frequencies.

Assessment of Effects

Noise levels are likely to be at the lower range of sensitivity for species of marine mammals potentially present in the general Project area. If mammals were present, it would be anticipated that noise would only be heard if in the immediate vicinity of the proposed iron sand excavation operation.

If marine mammals encounter unacceptably high noise levels they would be able to move away from the source. The Crawler noise characterisics are derived from continual motor operation, and are not the same as a sudden loud concussive detonation for example, so behavioural effects, such as fleeing are not expected to occur as a result of noise from proposed iron sand excavation process.

Marine mammals tend to be adapted for living in noisy underwater environments, and typically have hearing thresholds that are much less sensitive than animals adapted for the atmospheric environment (such as humans). Table 31 sets out the approximate noise levels of the iron sand extraction above the threshold of hearing for dolphins and whales:

Distance from extraction Crawler extraction noise sound level above the threshold of hearing

50 m 51 100 m 45 250 m 37 500 m 31

1000 m 25 1500 m 21

Note: Shaded areas indicate general iron sand extraction noise is expected to be masked by the ambient sound.

Table 31: Noise Level (dB re 1μPa) above the Threshold of Hearing

In order to hear the sound it is necessary for that sound to either be above the background sound (ambient sound) or if below the background sound the sound of interest must have a sufficiently distinct spectrum content to be able to pick out the sound amongst the background sound.



Without a detailed spectrum analysis of the various sounds likely to arise from extraction, Hegley 2013 used a conservative assumption that if the dredge noise is at least at the background sound less 10 dB it will be heard. Thus, the masking effects of the existing noise environment can be predicted based on the sea noise being around 132 dB. This means if the dredge is no more than about 122 dB the sea noise will mask most dredge noise. This level of 122 dB will be achieved at approximately 300 m from the suction dredge.

Consideration was also given to the potential effects of acoustic devices used for crawler and re-deposition pipe alignment. No adverse effects from these devices are anticipated given their low intensity.

Other Species

Fish and seals also occur in the broader Taranaki Bight, but as for whales and dolphins, they are not recorded as abundant in the vicinity of the TTR Project area.

Seals exhibit similar audiograms to whales and dolphins as shown in Figure 104, so would be expected to exhibit similar sensitivities. Seals are reported to frequent offshore FPSOs in the Taranaki Bight, without adverse reactions to operational noise.

Source: Subacoustech (2013)

Figure 104: Comparison of hearing threshholds for species of pinniped

Audiograms are available for fish as illustrated in Figure 105, showing that fish have different auditory characteristics to whales, dolphins and seals as set out above. TTR’s noise generation will be well below the level at which lethal effects arise. For example situations involving pile driving where peak to peak pressure levels exceed 240 dB re 1 μPa; physical injury is reported where peak to peak pressure levels exceed 220 dB re 1 μPa (Subacoustech 2013). However, little is known of the effects of low level noise on fish as would be expected from TTR’s operations. It is likely that fish would be able to



hear the TTR noise more than marine mammals, but as levels are below those at which fatality or injury would occur, then it is assumed fish would be able to avoid the area of operations.

Source: Subacoustech (2013)

Figure 105: Comparison of hearing thresholds for species of fish

Conclusions

The effects of TTR Project noise on marine mammals are predicted to be no more than minor. Given the paucity of fishlife recorded in the vicinity of the TTR Project area, it is likely that the level of impact on fish will also be low.

Effects on Air quality

Introduction

TTR commissioned Tonkin and Taylor85 to undertake an air dispersion modelling study of emissions to air from the combustion of Heavy Fuel Oil to meet the FPSO’s energy requirements. The air pollutants considered were fine particulate matter (PM10), sulphur dioxide, nitrogen dioxide and carbon monoxide from the operation of four gas turbines or seven reciprocating engines located on the FPSO and using HFO for fuel (see Section 2.18.5).

Emission rates considered for the study were based on USEPA AP-42 emission factors and calculations by T&T using plant and process data supplied by TTR.

The proposed mining area is located in the open ocean approximately 22.4 km off shore. A 3D meteorological dataset was developed for the region using terrain and land

85 Tonkin and Taylor 2013: “Trans-Tasman Resources Ltd Offshore Iron sands Project - Air Dispersion Modelling Study”



use information, observations from six meteorological surface sites and 3D upper air data developed by another meteorological model (MM5).

Ground level concentrations of each contaminant were predicted using the CALPUFF dispersion model over a 52 km x 40 km grid (100 metre grid resolution) surrounding the site. The maximum predicted ground levels concentrations anywhere within the modelling domain, as well as the maximum concentration on land, were reported.

Gas Turbine Option

As shown in Table 32, the predicted ground level concentrations of all Gas Turbine-derived contaminants considered were found to be below relevant health-based air assessment criteria.

Table 32: Maximum Predicted ground level concentrations – Gas Turbine Option

Reciprocating Turbine Option

As with the gas turbine scenario, two sets of results are presented in Table 33 for each contaminant; the worst case offshore and onshore concentrations. The offshore result is the maximum predicted concentration anywhere in the modelling domain and occurs over water near the FPSO. The onshore result is the maximum concentration that is predicted to occur on land when the FPSO is at the closest point to land (12 nautical miles offshore). The maximum predicted concentration onshore will decrease as the FPSO moves further away from the coast.

It was assumed that all the NOx discharged from the reciprocating engines will be converted to NO2 (which is a conservative assumption – usually no more than 10% will be converted) and that the Heavy Fuel Oil used in the engines will have a maximum sulphur content of 4.5% w/w.

The assessment criteria used for comparison with the modelling results are the National Environmental Standards for Air Quality (NESAQ), the New Zealand National Ambient Air Quality Standards (NZAAQS), and the World Health Organization (WHO) guidelines for NO2 and SO2. The 24-hour average WHO guidelines for SO2 and the annual WHO guideline for NO2 do not have any regulatory status in New Zealand; however they have been referred to recently in some air quality assessments and are included in the table below for completeness.



Contaminant Time average Maximum Ground

Level Concentration

(µg/m3)

Air assessment criterion(µg/m3)

Offshore Onshore

Particulate matter (PM10)

24 hour

Annual

4.4

0.14

0.6

0.024

50

20

Nitrogen dioxide 1 hour (99.9%)

24 hour

Annual

313 160

5.3

60 22

0.9

200 (9 exceedance allowed per 12 months)

100

Sulphur dioxide 1 hour (99.9%)

24 hour

453

231

87 31

350 (9 exceedances allowed per 12

months)

570 (not to exceed)

120 (20*)

Carbon monoxide 1 hour (99.9%)

8 hour

75

67

14

12

30,000

10,000

Note: (MGLC - Maximum Ground Level Concentration)

Table 33: Maximum Predicted ground level concentrations – Reciprocating Generator Option

The maximum ground level concentrations predicted to occur on land of all contaminants considered are well within the relevant New Zealand air quality standards and guidelines. However, the maximum predicted ground level concentration of SO2 on land does exceed the 24-hour average WHO guideline. However it is noted that this guideline is based on exposure over a 24-hour period and it is unlikely that there would be people exposed for this period of time given that the location is an unpopulated coastline.

The maximum predicted ground level concentrations of NO2 and SO2 (1 hour (99.9%) and 24 hour averages) exceed the relevant New Zealand air quality standards and guidelines over water close to the FPSO and are located outside the 12 nautical mile limit where people are most unlikely to become exposed to these contaminants. The maximum predicted ground level concentrations of PM10 and CO anywhere in the modelling domain are within the relevant New Zealand air quality standards and guidelines.

These calculations were all based on use of a fuel with 4.5% sulphur content. TTR will use fuel with a lower sulphur content (likely less than 3.5% sulphur) and this will mitigate risks of exceeding guideline values.

Summary of Effects of the Physical Environment

Table 34 summarises the effects on the physical environment identified in relation to the TTR Project. In Section 15, detailed consideration is given to options to mitigate risks associated with TTR’s activities.

Appendix 8 sets out each assessed effect, cross-referenced against source information in each case.



Table 34: Summary of “Pre-Mitigation” Effects on the Physical Environment

Activity Effects Rating Mitigation Factors

Waves

Extraction/Deposition In immediate vicinity of the dredged pits and mounds - worst case localised changes in wave height of up to 200-300 mm, or 7-12%.

Moderate Distance offshore

Extraction/Deposition Nearshore, worst case change of wave height +/- 100 mm. Minor Distance offshore FPSO Vessel Presence Worst case wave height changes of up to 15 mm. Minor Distance offshore Coastal processes

Extraction/Deposition Sand extraction offshore will affect the wave climate at the shore to a minor degree and will have no influence on beach state and geomorphic character.

Minor Distance offshore

Extraction/Deposition Coastal erosion will not change significantly with sand extraction offshore and therefore public access to the marine environment will not be hindered.

Minor Distance offshore Disconnect between offshore and

nearshore Extraction/Deposition Any very fine sands and muds deposited on beaches, will be quickly winnowed from the beach

sediment by wave action and transported offshore not building up on the beach. Minor Nearshore assimilation

Extraction/Deposition Sand extraction will not significantly affect sand supply to beaches and will not promote erosion. Minor Disconnect offshore and nearshore Extraction/Deposition The extraction proposed by TTR meets the criterion for “accepting” a sand extraction site in

relation to effects on longshore transport. Minor Disconnect offshore and nearshore

Extraction/Deposition Sand extraction offshore will have no significant effect on the beaches in terms of the natural processes of erosion and accretion which under natural conditions are highly variable.

Minor Nearshore assimilation Disconnect offshore and nearshore

Sediment Plume and Sediment Re-Suspension

Extraction/Deposition The plume of mining-derived sediment contributes significantly to the total SSC within a few kilometres of the source.

High Distance offshore

Extraction/Deposition The plume of mining-derived sediment is insignificant relative to the natural SSCs near the coast.

Minor Nearshore assimilation

Sediment Deposition

Extraction/Deposition Deposition rates of mining-derived sediments are distinguishable from natural background in the vicinity of the source.


Extraction/Deposition Deposition rates of mining-derived sediments, near the coast are only a minor change in comparison with natural rates.




Effects on Optical Properties

The sediment plume effects on light penetration, visibility and colour near-shore waters described as ‘fairly subtle’.


Extraction/Deposition Colour and clarity of ambient near-shore waters are variable over time and space in response to river plumes and wave action; ‘sensitivity’ of aquatic ecosystems and human observers and recreationalists to optical and visual impacts on coastal and near-shore STB waters are expected to be low.


Visual Effects

Presence of Vessels The visual effects of the surface marine activities are assessed as being minor and will not be adverse nor will they appear to be visually intrusive from recreation and amenity areas.


Extraction/Deposition The visual effect of the TTR-derived sediment plume is considered to be moderate to high overall from marine based locations within or in close proximity (3-5 km) of the plume. The sediment plume will however, only be evident during the extraction operations and accordingly this effect in the blue-green marine area is reversible.


Extraction/Deposition Visual effects will be most apparent from recreational and commercial aircraft, and while these effects will be variable and dependant on weather conditions, they will tend to be experienced by transient viewers who in many instances will have no direct relationship with the area.

Minor-Moderate

Distance offshore

Extraction/Deposition In many instances, the visibility and the offshore pattern of the mining derived sediment plumes are likely to be seen as a feature and focal point in the South Taranaki Bight seascape.

Minor-Moderate

Distance offshore

Extraction/Deposition In terms of visible cumulative effects, the mining derived sediment will not add appreciably to the natural or background levels within the inshore and nearshore marine areas.


Effects on Natural Character

Extraction/Deposition Excluding the biophysical/ geomorphological component of natural character, the overall significance of effects on natural character is judged to be in the minor category.

Minor Distance offshore Nearshore assimilation

Extraction/Deposition Effects on the seabed are not visible, nor are they likely to have significant effects beyond the immediate vicinity of the extraction area. However such effects are likely to be perceived by some as a significant perceptual issue. Therefore, while there will be negligible effects elsewhere, the seabed effects in the vicinity of the extraction area, albeit occupying only a small percentage of the area of the STB, are likely (subject to what mitigation measures are developed) to be major.

Major Distance offshore

Noise Effects

Operational noise Even in the unlikely event that marine mammals were present near the operational area, there is not expected to be any more than some temporary alteration to sea mammal behaviour.

Minor Absence of marine mammals Limited distance of noise effect



Operational noise For fish the sound level expected to be generated by TTR Project is not expected to interfere with the sound spectrum other than in the immediate vicinity of the Crawler. Background sea noise will mask most dredge noise from a distance of approximately 300 m from the crawler. When taking the above into account the effects of TTR Project noise on marine mammals and fish are predicted to be no more than minor.

Minor Limited distance of noise effect

Effects on Air quality

Emissions to Air Air dispersion modelling study of emissions to air from the combustion of Heavy Fuel Oil determined ground level concentrations of all contaminants will be below relevant health-based air assessment criteria on land.




Page intentionally blank



12. EVALUATION OF MARINE ECOLOGICAL EFFECTS

Introduction

Section 2 of the EEZ Act requires that any adverse effects shall be avoided remedied or mitigated. Therefore it is important to firstly identify all environmental effects, as discussed in the preceding section of this IA. The next step is to undertake an evaluation of these effects to provide a basis for developing appropriate “avoid remedy or mitigate” options.

This section evaluates all marine ecological effects as described below.

Effects on physical processes and the social environment are assessed in subsequent sections of the IA.

Benthic Ecology, Fish and Birds

TTR engaged Dr Dan McClary of Gardline Australia Pty Ltd. to undertake an ecological effects evaluation using a Risk Assessment Framework as described in Appendix 6. Consideration was given to the following ecological matters:

Benthos Plankton Fish Birds Habitat Water quality Ecosystems and biological diversity

Potential ecological effects were subject to a risk analysis which was used to identify appropriate measures to avoid remedy or mitigate adverse effects as set out in Section 15 of this IA.

The approach adopted was based on the rationale set out in NIWA (2011)86, a report prepared for the Ministry for the Environment setting out the findings of an expert risk assessment of activities in the New Zealand Exclusive Economic Zone and Extended Continental Shelf.

Each of TTR’s activities was evaluated in terms of its associated potential ecological risk, with results set out in Table 35.

86 MFE (2011) “Expert Risk Assessment of Activities in the New Zealand Exclusive Economic Zone and Extended Continental Shelf “ NIWA Client Report No: WLG2011-39, September 2011, Published in May 2012 by the Ministry for the Environment, Publication No: CR 124.



Table 35: Ecological Assessment: Iron sand mining - Pre-Mitigation. Levels of consequence, likelihood, risk and confidence associated with TTR’s activities are listed (a, b, c, etc.) after each threat to which they contribute. The maximum possible level of environmental risk is 30. Extreme environmental risks are highlighted in red, high in yellow, and moderate in green. Low risk activities are not highlighted.

Recovery period Key species Protected species/

sensitive environments Ecosystem functional impact

Proportion of habitat affected

Activity Effects

Consequence

Likelihood

Risk

Confidence

Consequence

Likelihood

Risk

Confidence

Consequence

Likelihood

Risk

Confidence

Consequence

Likelihood

Risk

Confidence

Consequence

Likelihood

Risk

Confidence

a. Antifouling Impact on pelagic organisms and coastal ecosystem function 2 1 2 2b 3 1 3 2b 2 1 2 2b 3 1 3 2b 0 1 0 2b

b. Mooring blocks and structures Impact on benthos 1 6 6 2b 0 6 0 2b 0 6 0 2b 0 6 0 2b 0 6 0 2b

c. Extraction of sand from the seabed, including grade control drilling

Impact on benthos 2 6 12 2b 0 6 0 2b 0 6 0 2b 0 6 0 2b 0 6 0 2b

Impact on demersal fish 0 6 0 2b 0 6 0 2b 0 6 0 2b 0 6 0 2b 0 6 0 2b

d. De-ored sand re-deposition & hydro-cyclone overflow sediment

Impact on benthos at mining site due to processing and re-deposition of sediment 2 6 12 2b 2 6 12 2b 2 6 12 2b 2 6 12 2b 2 6 12 2b

Impact on near-field benthos due to re-deposition 2 6 12 2b 2 6 12 2b 2 6 12 2b 2 6 12 2b 3 6 18 2b

Impact on rocky reef benthos due to re-deposition 0 6 0 2b 0 6 0 2b 0 4 0 2b 0 6 6 2a 0 6 0 2a

Impact on rock reefs due to choking 1 6 6 2b 1 6 6 2b 1 6 6 2b 2 3 6 2a 1 3 3 2b

Impact on rocky reefs due to light reduction 1 2 1 2b 2 0 0 2b 1 4 4 2b 4 0 0 2b 1 0 2b

Impact on nearshore sand due to re-deposition 0 6 0 2b 0 6 0 2b 0 6 0 2b 0 6 0 2a 0 6 0 2a

Impact on nearshore sand due to choking 0 6 0 2b 0 6 0 2b 0 6 0 2b 0 6 0 2a 0 6 0 2a

Impact on benthic algae 0 5 0 2b 0 5 0 2b 0 5 0 2b 0 5 0 2b 0 0 0 2b

Impact on offshore biogenic habitat due to re-deposition 1 6 6 2b 1 6 6 2b 1 6 6 2b 1 6 6 2b 1 5 5 2b

Impact on offshore biogenic habitats due to choking 2 6 12 2b 2 6 12 2b 2 6 12 2b 2 6 12 2b 2 6 12 2b

Impact on algae in offshore biogenic habitats due to light reduction 0 5 0 2b 0 5 0 2b 0 5 0 2b 0 5 0 2b 0 0 0 2b

Change in water chemistry 0 5 0 2b 1 6 6 2b 1 6 6 2b 1 6 6 2b 1 5 5 2b

Change in pore water 0 5 0 2b 1 6 6 2b 1 6 6 2b 1 6 6 2b 1 5 5 2b

Offshore shading effects 0 5 0 2a 0 5 0 2a 0 5 0 2a 0 5 0 2b 0 5 0 2b

Offshore u/w visibility effects 1 6 6 2b 1 6 6 2b 1 6 6 2b 1 6 6 2b 1 6 6 2b

Offshore effect on aerial predators 1 6 6 2b 1 6 6 2b 1 6 6 2b 1 6 6 2b 1 6 6 2b

Offshore choking 1 6 6 2b 1 6 6 2b 0 6 0 2b 1 6 0 2b 1 6 6 2b

Midshore shading effects 1 6 6 2a 1 6 6 2a 0 6 0 2a 0 6 0 2a 0 6 0 2a

Midshore u/w visibility effects 1 6 6 2a 1 6 6 2a 0 6 0 2a 1 6 6 2a 0 0 0 2a

Midshore effect on aerial predators 1 6 6 2b 1 6 6 2b 1 6 6 2b 1 6 6 2b 1 6 6 2b

Midshore choking 0 6 0 2c 0 6 0 1c 0 6 0 1c 0 6 0 1c 0 2a

Nearshore shading effects 0 6 0 2c 0 0 6 0 2a 0 0 2a

Nearshore u/w visibility effects 0 6 0 2c 0 0 6 0 2a 0 0 2a

Nearshore effect on aerial predators 0 6 0 2c 0 0 6 0 2a

Nearshore choking 0 6 0 2c 0 6 0 2c 0 6 0 2c 0 6 0 2c 0 6 0 2c

e. Effects of FPSO operations – u/water noise and vibrations

Acoustic impact on marine mammals, reptiles, fish and invertebrates 1 4 4 2c 1 4 4 2c 1 4 4 2c 1 4 4 2c 1 4 4 2c

f. Release of dissolved material ex pore water

Impact on pelagic organisms 1 3 3 2b 1 3 3 2b 1 3 3 2b 1 3 3 2b 1 3 3 2b



Table 35 (contd.): Ecological Assessment: Iron sand mining - Pre-Mitigation. Levels of consequence, likelihood, risk and confidence associated with TTR’s activities are listed (a, b, c, etc.) after each threat to which they contribute. The maximum possible level of environmental risk is 30. Extreme environmental risks are highlighted in red, high in yellow, and moderate in green. Low risk activities are not highlighted.

Recovery period Key species Protected species/

sensitive environments Ecosystem functional impact

Proportion of habitat affected

Activity Effects

Consequence

Likelihood

Risk

Confidence

Consequence

Likelihood

Risk

Confidence

Consequence

Likelihood

Risk

Confidence

Consequence

Likelihood

Risk

Confidence

Consequence

Likelihood

Risk

Confidence

g. Ship-to-ship ore transfer Impact of normal operation on pelagic organisms 0 6 0 2a 0 6 0 2a 0 6 0 2a 0 6 0 2a 0 6 0 2a

Impact of normal operation on benthos 0 6 0 2a 0 6 0 2a 0 6 0 2a 0 6 0 2a 0 6 0 2a

h. Ship-to-ship fuel transfer Impact of normal operation on pelagic organisms 0 6 0 2a 0 6 0 2a 0 6 0 2a 0 6 0 2a 0 6 0 2a

Impact of normal operation on benthos 0 6 0 2a 0 6 0 2a 0 6 0 2a 0 6 0 2a 0 6 0 2a

i. RO brine in hydro-cyclone flow Impact on pelagic organisms 0 6 0 2a 0 6 0 2a 0 6 0 2a 0 6 0 2a 0 6 0 2a

j. Hydro-cyclone overflow (sea water with fines sediment, particulate and dissolved organic matter

Impact on pelagic organisms

0 6 0 2a 0 6 0 2a 0 6 0 2a 0 6 0 2a 0 6 0 2a

k. Reverse osmosis chemical discharge Impact on pelagic organisms N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A

l. Discharge from hyperbaric filters that de-water the concentrate on-board the FSO. Impact on pelagic organisms 0 6 0 2a 0 6 0 2a 0 6 0 2a 0 6 0 2a 0 6 0 2a

m. Other discharges from ships (such as sewage) N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A

n. Discharge to air Impact on pelagic organisms 0 6 0 2a 0 6 0 2a 0 6 0 2a 0 6 0 2a 0 6 0 2a

o. Ship’s deck lighting (shielded) Seabird attraction, disturbance, collision 0 6 0 2a 0 6 0 2a 0 6 0 2a 0 6 0 2a 0 6 0 2a

Effects on squid 0 6 0 2a 0 6 0 2a 0 6 0 2a 0 6 0 2a 0 6 0 2a

Effects on fish 0 6 0 2a 0 6 0 2a 0 6 0 2a 0 6 0 2a 0 6 0 2a

p. Other- Vessel exclusion Impact of displaced fishing on fish stocks 1 3 3 2c 1 3 3 2c 0 1 0 2c 0 1 0 2c 0 1 0 2c

q. Vessel movements Ship strikes on marine mammals 3 1 3 2a 0 6 0 2a 3 1 3 2a 0 6 0 2a 0 6 0 2a

r. Unplanned Events Effects on native biodiversity through the incidental translocation of non-indigenous marine species; Effects of spills 3 4 12 2c 3 4 12 2c 3 4 12 2c 3 4 12 2c 3 4 12 2c



Identified Effects

Introduction

Four moderate-high risk effects were identified as described below. Primarily, these matters related to effects on benthic organisms in the vicinity of the direct extraction and deposition area, biosecurity and potential impacts on biogenic offshore habitats due the potential “choking” ” effect.

The following sections describe the identified risk factors and provide additional discussion of factors contributing to the assessed risk level.

Section 0 discusses effects of low environmental risk.

Effects of High Environmental Risk

The following effect was considered to be of high environmental risk (Score 15-20 in Table 35):

(1) Extraction of benthos at extraction site due to sand extraction, and smothering and burial from de-ored sand re-deposition. A particular effect was associated with direct impact on the habitat of the tubeworm Euchone sp. A (Table 35; Activity D) refer Section 6.10.2 of this IA).

Effects of Moderate Environmental Risk

The following effects were considered to be of moderate environmental risk (Score 7-12 in Table 35).

(2) Impact on near-field benthos due to de-ored sand deposition (same effect on Euchone sp. A – but at lower deposition rates across a wider area than the direct extraction and deposition zone.

(3) Impact on offshore biogenic habitats due to “choking” – potential effect of elevated sediment loads in water column.

(4) The potential for effects arising from Unplanned Events – including biofouling effects on native biodiversity through the incidental translocation of non-indigenous marine species to the project site and around New Zealand; and ecological effects from spills.

Benthic Disturbance and Recolonisation

Background

It is clear that there will be direct impact on benthic organisms in the immediate area of TTR’s extraction process. The Crawler will extract sediment by jetting and fluidising the seabed material to make it available for extraction by pumping. The fluidising process will release small amounts of silt into the water column, but this material will be entrained into the intake stream of the Crawler pump.

It is assumed that all sediment and immobile benthic organisms will be entrained into the intake and pumped to the FPSO. Fish at the periphery of the intake zone may be able to avoid entrainment into the intake pump but the intake water velocity of the Crawler pump exceeds the likely burst swimming velocity of smaller coastal fish and entrainment of fish along with non-mobile benthic organisms is expected.

Biota entrained into the Crawler pump system will pass through the pump and then to the Trommel Screens where material larger than 2 mm will be excluded from the process train. This initial screening will divert any hard bodied organisms (such as



bivalves) and fish, but soft bodied organisms that have survived transit through the pump will be physically disrupted by the screening process, and 100% mortality of soft-bodied organisms is assumed.

Screenings from the Trommel Screen will be discharged to the hydro-cyclone. In broad terms the extraction operation will entrain all biota into the FPSO. Larger organisms may be screened out and discharged back to the seabed but the pumping and screening process is expected to result in complete de-faunation.

Re-deposition will involve de-ored sand being placed onto the seabed in layers as deep as 11 m depending on the depth of the pit being filled at the time. This will directly smother any residual fauna remaining in those pits.

In terms of considering the long-term environmental implications of extraction and deposition, the matter to be addressed is the rate with which the operational area will recover from the sediment extraction and re-deposition process. The mechanism for this recovery is recolonisation, which represents a potentially significant mitigation factor in respect of environmental risks associated with benthic biota. This section addresses recolonisation factors relating to the TTR Project area.

Recolonisation of de-ored sediment (and near and far field areas) will be influenced by numerous factors including: latitude, extraction and disposal methodology, site-specific bathymetry, hydrodynamics, depth of deposited sediments, the spatial scale of the disturbance, sediment type, and the timing and frequency of the disturbance. Each element is addressed as follows in relation to the TTR Project.

At the outset, it is noted that relatively few NZ studies have been undertaken into recolonisation of dredged sediments but notably studies have been undertaken near Auckland, Nelson, Christchurch and Dunedin. There is, also a considerable body of international literature on recolonisation of disturbed seabeds, many of which are relevant to the TTR Project (Table 36). This section of the IA sets out information from these studies.

Geographical Latitude 12.4.2

Relatively rapid recovery occurs in temperate and sub-tropical disposal areas, with longer recovery rates (up to several years) observed at higher latitudes where the associated stable physical environments and long-lived taxa take longer to recover from disturbances.

Investigations into the recovery of the Hauraki Gulf disposal site indicated a rapid recovery characterised by re-establishment of a benthic community typical of late stage succession within timeframes of the order of months. Monitoring undertaken for the Lyttleton Harbour dredging programme indicates recovery post-disposal commences rapidly, such that polychaetes become established within a year in a fluid muddy-bottom disposal site. Monitoring undertaken in Tasman Bay for the Port of Nelson dredging disposal programme indicates very rapid rates of recovery (4-6 months). Overall, these recovery rates are indicative of the likely recovery rate for the TTR project area.



Table 36: Studies in which benthic macrofaunal recovery rates were reported (from Wilber & Clarke 2007)

Site Region Depth(m) Sediment Type CH1 Mech2

Recovery Time3 Metric4

Reference

Open

Water

Disposal

Sites

New S. Wales, Australia Temperate 6 Fine sand N A 3 months U/M Smith & Rule 2001 Gulfport, MS, US Temperate 3 Silt and clay Y A 1 year U/M Wilber et al. in press Corpus Christi, TX, US Temperate 3 Silt and clay N L/A < 1 year U/M Ray & Clarke 1999 South Carolina, US Temperate 13 Fine sand Y Un N/A U/M Zimmerman et al. 2003 Coastal Louisiana, US Temperate 3 Silt and clay N Un 5 months U/M Flemer et al. 1997 Sewee Bay, SC, US Temperate 3 Silt and clay Y A 6 months U/M Van Dolah et al. 1979 Dawho River, SC, US Temperate <5 Silt and clay Y A 3 months U/M Van Dolah et al. 1984 Delaware Bay, US Temperate Shallow Silt and clay N Un >5 months U Leathem et al. 1973 Queensland, Australia Sub-Tropical 11 Silt and clay Y A 3 months U/M Cruz-Motta & Collins 2004 New S. Wales, Australia Temperate Shallow Silt, clay, sand N A 1 month U Jones 1986 Mobile Bay, AL, US Temperate 3 Mud N A 3 months U Clarke & Miller-Way 1992 Oregon, US Temperate 8 Silt and clay N A 1 month U McCauley et al. 1977 Mirs Bay, Hong Kong Sub-Tropical 19 Sand and gravel Y Un < 2 years U/M Valente et al. 1999 Quebec, Canada Cold 55 Fine sand Y L/A > 2 years U/M Harvey et al. 1998 Port Valdez, Alaska Cold 15-23 Mud N L > 2.5 years U/M Blanchard & Feder 2003 Puget Sound, WA Cold 60 Silt, clay, sand N A > 9 months U Bingham 1978 Western Baltic Sea Cold 19 Fine sand N A < 2 years U/M Powilleit et al. 2006 Liverpool Bay, UK Cold 10 Sand and mud N Un N/A U/M Rees et al. 1992 Weser estuary, Germany Cold 16 Silt and sand Y Un > 8 months U/M Witt et al. 2004 James River, VA Temperate 3 Fluid mud N L/A 3 months U Diaz & Boesch 1977, Diaz 1994 Columbia River, OR Cold Shallow Fine sand, clay N L/A >10 months U Richardson et al. 1977 Southern Brazil Temperate 19 Silt, clay, fine sand Y A < 9 months U/M Angonesi et al. 2006

Dredging -

Site

Channels

Sewee Bay, SC, US Temperate 4 Silt and clay Y A 6 months U/M Van Dolah et al. 1979 Dawho River, SC, US Temperate 4 Silt and clay N A 3 months U Van Dolah et al. 1984 Georgia, US Temperate Shallow Silt and clay N A 3 months U Stickney & Perlmutter 1975 Oregon, US Temperate 11 Silt and clay N A 1 month U McCauley et al. 1977 Delaware Bay, US Temperate Shallow Silt and clay N Un >5 months U Leathem et al. 1973 Sardinia, Italy Temperate 15-20 Silt and clay N A ~ 6 months U Pagliai et al. 1985 Ceuta, North Africa Temperate 3 Silt and clay Y L/A 6 months U/M Guerra-Garcia et al. 2003 New South Wales, Australia Temperate Shallow Silt, clay, sand N A 1 month U Jones 1986 Queensland, Australia Temperate 17 Medium/fine sand N Un N/A U Poiner & Kennedy 1984 Southwest Finland Cold 9 Mud N L/A 2-5 years U Bonsdorff 1980, 1983 Long Island, NY Temperate 2 Sand, silt, clay Y A > 11 months U Kaplan et al. 1975 Algeciras Bay, Spain Temperate 5,15,30 Fine sand N L/A 4 years U/M Sanchez-Moyano et al. 2004



Yaquina Bay, OR Cold 6-11 Fine sand, silt Y L/A 1 year U/M Swartz et al. 1980 North Sea, UK Cold 9 Silt and clay N A > 3 months U/M Quigley & Hall 1999 Southern Brazil Temperate 3-18 Silt, clay, sand Y Un > 3 months U/M Bemvenuti et al. 2005

Dredging

Site -

Aggregate

Mining

Nome, AK Cold 9-20 Sand, cobble Y Un 4 years U/M Jewett et al. 1999 Southeast coast, England Cold 27-35 Sand, gravel Y L 2-4 years U/M Boyd et al. 2004 South coast of U.K. Cold 10-20 Sand, mud, gravel N Un 2-3 years U/M Newell et al. 2004 Eastern English Channel Cold 15 Gravel Y Un > 28 months U Desprez 2000 Southern Baltic Sea Cold 10-14 Sand Y Un > 10 years U/M Szymelfenig et al. 2006. Southern North Sea Cold 25 Sand, gravel Y L > 2 years U/M Kenny and Rees 1996 Botany Bay, Australia Temperate 14-18 Mud Y L > 1 year U/M Fraser et al. 2006

Capping Hong Kong, China Sub-Tropical 5-6 Mud N L 3 years U/M Qian et al. 2003



Prevailing energy regime 12.4.3

Locations that experience relatively frequent wave, wind, and current induced disturbances, are typically inhabited by low-diversity, “r-selected” benthic assemblages (fast-growing, small, opportunistic) that can readily re-establish themselves under conditions of high frequency disturbances. These communities are naturally held in early successional stages and therefore are able to recover more rapidly than communities in more stable less-disturbed environments. Marine organisms in high energy areas such as STB are thus generally adapted to sediment disturbance as a consequence of frequent storms that pass through the area.

The generally accepted benthic successional paradigm states that following initial decreases to benthic diversity, abundance, and biomass that immediately follow a disturbance, pioneering (Stage I) organisms, such as small, tube-dwelling polychaetes and small bivalves colonise the surficial sediments. These opportunistic taxa occur in relatively high abundances and low diversity and over time are replaced by larger, longer-lived and deeper-burrowing (Stage II) species. The Stage III assemblage is comprised of a more diverse but less abundant group of larger taxa such as maldanid polychaetes.

A benthic community dominated by early successional stages is evident in the TTR extraction area, with the key species being the polychaete worms Euchone sp. A., Aricidea sp. and the cirolanid isopod Pseudaega spp. (Section 6.10.1 of this IA).

Sediment Extraction and Replacement Methodology 12.4.4

Re-colonisation of de-faunated dredged areas may occur from adults migrating from adjacent relatively undisturbed areas, or from larval recruitment from nearby areas and those more distant. Rapid recolonisation of unconsolidated sediments in dredged channels has been attributed to slumping of non-dredged sediments into the dredged furrows, thus transporting benthic infauna.

The spatial scale of the dredged or disposal area may proportionally influence recovery times, particularly in relation to migration. For small-scale disturbances, the edge/surface area ratio of the disturbed area is larger than for larger disturbances, therefore colonisation through adult immigration from surrounding undisturbed areas may facilitate more rapid recovery. With larger disturbed areas, the central portion of the disturbed areas is reliant upon settlement from the water column for colonisation which may be dependent on seasonal recruitment patterns and local hydrodynamics. One particular study (Guerra-Garcia et al. 2003) demonstrated a log-linear relationship between recovery times and spatial scale using 14 studies of recovery at dredging and disposal sites. For instance, recovery in small patches (1,000 m2) took 7 months, whereas recovery was projected to require years at spatial scales of 10,000 m2 and above.

Marine aggregate mining operations along the eastern and southern English coastlines results in saucer-shaped depressions 8-10 m deep depending on the scale of the dredging operation, frequency of dredging, degree to which sediments are changed, hydrodynamics and the general nature of the habitat. In this instance, full restoration of benthic communities on the sandy, coarse gravel substrate occurred within approximately 2-4 years following the cessation of dredging.

In the US, dredging sand for beach nourishment typically results in either the creation of relatively shallow pits that are refilled by sand movement and are rapidly recolonised by opportunistic infauna, or the creation of deeper pits that become depositional areas where fine sediments accumulate and sand-associated assemblages are replaced by soft-bottom fauna. If borrow pits are deep enough that water circulation is restricted, hypoxic or anoxic conditions may result in a depauperate infaunal community. Recovery of infaunal abundance, diversity and community composition in New Jersey occurred in one year, whereas the return of biomass to reference conditions took 1.5 to 2.5 years. In Florida, relatively rapid recovery (~1 year) was reported for borrow areas



when measured in terms of total abundance and taxonomic diversity, however, recovery times of up to three years were needed to restore functional groups, such as deposit feeders and mid-depth burrowers.

In relation to the Port of Otago dredging project James et al. (2009) predicted that the highly mobile sand habitat near the entrance the harbour would likely recover from dredging disturbance through dispersion of larvae and bed transport.

TTRs extraction process involves use of a Crawler to cut 10 m ‘lanes’ and replacement of de-ored sediment into adjacent areas. This should facilitate recovery from areas close proximity. The narrowness of these extraction and deposition ‘lanes’ will likely assist quicker recolonisation process than if for example extraction was undertaken over a large area, with de-ored sand disposal occurring some time later.

The proposed extraction methodology will also increase the opportunity for rapid recolonisation as a result of the cross-current orientation of the narrow dredging “lanes”.

In addition individual “lanes” will be subject to continuous extraction and backfilling such that the maximum area of disturbance at any one time will be only 300 m x 300 m. Once the area is backfilled it will be available for recolonisation.

Sediment Type 12.4.5

Rapid recolonisation of soft-bottom benthic habitats is frequently associated with either unconsolidated fine grain sediments or the rapid dispersion of fine-grained dredged material by currents. Typical recovery times of 1-3 years have been documented for coarser sand and gravel substrata.

James et al. (2009) commented that, in relation to the Port of Otago dredging’s disposal site, recovery is fastest when dredged and spoil sediments are well matched (i.e., similar gain size). Once disposal ceases, recovery could take up to a year for early pioneering species and several years for large animals. In sandy locations of the dredging area recovery is likely to be medium term (1-5 years).

Monitoring undertaken in Tasman Bay for the Port of Nelson dredging disposal programme indicates that the site has been permanently altered to a sandier substrate and very rapid rates of recovery have been observed (4-6 months) (R Sneddon, Cawthron Institute pers. com.).

Existing surficial sediments in the extraction area are typically medium to fine sands (150-500 µm. Finer material has been “winnowed” out because of re-working by wave activity.

TTRs extraction process collects all sediments, processes it to remove magnetite and then passes residual sediments through hydro-cyclones to strip out fine particles (most of which arise from the milling process on the FPSO). The de-ored sand deposited back to the seabed will have a similar particle size distribution to that present on the seabed surface prior to extraction. Therefore particle size will be very similar post deposition and change in particle size should not in itself pose an impediment to recolonisation.

Timing of disturbance activities 12.4.6

For the Port Otago dredging project James et al. (2009) commented that populations would be less vulnerable if dredging took place in winter as although there may be continual or pulses of recruitment during the year the majority of benthic recruits are likely to settle in the warmer months (spring/summer) (Roper et al. 1992, NIWA, unpublished data).

TTR’s anticipated excavation rate is around 4-5 hours for each 300 m x 10 m excavation “lane” will mean that the extraction and deposition impact at each site will be of very



short duration, meaning that there will be on-going opportunity for recovery on a continuous basis throughout the year.

‘Near’ and ‘far’-field recovery from sediment deposition 12.4.7

Some benthic organisms such as burrowing polychaetes, amphipods and molluscs can colonise newly deposited sediments through vertical migration, therefore, if deposited sediment depths are within the vertical migration capacity of these organisms (20-30 cm), recovery rates may be quicker than if colonisation is dependent upon the lateral migration of juveniles and adults from adjacent areas and larval settlement. Successful vertical migration through 15 cm of sediments occurred for benthic infauna in Auckland, NZ and mud snails in Delaware Bay. Successful movements through up to 32 cm have been documented for polychaetes and bivalves. The amount of the deposit and the frequency of deposition are interactive factors affecting vertical migration for nematodes.

Vertical migration of juveniles and adults through the deposited sediments is also thought to contribute to relatively quick recovery rates in areas with shallow deposits.

The nature of deposited sediments can have a bearing on ability for recolonisation. For example experiments with clay deposits in an Auckland estuary demonstrated that clay layers as thin as 0.3 to 0.7 cm had some impact on macrofauna, but are relatively short-term. Rapid accumulations of fine sediments on the other hand (over 2 cm in one event) were found to smother entire benthic communities. In these situations (which will differ on a case-by-case basis), recovery of sediment properties and benthic communities was found to take a few months for opportunistic species like many polychaete worms and several months to a few years for larger taxa like some gastropod molluscs.

The re-deposited de-ored sands from the TTR project will not contain clays such as those noted above. The de-ored sediments will have a very similar particle size distribution to the ambient seabed, with the removal of iron being the only significant difference. Accordingly, recovery should occur within the timeframes noted.

In the immediate deposition area the thickness of de-ored sand will be of the order of 4-5 m, so upward movement of biota is unlikely. However, the offsite deposition of material in the nearfield and farfield areas has been modelled by NIWA to be in the order of 1 mm. Impacts on benthic communities away from the extraction area and immediate deposition area therefore likely to be minimal, thus presenting an on-going source for recolonisation of the surficial layers of the impact zone.

Consideration of TTR Effects on Potential Larval Settlement Behaviour 12.4.8

Recolonisation of disturbed sediments by benthic invertebrates is dependent on a variety of factors, including the nature and extent of nearby communities (potential source populations), the physical structure of the seabed and environmental factors such as light, temperature and currents, among others.

The seabed within the TTR extraction and re-deposition area is considered to be a dynamic environment. This environment is continually being disturbed by the prevailing waves and currents, as well as by moderately frequent storm events, in which the oscillatory currents at the seabed will approach 1 m/s. Populations of organism living within this environment must be either fully mobile or, if not, capable of rapid recolonisation following disturbance. Such rapidly colonising species are referred to as ‘r’-selected or opportunistic species. The main sessile species that are present in the TTR extraction and re-deposition area are such opportunists, frequently among the first organisms to colonise a disturbed area.

Although the effects of the proposed activities on larval settlement and recolonisation are not categorically defined, a number of generalisations may be made which describe the key environmental drivers of settlement and recolonisation. Typically,



macroinvertebrate larvae preferentially select appropriate chemical cues present on the substrates on which to settle and grow. Such cues may be comprised of the metabolites of extant species in the area, specific bacterial flora or simply the presence of foodstuffs (either grazed or prey species), among other things.

The processes involved in extracting the ore from the seabed and dewatering the sands will result in removal of the existing cues upon which benthic macrorganisms settle. The dewatered sand that is deposited into the furrows on the seabed will, however, be subject to the same natural processes of succession that govern colonisation of any artificial structure in the marine environment. These processes proceed in the following manner:

1. Deposition of the dewatered sand into the dredge furrows;

2. Rapid colonisation of the surficial sediments by bacteria, microphytobenthos and mobile epifaunal (e.g. polychaete worms); this will begin almost immediately upon settling of the sediments on the seafloor;

3. Continued winnowing of the surficial sediments by the extant physical processes (currents, waves, storm events);

4. Colonisation of winnowed sediments by short lived, r-selected (opportunistic) species living in the vicinity; this will typically occur within 1-2 generations (on a scale of months to years);

5. Continued colonisation by opportunists with increasing levels of larval settlement by longer lived species; and,

6. Displacement of the opportunistic species by longer lived taxa.

The biological communities present within the TTR extraction and re-deposition area are relatively depauperate, heavily dominated by short lived, opportunistic species (e.g. sabellid and paraonid polychaetes, isopods). The absence of longer-lived taxa is indicative of a highly disturbed environment. On this basis, it is considered that larval settlement and recruitment processes onto the dewatered sand that is deposited into the furrows will occur in a similar fashion and timescale as on the natural seabed.

TTR’s process involving extraction in narrow strips, and replacement of de-ored sediment into immediately adjacent areas, and avoiding exposure of extremely large worked-over areas will facilitate recovery, particularly in view of the cross-current orientation of the narrow dredging “lanes”. Once an area is backfilled it will be available for recolonisation.

In general, after an initial disturbance to seabeds such as in the STB, “pioneering” organisms, such as small, tube-dwelling polychaetes and small bivalves colonise the surficial sediments. These opportunistic taxa occur in relatively high abundances and low diversity and over time are replaced by larger, longer-lived and deeper-burrowing species. TTR’s extraction area is currently dominated by opportunistic or early successional species such as the polychaetes Euchone sp and Aricidea sp. This characteristic will facilitate early recolonisation.

The de-ored sand discharged back to the seabed will have a similar particle size distribution to that present on the seabed prior to extraction. It is therefore not considered that changes in grain size would pose any impediments to recolonisation.

Although TTR plans to extract year round, timing in relation to larval recruitment is not expected to be significant due to the scale of the Project area relative to the broader STB, and the long term nature of the Project. TTR’s anticipated excavation rate is around 4-5 hours for each 300 m x 10 m excavation “lane”, followed by deposition over a similar timeframe, albeit separated by around 5-10 days. Overall impacts due to extraction and deposition activities at each site will be of relatively short duration, meaning that there will be ongoing opportunity for recovery on a continuous basis throughout the year.

The TTR Project de-ored sands will not contain clays which have been found elsewhere to inhibit re-colonisation. Offsite deposition of material (nearfield and farfield) has been



predicted to be in the order of 1 mm. Impacts on benthic communities away from the extraction area and immediate deposition area therefore likely to be minimal, thus presenting an on-going source for recolonisation of the surficial layers of the impact zone.

Re-colonisation references are included in Appendix 9.

Summary and Conclusions 12.4.9

Recolonisation of the seabed post disturbance is expected to be relatively rapid. Mobile organisms (e.g. Opalfish, Scallops, and some polychaete worms) will be capable of moving back into the area immediately post-disturbance.

The extant benthic communities within the TTR extraction and re-deposition area are dominated by both sessile suspension and motile deposit feeding polychaetes, with two species comprising over 40% of individual abundance in the collected samples. Currently the timing and frequency of natural reproduction and recruitment by these numerically dominant benthic taxa (the polychaetes Euchone sp and Aricidea sp (each ~20%) and the cirolanid isopod Pseudaega sp (10%)) is unknown. ‘R’ selected or early successional taxa such as these, however, typically colonise disturbed environments, generally have short generation times and multiple reproductive periods per life cycle, facilitating rapid recruitment.

Although these organisms will be removed from the processed sediments, the approach to extraction in 10 m wide lanes, with re-deposition of de-ored sediment, will provide undisturbed source populations in very close proximity, permitting rapid natural recolonisation within a few generations. It is expected that the mobile polychaetes will immediately begin to recolonise the disturbed area following re-deposition of the de-ored sediment.

In addition and given the natural disturbance history of the seabed in this high energy environment, it is considered that nearby populations of will serve as sources for new recruits, both through natural movements/migration of mobile adults and reproductive processes. It is expected that the mobile polychaetes and isopod populations will rapidly redistribute themselves across the deposited sediments.

Overall, recolonisation of the de-ored sediments by local organisms is expected to occur very rapidly, with full recovery expected on a scale of months to years.

Effects on Offshore Biogenic Habitats

Community Description 12.5.1

The benthic habitats offshore of the TTR extraction and re-deposition area are comprised of both bryozoan and shellfish dominated communities. Both these communities are characterised by the presence of shell debris and other potentially biogenic material.

The ‘bryozoan rubble’ habitats are found predominantly in waters of greater than 60 m depth, while the ‘bivalve rubble’ habitats (dominated by the dog cockle Tucetona laticostata) are found primarily in shallower waters (NIWA 2013a).

The spatial location of the Tucetona bivalve populations appears to be temporally stable, and along with considerable shell debris forms a dominant biogenic habitat above 60 m depth; this biogenic debris (the ‘bivalve rubble’) supports a range of early successional stage colonisers (‘r’–selected species). This is indicative of a high energy habitat.

In contrast, the shell debris below 60 m (the ‘bryozoan rubble’) is heavily encrusted with late stage colonisers, dominated by branching bryozoans. These, along with a wide variety of other sessile suspension-feeding invertebrates, collectively bind and stabilise the shell debris, providing further structural refuge for a diverse array of motile species (NIWA 2013a).



Total abundance and species richness were both significantly higher in these deeper biogenic habitats, than in the comparatively depauperate mid-shelf (TTR extraction and re-deposition area and adjacent areas) and inner shelf habitats - with the exception of rocky outcrops. Total abundance and species richness was also higher in the later-stage bryozoan/rubble habitat compared to the more poorly colonised shell debris of the bivalve beds. Further offshore (>80 m), the biogenic zone became less abundant.

Potential Effects 12.5.2

As the physical, direct impact of TTR’s activities occurs within the TTR extraction and re-deposition area, the potential for these communities offshore of that area to be affected depends upon the likelihood for the sediments disturbed by the activities to be redistributed over the areas of interest.

NIWA (2013j) describes modelling of predicted suspended sediment levels over the wider STB under scenarios of active dredging and re-deposition of de-ored sediment. Models focussed on predicting likely suspended solids concentrations (SSC) near both the water’s surface and the seabed (see Section 11.5 of this IA). In neither scenario does the expected SSC change markedly over the areas occupied by the biogenic habitats. Deposition modelling similarly predicts that the potential for accumulation of sediments on the seabed over the biogenic habitats is very low.

Overall it is considered that the potential for effects related to TTRs activities on the offshore biogenic habitats is very low.

Ecological Effects of Unplanned Events

Potential effects of unplanned events arise from biofouling (introduction of non-indigenous species) and from spills. Ecological implications of each are reviewed as follows.

Biofouling

As noted in Section 2.19.4.3 of this IA, vessel biofouling refers to the organisms carried by vessels on both the external surfaces of their hull(s) and also within their internal seawater systems. These organisms can be problematic if introduced to new ecosystems. Once established in new localities such organisms are termed non-indigenous species (NIS).

If NIS successfully become established by colonising the marine environment after release in New Zealand waters, and subsequently developing to form viable self-sustaining populations, they can spread domestically, both by natural dispersal mechanisms and by anthropogenic transport pathways such as vessel movements and aquaculture transfers among regions.

After establishment, some NIS proliferate in new environments, and may cause (or be perceived to cause) adverse effects. Such species tend to get described as “marine pests”. The issue of marine pest introduction and spread is generally regarded as an important one, not only because of the range of values at risk, but also because, once introduced, NIS usually become permanently established (i.e. their effects are irreversible).

The colonisation and growth of such organisms is typically controlled through both the application of fouling control or release coatings (‘antifouling paints’) to the external surfaces of the vessel as well as a variety of ‘approved’ active and passive systems for controlling fouling of internal systems. TTR considers that the appriate approach to mitigating potential biofouling effects is by use of appropriate biofouling management measures as set out in section 4.5.3 of this IA.

Spills

The potential ecological effects of spills relate to the ecotoxic characteristics of spilt material and in the case of oil spills, to physical smothering of mobile and sessile marine biota.



The Kupe Platform is located immediately adjacent to, and slightly to the north of, the TTR operational area. Oil spill trajectory modelling in relation to the Kupe Platform has been reported by the Taranaki Regional Council87 showing that there is a very low probability that oil spilt from the vicinity of the platform would beach in coastal regions beyond the zone from Cape Egmont to Porirua. Exceptions identified were D’Urville Island and the outer margins of Marlborough Sounds. Travel times identified for the spilled oil to beach range from a minimum time of 27 hours (Patea) to a maximum averaged time of 1672 hours (near Wellington). In spring (September – November) the highest beaching probabilities are along the Manawatu coast; in autumn (March – May) the highest beaching probabilities are along the Manawatu coast; in winter (June – August) the highest probabilities of beaching are along the South Taranaki / Patea coast; and in summer (December –February) the predicted impacts are approximately equivalent for the coastline from South Taranaki to the Manawatu coast.

TTR’s HAZID concluded that potential oil spill effects would be of moderate environmental risk primarily as a consequence of the potential dispersion characteristics of spilt HFO, and the ecological sensitivity of the nearfield ecotype which is identified as the Traps (more than 20 km distant, and submerged).

A comprehensive Spill Contingency Plan will be prepared as required by Maritime New Zealand. TTR considers that such an approach will address the risks of spills and associated mitigation measures necessary to reduce residual spill ecological risk levels to as low as reasonably practicable.

Effects of Low Environmental Risk

The effects listed in Table 37 were considered to be of low environmental risk. Each effect is discussed separately.

Table 37: Effects of Low Environmental Risk

Environmental Effects and Risk Analysis (Low Environmental Risk)

a. Antifouling

Impact on pelagic organisms TTR vessels arriving in New Zealand will be required to comply with the IMO Biofouling Guidelines 2011 to minimise the transfer of invasive aquatic species’. Only three major vessels will be on-station for TTR, compared with the high level of vessel traffic in the STB (Section 6.17). Considered to be very low to zero risk. The new build vessels to be stationed offshore will all be coated in IMO-compliant antifouling/fouling release coatings. The presence of the vessels stationed offshore in this sense would be no better or worse than ships waiting to enter harbour which occurs regularly around most New Zealand ports.

b. Mooring Blocks and Structures

Impact on the benthos Considered to be low risk. The anchor deployment for the FPSO involves installation of 4 standard Stevpris-type anchors, each attached by anchor chain and 90 mm diameter, tensioned steel cables directly to the FPSO. The anchors are moved in the course of the Crawler extraction programme (Section 2.7.4), but other than the direct disturbance caused by the anchor placement, removal and re-deployment, the anchor system will have only a limited range of sweep when used in extraction mode and will have lesser environmental effect than conventional anchoring with 360 degree sweep. Furthermore anchor deployment will be largely on areas

87 Taranaki Marine Oil Spill Contingency Plan - published 2012 – see: http://www.trc.govt.nz/marine-oil-spill-contingency-plan-2/




which will be or have been subject to extraction and re-deposition so that effects of anchoring will be minor relative to the impact of those activities. The Crawler will manoeuvre on the seabed using two hydraulic-driven tracks. This will cause seabed compression and will affect marine biota immediately under the tracks, but these effects will not be significant in comparison with the extraction process.

c. Extraction of sand from the seabed, including grade control drilling

Grade control drilling effects considered to be low risk. The surface area affected by grade control drilling will be no more than 0.05 m2 per drill with the rig footprint occupying around 4 m2. This area is minimal in comparison with the anticipated extraction area. Accordingly, no additional adverse effects are anticipated in relation to grade control drilling.

Water chemistry changes Section 6.8 presents the results of the chemical analysis of STB sands to be extracted. In summary, for all trace metals except nickel, the concentrations in standard elutriate extracts of sediment core samples were either below the detection limits (chromium, copper, lead, zinc) or, if the metal was detected (cadmium, zinc), concentrations were below ANZECC & ARMCANZ water quality trigger values for the protection of 99% of species. Elutriate extracts of deeper and surface sediments from three of the five sites contained nickel at concentrations that exceeded the ANZECC & ARMCANZ water quality trigger concentrations for the protection of 99% of species. However, nickel concentrations in elutriate extracts did not exceed ANZECC & ARMCANZ water quality trigger values for the protection of 95% of species. However, additional analyses of sediment slurries collected at one-metre increments to a maximum sediment depth of 18 m in mining areas Diana and Christina did not show evidence of such a trend. AUT found no consistent increase with depth in the concentrations of dissolved nickel. The concentrations of chromium were below the detection limits of the analysis. Based on these results, AUT inferred a low probability of adverse effects of sediment re-suspension on pelagic biota.

Impact on demersal fish There is likely to be a minor and highly localised impact on demersal fish from sediment extraction. Most species would be mobile enough to swim away from the areas of disturbance. A number of species would be attracted to this as a source of displaced food and advice could be sought as to the likelihood of mobile fishes to swim against currents developed by the extraction head. The loss of feeding area is also not likely to be significant as the extraction process operates in a sequential harvesting manner. To some extent this activity is also linked to the return of de-ored sediment. Overall, given there are no endangered species in the region and that the region does not support fish nursery or extensive feeding grounds, the effects are likely to be negligible. Snapper and a range of other fish might use the STB for spawning, but the area is not reported as a high value snapper spawning area. Any effects on spawning by snapper (or other demersal fish) would be likely to be minor, given the relatively small scale of TTR’s activities in the context of the broader area of the STB. Although nothing is known of the use of the STB by diadromous (freshwater migratory) fish such as lamprey, eels and whitebait, these




fish are adapted to living in turbid freshwater systems and it is considered unlikely that the SSC elevations arising from TTR’s operations would adversely affect such fish – either in the adult form or the larval form.

d. De-Ored sand re-deposition and cyclone overflow sediment

Impact on rocky reefs due to choking (smothering)

‘Choking’ is a term that conveys smothering, respiration limiting (gill clogging) and similar or related effects on target organisms. This impact specifically focuses on rocky reef communities in the vicinity of the excavated seabed (downstream by prevailing currents of the project site). The risk to the habitat in terms of recovery and its component species is viewed as low with a high level of confidence as the rocky reef areas in this region are distant from TTR’s extraction area, and they are already pre-disposed to high sedimentary regimes. No rare species are known, indeed the community composition is indicative of an assemblage that is robust to high sedimentation events and regular storm driven disturbance. Ecosystem functioning will be only marginally affected and the proportion of the habitat available in the region that is likely to be influenced by project sediments is relatively low.

Impact on rocky reefs due to light reduction

Optical property effects of nearshore reefs are indistinguishable from the natural or background pattern. Algae present on nearshore rocky reefs will not be adversely impacted through loss of light.

Impact on nearshore sand due to deposition

The effects of sediment plumes and any mobile re-dispersed benthic de-ored sediment on nearshore sedimentary systems is viewed as being negligible against the backdrop of significant sedimentation from local rivers. A high degree of confidence is listed in this assessment

Impact on nearshore sand due to choking

The effects of sediment plumes and any mobile re-dispersed benthic de-ored sediment on nearshore sedimentary systems is viewed as being negligible against the backdrop of significant sedimentation from local rivers. A high degree of confidence is listed in this assessment

Impact on benthic algae Benthic algae occur on nearshore reef structures. Optical property effects of nearshore reefs are indistinguishable from the natural or background pattern. Algae present on nearshore rocky reefs will not be adversely impacted through loss of light.

Impact on offshore biogenic habitat due to deposition

This is viewed as low risk with high confidence in that assessment. The assessment is based on the prediction that plume and any mobile de-ored sediment will move in a SE/NW direction and not reach the bryozoans beds deeper down the slope. The assessment is based on the ACDP information (2 m above the seabed) and modelling.

Impact on algae in offshore biogenic habitats due to light reduction

There are signs of red algae on these deeper reef systems. This is viewed as low risk with high confidence in that assessment. The assessment is based on the prediction that plume and any mobile de-ored sediment will move in a SE/NW direction and no reach the bryozoan beds deeper down the slope. The assessment is based on the ACDP information (2 m above the seabed) and modelling

Change in water chemistry No discharges of any chemicals from the vessels during processing. High salinity water is likely to be produced, and it is assumed that this will be very quickly diluted

Change in porewater A low likelihood of adverse effect given metal concentrations




chemistry/dynamics assessed in seabed sediments and in discharges.

Offshore shading effects This effect was scored as low risk with high certainty due to the fact that there is little algal life in the deeper reef systems and that which is present is predisposed to turbid conditions.

Offshore UW visibility effects Again this was scored as low risk with high confidence based on modelling of the plume direction (away from these deeper reef systems).

Offshore effects on aerial predators Again this was scored as low risk with high confidence based on modelling of the plume direction (away from these deeper reef systems).

Offshore pelagic choking Again this was scored as low risk with high confidence based on modelling of the plume direction (away from these deeper reef systems).

Midshore shading effects This was scored as low to moderate risk with high confidence as the habitats midshore are already characterised by turbid conditions and the modelling suggests that this will not be significantly worsened.

Midshore u/w visibility effects This was scored as low to moderate risk with high confidence as the habitats midshore are already characterised by turbid conditions and the modelling suggests that this will not be significantly worsened. (Refer literature on visibility).

Midshore effect on aerial predators This was scored as low to moderate risk with high confidence as the habitats midshore are already characterised by turbid conditions and the modelling suggests that this will not be significantly worsened. (Refer literature on visibility). In addition, the extend of marine bird populations in this region is considered to be relatively low

Midshore pelagic choking This was scored as low to moderate risk with high confidence as the habitats midshore are already characterised by turbid conditions and the modelling suggests that this will not be significantly worsened.

Nearshore shading effects This was scored as low to moderate risk with high confidence as the habitats nearshore are already characterised by turbid conditions and the modelling suggests that this will not be significantly worsened.

Nearshore u/w visibility effects This was scored as low to moderate risk with high confidence as the habitats nearshore are already characterised by turbid conditions and the modelling suggests that this will not be significantly worsened

Nearshore effect on aerial predators This was scored as low to moderate risk with high confidence as the habitats nearshore are already characterised by turbid conditions and the modelling suggests that this will not be significantly worsened. (Refer literature on visibility). In addition, the extent of marine bird populations in this region is considered to be relatively low.

Nearshore choking This was scored as low to moderate risk with high confidence as the habitats nearshore are already characterised by turbid conditions and the modelling suggests that this will not be significantly worsened.

e. Effects of FPSO operations – presence, u/w noise and vibrations

It is recognised that vessels such as the FPSO can act as a Fish Aggregating Device (FAD). Past experience by existiong operators of FPSO activities in the offshore Taranaki Region indicates that the TTR FPSO will provide a potentially significant FAD habitat for pelagic fish. The combination of the navigational safety buffer zone and the presence of the hull will potentially act as a de-facto marine reserve, providing a supply of pelagic fish to the wider area.

Acoustic impact on marine mammals, reptiles, fish and invertebrates

This was considered to be of low to negligible risk given the relative paucity of marine mammals and other species that could possibly be influenced by noise in the region. As indicated above, the effects are




likely to be similar to those emitted from ships anchored and awaiting entry to ports.

f. Release of dissolved material ex pore water

A low likelihood of adverse effect given metal concentrations assessed in seabed sediments and in discharges.

g. Ship to ship ore transfer

Impact normal operation on pelagic organisms

The process of transfer of concentrate from the FPSO and the FSO does not involve any operational discharges. The conveyor/slurry methodology is enclosed, with TTR’s primary focus on retaining the concentrate. In the event of an inadvertent spillage, TTR procedures will ensure that transfer ceases immediately. Any concentrate entering the sea will fall to the seabed as a consequence of its bulk density, and will not result in an adverse environmental effect other than possible burying of organisms in the immediate area of deposition. Any such spillage will be of short duration and such adverse effects are anticipated to be transient. Negligible risk including spills due to dilution.

Impact normal operation on benthos The process of fuel transfer to the FPSO and the FSO does not involve any operational discharges. TTR’s primary focus will be on avoiding spillage. Transfer methods are discussed in Section 2.17. Negligible risk including spills due to dilution.

h. Ship to ship fuel transfer

Impact normal operation on pelagic organisms

Negligible risk including spills due to dilution. Oil spill contingency plan.

Impact normal operation on benthos Negligible risk including spills due to dilution. Oil spill contingency plan.

i. Brine discharge

Impact on pelagic organisms Process outputs from the RO plant are freshwater and brine. Brine will be co-disposed with the hydro-cyclone overflow. It is estimated in Section 2.12.6 of this IA that the hydro-cyclone overflow salinity will be marginally changed from a nominal 35 ppt to around 37 ppt. This very minor change in salinity will rapidly be assimilated with ambient salinity and will not result in any adverse environmental effect. Negligible risk due to dilution.

j. Cyclone overflow

Impact on pelagic organisms Information on the hydro-cyclone overflow is set out in Sections 2.10.1 and 2.11 of this IA. In broad terms around 48% of the overflow water from the “coarse” hydro-cyclones along with all of the overflow water from the “fine” hydro-cyclones will discharge from a dedicated “hydro-cyclone overflow pipe” located on the de-ored sand deposition pipe, at a nominal height of 2 m above the de-ored sand outlet. The effects of this discharge on suspended sediment concentrations are evaluated in detail in Section 11.5 of this IA. Aquatic chemistry effects are addressed as follows. A copper concentration of up to 8.1 ppb was determined in elutriate from processed ore. In practice, the copper concentration would be reduced below the 8.1 ppb level prior to discharge due to a 1:1 mixing with process water, resulting in a “discharge concentration of around 4 ppb. Following discharge into the South Taranaki Bight waters (assuming 0.25 ppb copper in seawater), an 85-fold dilution




would decrease the highest measured average copper concentration to below the highly conservative ANZEC 99% Guideline value of 0.3 ppb (or the more commonly accepted 95% ANZECC Protection Trigger Value of 1.3 ppb (requiring a dilution of slightly more than 3-fold). This would be readily achievable based on the factors outlined in Section 11.5.5. TTR will monitor dissolved concentrations of copper and other trace metals in the beneficiation plant discharge to verify compliance with ANZECC & ARMCANZ guidelines. However, overall it is concluded that there will be negligible risk as a result of dilution.

k. Reverse osmosis chemical discharge

Impact on pelagic organisms Section 2.12.5 sets out information on the RO cleaning chemicals. Used CIP chemicals will be collected and retained for onshore disposal by approved contractors. Storage and handling of these chemicals on the FPSO will be managed to ensure safe practices consistent with requirements under health and safety and hazardous substances legislation. There will be no discharge of RO treatment chemicals.

l. Discharge from hyperbaric filters

Impact on pelagic organisms Section 2.14.4 indicates that the HPF filtrate will comprise around 33,000 m3/day of freshwater, discharged by a pipe located 1 m below surface near the bow of the FSO. The potential effects of such a discharge are assessed in Section 11.5.5, and it is concluded that any effect in depressing salinity will not be significant. Section 6.8 provides detail in respect of potential contamination derived from the processed ore: a copper concentration of up to 8.1 ppb in the concentrate has been calculated. In practice, the copper concentration in the HPF discharge would be reduced below 8.1 ppb prior to discharge due to a 1:1 mixing with the RO freshwater water, resulting in a discharge concentration of around 4 ppb. Following discharge into the South Taranaki Bight waters (assuming 0.25 ppb copper in seawater), an 85-fold dilution would decrease the highest measured average copper concentration to below the highly conservative ANZECC 99% Guideline value of 0.3 ppb (or the more commonly accepted 95% ANZECC Protection Trigger Value is 1.3 ppb (requiring an approximate 3-fold dilution)). This would be readily achievable based on the factors outlined in Section 11.5.5. TTR will monitor dissolved concentrations of copper and other trace metals in the discharge to verify compliance with ANZECC & ARMCANZ guidelines. However, overall it is concluded that there will be negligible risk as a result of dilution.

m. Other ship discharges

Impact on pelagic organisms No discharge of sewage or garbage. No discharge of oily wastes other than in compliance with Marpol requirements. Risk assessed as low.

n. Air emissions

Impact on pelagic organisms N/A

o. Ship lighting

Seabird attract, disturb, collision Negligible risk due to shielded lighting systems, and experience with range of existing installations offshore from Taranaki.

Effects on squid Negligible risk due to shielded lighting systems – avoiding light spill




as far as practicable.

Effects on fish Negligible risk due to shielded lighting systems – avoiding light spill as far as practicable.

p. Vessel exclusion

Impact displaced fishing/fish stocks Negligible risk due to low level fisheries in the region.

q. Ship movements

Ship strikes on marine mammals Vessels mostly stationary apart from ore carrying ships. No significant difference from existing maritime traffic. Low level risk predicted with high confidence.

Effects of Lighting on Birds and Fish

Introduction

The FPSO and FSO will be illuminated for navigational, safety and operation purposes. There are two main factors to consider when assessing potential effects: visibility from other locations (evaluated in Section 11.7.3), and potential effects on seabirds.

Operational lighting on the ships will focus on operating areas on the deck of the FPSO and FSO to ensure a safe 24 hour working environment. Lighting will be designed to minimise light spill. However, a suitable level of lighting must be maintained to ensure the vessels are visible to passing marine vessels and also to safely conduct normal operations at night.

There is the potential, either positive or negative, for sea birds to interact with the FPSO, FSO and/or support vessels. A positive interaction would include the vessels providing loafing or perching opportunities that would not otherwise be available to birds on the open ocean, and this is known to occur particularly on slow-moving vessels and offshore installations. Negative interactions could include injury to birds through a collision with the vessels or becoming entangled in any rigging.

Evaluation of Likely Effects

NIWA (2013m) considered the effects of nocturnal artificial light on seabirds (along with fish and squid), taking into account the likely light regime on the TTR iron sand processing vessel.

The report concludes that overall, whilst artificial nocturnal light generally attracts all three groups of marine animals to a certain extent. The attractiveness of light is not universal across these marine species; for example, the majority of diurnally-active seabirds appear not to exhibit marked attraction to artificial light, whereas light can potentially be a problem for nocturnal species.

For fish and squid, the report concluded that any effects of TTR’s vessels as a source of artificial nocturnal light are likely to be very localised and centred on the vessels themselves, some species of both groups could potentially aggregate in the water column close to the vessel, but these effects are highly unlikely to have any measurable population level impact on the attracted species.

Similarly for seabirds NIWA (2013m) concluded that it is potentially possible that the vessel’s lights may attract nocturnal species, particularly in poor weather, but the remoteness of the area of operation from major seabird breeding colonies and relatively standard mitigation protocols would also suggest that any effect would be highly unlikely to have any measurable population level impact on the attracted seabird species.



Experience with Offshore Taranaki Operations

Investigations for the Taranaki offshore oil industry88 have shown that artificial lighting can cause disorientation in seabirds, mainly fledglings and novice flyers, particularly when the activity is nearshore.

Based on experience with the Taranaki offshore oil industry, collisions or entanglements during the day are unlikely as most seabirds are agile flyers with keen eyesight, and would be able to avoid collisions with TTR’s vessels. However, there is a risk of such collisions or entanglement at night, as birds may become disoriented or unable to identify the rigging in flight.

Based on reported information in the AWE Impact Assessment (AWE 2013), relating to a number of exploration drilling programmes undertaken in the offshore Taranaki area as well as on the Maui A and B platforms, which have been on location and operating since 1978 and 1992 respectively, there is no evidence of any adverse effects on seabirds.

Reportedly at the Tui FPSO, the only birds observed to have been landing on the facility are sparrows, swallows and finches which are believed to have been brought out by the workboats and Offtake Tankers visiting the FPSO. No collisions or deaths have been observed since the Tui FPSO has been onsite. At the Maui platforms, the most common birds observed landing on the facilities are pigeons, which are exhausted and use the platform to rest.

AWE (2013), reports that on average one bird is delivered to DOC Taranaki Area Office every three or four years from manned offshore installations, all of which have been alive. The birds have not been entangled in rigging but attracted to the lights and then disorientated, whereupon they get into the machinery spaces and get oil on their feathers. The birds were transported back to land via helicopter and sent to Massey University to have the light oiling removed from their feathers. All birds were then released into the wild from a boat off New Plymouth. Birds that have been delivered to DOC have included blue petrels, fairy prion and diving petrels.

Conclusions

Based on findings of NIWA (2013m) and reported experience in offshore from Taranaki, the risk of adverse effects on birdlife, fish and squid arising from the lighting on the FPSO and FSO is assessed as low. In accordance with usual practice, observations and recording of any incidents will be maintained. In the event that bird mortalities occur and are recorded, DOC will be informed immediately.

Effects on Marine Mammals

Introduction

The potential key effects of TTRs activities on cetaceans include the following matters each of which is addressed in further detail below.

Risk of collision with TTR vessels; and Loss of benthic habitat and fisheries resources

Noise effects are addressed in Section 11.8 of this IA.

88 AWE Limited (2013) “Taranaki Basin Exploration & Development Drilling 2013 AWE Limited”

Impact Assessment AWENZ-RPT-1304, REM Limited, 20th September 2013.



Collision Risk

Section 2.5 of the IA describes the vessels and machinery that will be involved in TTR’s operations. In summary, seabed material will be excavated using a crawler which will transfer extracted sediment to a FPSO, which will be moving at very low speeds, where extracted sediment will be processed into iron ore concentrate. Concentrated ore will then be transhipped to the FSO which will store and de-water the concentrate, and in turn trans-ship it to standard “Cape-size” export vessels.

Overall, given the low vessel speeds during excavation and the low number of operational vessels proposed (approximately four including an Anchor Handling Tug) in additional to those already using the STB, the additional risk to any cetaceans that may be present in the TTR extraction area is considered to be extremely low. In addition, as part of the EMP, observers stationed on the vessels will identify any cetaceans that are present during vessel movement and extraction activities.

Loss of Benthic Habitat and Fisheries Resources

Section 6.10 describes the benthic habitat and fisheries resources present in the TTR extraction area. In summary, no evidence was found to suggest that the Project Area was “unique” with respect to benthic fauna. In addition, the fish species likely to be found in the Project Area, and which would potentially form part of the diet of cetaceans, are common across the wider STB.

Overall, given the small proportion of habitat of the STB that will be disturbed in the Project Area, and the low density of cetaceans present, any potential effects are considered to be low.

Protection Matters Prescribed in the Act

Introduction

Section 59(2) of the EEZ Act requires the EPA to take account of the following matters when considering an application for a marine consent and submissions on an application. Each is discussed below.

(c) the importance of protecting the biological diversity and integrity of marine species, ecosystems, and processes; and

(d) the importance of protecting rare and vulnerable ecosystems and the habitats of threatened species

Protection of biological diversity

TTR’s operations will affect a relatively small area of the seabed within the STB. On an annual basis TTR’s extraction operations will disturb around 5% of the 65.76 km2

extraction area or 3.23 km2 (assuming a 20 year project life). This equates to less than 0.1% of the area of the STB out to 18 nm from the shore.

Given these ratios, the TTR operation is not considered to present any issues in respect of protection of biological diversity in the broader STB area notwithstanding localised effects in the extraction and immediate deposition areas.

Protection of rare and vulnerable ecosystems

No rare or vulnerable ecosystems or habitats of threatened species have been identified as being potentially affected by the TTR Project.



Summary of Ecological Effects

Table 38 summarises the effects on the ecological environment identified in relation to the TTR Project. In Section 15, detailed consideration is given to options to mitigate risks associated with TTR’s activities.




Table 38: Summary of “Pre-Mitigation” Ecological Effects

Activity Effects Risk Rating Mitigation Factors

Extraction/deposition Extraction of benthos at extraction site due to sand extraction, and smothering and burial from de-ored sand re-deposition. Direct impact on the habitat of the tubeworm Euchone sp. A

High Rapid recovery timeframes of the order of months to a few years (within lifetime of operation).

Extraction in narrow lanes, and replacement of de-ored sediment into immediately adjacent areas.

Avoiding extremely large worked-over areas to facilitate recovery. Cross-current orientation of the narrow dredging “lanes”. TTR’s extraction area is currently dominated by early successional species –

will facilitate early recolonisation. The de-ored sand discharged will have a similar particle size distribution to that

present on the seabed prior to extraction. TTR’s short-duration excavation rate will reduce extraction and deposition

impact at each site. Ongoing opportunity for continuous recovery throughout the year. Offsite deposition (nearfield and farfield) only in the order of 1 mm. Impacts on benthic communities away from the extraction area and immediate

deposition area therefore likely to be minimal - on-going source for recolonisation of the surficial layers of the impact zone.

Unplanned Events The potential for effects on native biodiversity is noted through the incidental translocation of non-indigenous marine species to the project site and around New Zealand; ecological effects of spills.

Moderate Attention to biosecurity management Attention to Spill Response.

Extraction/deposition Impact on near-field benthos due to de-ored sand deposition (same effect on Euchone sp. A – but at lower deposition rates across a wider area than the direct extraction and deposition zone).

Moderate As above Reduced deposition at distance from primary extraction area.

Impact on offshore biogenic habitats due to “choking” – potential effect of elevated sediment loads in water column.

Moderate Plume and any mobile de-ored sediments will move in a SE/NW direction and not reach the bryozoans beds deeper down the slope.

a. Antifouling Impact on Pelagic Organisms Low TTR vessels arriving in New Zealand will be required to comply with the IMO Biofouling Guidelines 2011.

Only three major vessels will be on-station for TTR, compared with the high level of vessel traffic in the STB.

The presence of TTR vessels stationed offshore in this sense would be no better or worse than ships waiting to enter harbour which occurs regularly




around most New Zealand ports. b. Mooring blocks and structures

Impact on the Benthos Low FPSO not using tensioned steel cables – limited sweep – on extraction area. Anchoring of export vessel no different to any other ship anchoring.

c. Extraction of seabed - grade control drilling

Impact on the Benthos Low Minimal surface area affected by grade control drilling.

c. Extraction of sand from the seabed

Impact on demersal fish Low Most species would be mobile enough to swim away from the areas of disturbance – but there would be some direct loss of fish entrained into high velocity intake.

Loss of feeding area is also not likely to be significant as the extraction process operates in a sequential harvesting manner.

No endangered species in the region Region does not support fish nursery or extensive feeding grounds. Snapper might use the STB for spawning, but it is not reported as a high value

snapper spawning area. Any effects on spawning by snapper (or other demersal fish for that matter) would be likely to be minor, given the relatively small scale of TTR’s activities in the context of the broader area of the STB.

Diadromous (freshwater migratory) fish such as lamprey, eels and whitebait, these fish are adapted to living in turbid freshwater systems and even if they were present in the STB, it is considered unlikely that the SSC elevations arising from TTR’s operations would adversely affect such fish – either in the adult form or the larval form.

d. De-Ored sand re-deposition and cyclone overflow sediment

Impact on rocky reefs due to choking (smothering) Low Rocky reef areas in this region are already pre-disposed to high sedimentary regimes.

No rare species are known Community composition is reminiscent of an assemblage that is robust to high

sedimentation events and regular storm driven disturbance. The proportion of the habitat available in the region that is likely to be influenced

by project sediments is relatively low. Impact on rocky reefs due to light reduction Low Nearshore reefs – optical properties pre and post mining indistinguishable.

Impact on nearshore sand due to deposition Low Nature of the seabed communities and the likely speed of recolonisation, suggested to be on the order of months to years rather than many years.

Backdrop of significant sedimentation from local rivers. Impact on nearshore sand due to choking Low Backdrop of significant sedimentation from local rivers.




Impact on benthic algae Low Benthic algae on nearshore reefs. Nearshore reefs – optical properties pre and post mining indistinguishable.

Impact on offshore biogenic habitat due to deposition Low Plume and any mobile de-ored sediments will move in a SE/NW direction and not reach the bryozoans beds deeper down the slope.

Impact on algae in offshore biogenic habitats due to light reduction

Low Plume and any mobile de-ored sediments will move in a SE/NW direction and not reach the bryozoans beds deeper down the slope.

Change in water chemistry Low No discharges of any chemicals from the vessels during processing. Potential Copper elutriate will be rapidly dilutes in ambient seawater

Change in porewater chemistry/dynamics Low Potential Copper elutriate will be rapidly dilutes in ambient seawater

Offshore shading effects Low Little algal life in the deeper reef systems and that which is present is predisposed to turbid conditions.

Offshore UW visibility effects Low Modelling of the plume direction (away from deeper reef systems) Nearshore reefs – optical properties pre and post mining indistinguishable

Offshore effects on aerial predators Low Modelling of the plume direction (away from deeper reef systems) Nearshore reefs – optical properties pre and post mining indistinguishable

Offshore pelagic choking Low Modelling of the plume direction (away from deeper reef systems)

Midshore shading effects Low Habitats midshore are already characterised by turbid conditions and the modelling suggests that this will not be significantly worsened.

Midshore u/w visibility effects Low Habitats midshore are already characterised by turbid conditions and the modelling suggests that this will not be significantly worsened.

Midshore effect on aerial predators Low Habitats midshore are already characterised by turbid conditions and the modelling suggests that this will not be significantly worsened.

Midshore pelagic choking Low Habitats midshore are already characterised by turbid conditions and the modelling suggests that this will not be significantly worsened.

Nearshore shading effects Low Nearshore – optical properties pre and post mining indistinguishable.

Nearshore u/w visibility effects Low Nearshore – optical properties pre and post mining indistinguishable.

Nearshore effect on aerial predators Low Nearshore reefs – optical properties pre and post mining indistinguishable.

Nearshore choking Low habitats nearshore are already characterised by turbid conditions and the modelling suggests that this will not be significantly worsened.

e. Effects of FPSO operations – Presence, U/W noise

Presence of FPSO Vessel Low - Positive

Vessels such as the FPSO can act as a Fish Aggregating Device (FAD). The combination of the navigational safety buffer zone and the presence of the

hull will potentially act as a de-facto marine reserve, providing a supply of pelagic fish to the wider area.




and vibrations Acoustic impact on marine mammals, reptiles, fish and invertebrates

Low Relative paucity of marine mammals and other species that could possibly be influenced by noise in the region.

Effects similar to those emitted from ships anchored and awaiting entry to ports. f. Release of dissolved material ex pore water

Low Source sand pore water natural low levels of metals

g. Ship to ship ore transfer

Impact normal operation on pelagic organisms Low Good product transfer/hygiene practices Conveyor/slurry methodology is enclosed, with TTR’s primary focus on retaining

the concentrate Seabed chemistry and infauna monitoring in the mgt plan.

h. Ship to ship fuel transfer

Impact normal operation on benthos Low The process of fuel transfer to the FPSO and the FSO does not involve any operational discharges.

Impact normal operation on pelagic organisms Low Negligible risk including spills due to dilution. Oil spill contingency plan.

Impact normal operation on benthos Low Negligible risk including spills due to dilution. Oil spill contingency plan.

i. Brine discharge Impact on pelagic organisms Nil Hydro-cyclone discharge salinity will be marginally changed from a nominal 35 ppt to around 37 ppt.

Minor change in salinity will not result in any adverse environmental effect. j. Cyclone overflow Impact on pelagic organisms Nil Negligible risk due to dilution

k. Reverse osmosis chemical discharge

Impact on pelagic organisms Nil There will be no discharge of RO treatment chemicals

l. Discharge from hyperbaric filters

Impact on pelagic organisms Nil Negligible risk due to dilution

m. Other ship discharges

Impact on pelagic organisms Nil No discharge including sewage

n. Air emissions Impact on pelagic organisms Nil Discharge doesn’t affect sea water

o. Ship lighting Seabird attract, disturb, collision Low Negligible risk due to shielded lighting systems – minimise light spill Few birds in area

Effects on squid Low Negligible risk due to shielded lighting systems – minimise light spill

Effects on fish Low Negligible risk due to shielded lighting systems – minimise light spill

p. Vessel Exclusion Impact displaced fishing/fish stocks Low Negligible risk due to low level fisheries in the region.




q. Ship Movements Ship strikes on marine mammals Low Vessels mostly stationary apart from ore carrying ships. No significant difference from existing maritime traffic.

South Taranaki Bight Iron Sand Extraction Project October 2013


13. EVALUATION OF EFFECTS ON THE SOCIAL ENVIRONMENT

Introduction

This section of the Impact Assessment provides an assessment of the potential social effects (positive and negative) and the effect on existing interests, excluding iwi.

Community

Introduction This section provides an initial assessment of potential social effects (positive or negative), based on information available on the proposed operations, the local communities and resources, and technical reports commissioned by TTR. Taking into account the Social Wellbeing Framework, the potential effects have been assessed as follows:

the effect of employment directly generated by the proposal the effect on local business and associated employment from servicing TTR’s proposed

operations the effect on income the effect on private equity the effect on community facilities, social services and housing the effect on visual amenity recreation

Employment TTR has estimated that the proposed operations will directly create around 250 jobs (FTE) across various activity categories (Section 2.20). New jobs contribute to a communities’ social wellbeing by providing a livelihood and financial support for employees and their households.

The creation of around 250 new jobs will create social benefits. However, the significance of this job creation will depend upon the location of the workforce and the extent to which the local workforce89 is able to access those positions. These two factors are assessed below.

TTR’s proposal involves offshore operations in the coastal waters off South Taranaki, which are supported by onshore services operating from Port Taranaki and Port of Whanganui, and offices in Taranaki and Wellington. TTR estimates that around 200 positions will be based on the offshore vessels, the FPSO, FSO and Anchor Handing Tug. The remainder of the positions will be office based on, around 50.

The workforce operating the FPSO and FSO will likely work rosters similar to the existing FPSOs in Taranaki. These rosters may facilitate a workforce who could live anywhere in the region, or potentially anywhere in New Zealand or further afield, and fly in and fly out, or drive in and drive out for their offshore shifts.

A FIFO/DIDO (“Fly In Fly Out/Drive In Drive Out”) workforce is considered unlikely to generate adverse social effects principally a result of the workforce living in a regulated offshore environment when they are working, and not within an existing community.

The geographical spread of the workforce will also avoid the adverse social effects that can occur when a large new workforce in one location exceeds the capacity of the local community to provide adequate housing, health and education or other social and community services.

It is unlikely that the new jobs created will significantly reduce the relatively high levels of unemployment in the “local area” and “wider area”, because of the specialised skill levels that will be required for most of the new positions. However, providing funding and other forms of support to increase opportunities for residents of South Taranaki and Whanganui to access training

89 References to a “local workforce” means the workforce that is resident in the local or wider affected areas. Where necessary we note differences in employment opportunities between the local and wider affected areas



and work experience relevant to the range of positions associated with TTR’s operations could increase the percentage of local residents gaining employment on the project.

Local Businesses and Associated Employment TTR’s proposal will benefit businesses that provide services or supplies for the various aspects of TTR’s operations. This will have a positive spin-off in terms of jobs and income for the communities in which these businesses are located, as well as increasing the viability of these businesses. It is anticipated that the majority of these benefits will accrue to businesses in the “wider area”, particularly in New Plymouth, which already have experience in servicing extractive industries including those offshore.

Income Levels Many of the positions that will be created as a result of the proposed operations will be skilled and will require offshore experience. Therefore, it is likely that these jobs will be well-paid. This view was confirmed by businesses spoken to as part of the Social Impact Assessment, who have experience in providing support to Taranaki’s primary industries, such as operators of an FPSO, Port Taranaki, and engineering companies90.

None of the local communities or the three districts in the study area had median household incomes near to or above the New Zealand median (the median household income for New Zealand as a whole was $51,400 at the time of the 2006 Census). In addition, five of the eight local communities in the study area had a significantly higher percentage of households on low incomes, in comparison to New Zealand households as a whole (low income is defined as $30,000 or less per year).

The direct creation of approximately 250 jobs will result high standards of living (and hence social wellbeing) for the households concerned91. If many of these jobs are undertaken by workers who live locally, the Project will help to offset the lower than average household incomes that are currently experienced in the profiled areas. Therefore, it is concluded that the proposal will create positive social effects as a result of the opportunity for higher than average livelihoods and financial support for the employees and their households.

Community Facilities, Social Services, and Housing

If a proposal increases the residential population of an area, it can result in positive or negative social effects on the community facilities and service providers of that area, and the availability and costs of housing. If planned or provided for, an increase in population can contribute to the viability of local services, such as schools and health services, and facilitate a buoyant housing and rental market. Conversely, an increased population, especially where this occurs within a short timeframe, can create a shortage of services and facilities if there is insufficient existing capacity in the services.

TTR’s proposal is estimated to create a workforce of approximately 250 people. If all these workers were new to the area/region and they bring family with them, this could lead to an increase of approximately 625 new residents92. However, because the land-based aspects of the proposed operations are spread across Taranaki, Whanganui and Wellington, and because of the nature of the shift-work rosters, it is likely that the workers and their families will be spread over a relatively large geographic area.

90 The engineering businesses noted that the pay rates for trades people were higher in Taranaki than elsewhere in New Zealand as a result of the pay rates generated by the oil, gas and dairying industries in Taranaki. 91 The relationship between income and wellbeing is complex and has been the subject of much research. For the purposes of this SIA we acknowledge the general results of this research, that the relationship between income and happiness is positive and can be sizeable: people with high incomes have more opportunities to pursue, and achieve, what they desire (Frey and Stutzer, 2002). 92 Based on a mean household size of 2.5, which was the mean household size for South Taranaki and New Plymouth districts at the 2006 Census



Archaeological Effects

The assessment by Clough & Associates Ltd concluded that no shipwrecks were known to be present within the project area. The potential for encountering shipwrecks in the South Taranaki Bight EEZ is low, but cannot be discounted entirely. To provide for this possibility TTR will adopt a ‘Discovery Protocol for Shipwreck Finds’ to ensure that statutory requirements and processes are followed in the event that nineteenth century wreckage is encountered.

Effects on Existing Interests

Introduction

Section 60 of the Act sets out matters the EPA must have regard to in considering the effects of an activity on existing interests under section 59(2)(a). These matters are:

a) the area that the activity would have in common with the existing interest; and b) the degree to which both the activity and the existing interest must be carried out to the

exclusion of other activities; and c) whether the existing interest can be exercised only in the area to which the application

relates; and d) any other relevant matter.

This section of the IA describes the effects on the existing interests identified in Section 7, excluding iwi. TTR’s assessment of effects on iwi is set out in Section 9.

Effects on Navigation and shipping

The Marico Marine NZ Limited study into vessel movements in the South Taranaki Bight (Section 6.17) concluded that as the Project area is well separated from the nearest regular shipping routes and commercial fishing grounds there will be very little impact, if any, on the safety of navigation in the adjacent areas.

TTR’s operations will be adjacent to the unmanned Kupe Well Platform but will take place outside the exclusion zone around this installation and its associated pipelines. Marine activities associated with the platform will be readily accommodated by TTR’s operations. The presence of TTR’s manned vessels in the area will supplement the shore based surveillance of the platform’s exclusion zone and add to the security of the Kupe operation. The vessels will be equipped with radar, Automatic Identification Systems and an extensive communications suite to detect and communicate with vessels in the area.

In overall terms, marine traffic in the Project area is very light and impacts will be no more than minor.

Effects on Commercial Fishing Operators

The main commercial fishing in the immediate area of the mining operation is a mix of bottom trawl fishery for trevally, leatherjacket, gurnard and snapper, and a set net fishery targeting school shark, rig and blue warehou.

Some of the concerns raised by the commercial fishing industry and operators about the Project include:

Productive shark fisheries exclusion area including trevally fishing grounds, shark fisheries altering the bathymetry of the seabed, which may interfere with trawling gear environmental effects on fishing including plume effects downstream from the

Project area including on the bryozoan beds altering the environment cumulative effects as the fishing industry is been squeezed by various restrictions

and exclusion zones Unplanned events and the risk of an oil spill.



The proposed mining operation overlaps with the bottom trawl fishery and the set net fishery. The extent of spatial displacement of the trawl fishery is likely to be minor as trawling effort is mainly concentrated beyond the 50 m depth contour seaward of the mining site. The proportion of trawl catch taken within the mining site is therefore likely to be minimal. The wide distribution of the fishery means that any displaced catch can be caught elsewhere in the area with minimal, if any, increase in the overall cost of fishing. However, the increasing abundance of snapper off the west coast of the North Island, and the consequent limited availability of SNA 8 Annual Catch Entitlement, may result in increased operating costs for one fisher if trawl effort is displaced in a northerly direction.

The mining operation will also displace set net catch and effort for school shark. The overall proportion of school shark taken from the mining area is likely to be small. However, even a minimal amount of displacement may be considered significant by the affected fishers due to the history of spatial exclusion in the near-shore parts of the set net fishery where rig and blue warehou are targeted. Regulatory closures to protect dolphins have pushed additional set net effort south into the Taranaki Bight and outwards into deeper waters beyond 7 nm. These cumulative effects may leave some set net fishers with limited flexibility to respond to even small additional exclusions.

As the amount of displaced catch in both the trawl and set net fisheries will be small – in particular, no negative impacts on quota value, downstream businesses, or fish stock sustainability are anticipated as a consequence of spatial displacement.

Aside from spatial exclusion, commercial fisheries may be affected by changes in distribution or abundance of commercially fished species either in the mined area, or in adjacent waters or coastal reefs. In the mined area, key considerations are whether the seafloor will be restored to its current state and how quickly it will be recolonised by commercially fished species. In the adjacent waters, the dispersal of the sediment plume is a key consideration.

Further out in the EEZ the mining operation is unlikely to have any negative effects on the mid-water trawl and bottom longline fisheries as the target fish species can migrate out of any areas affected by sediment dispersal. The degree of impact on fisheries along the Taranaki coast, including the valuable rock lobster fishery and the developing shellfish fisheries, will depend on the amount of sediment that is introduced into the reef environment. With appropriate management of sediment dispersal, no significant off-site impacts on commercial fisheries are anticipated.

TTR has provided assurances that the exclusion area will not cover the entire Project area. TTR is proposing a buffer zone of approximately 1 nm from the centre of the FPSO. This exclusion zone will incorporate the FPSO, Crawler, anchors and the FSO. TTR proposes that this buffer zone will move with the FPSO when the anchors are moved approximately every 10 days. This will allow fishing operators to continue to fish in the remaining project area.

Quantitative Effects of Exclusion and Displacement on Commercial Fishing

TTR commissioned a report on the Economic Impacts if displaced catch arising from exclusion over the entire TTR operational area was not available to the commercial fishery. This was undertaken as an extreme worst case evaluation, and such exclusion is not contemplated (See Section 13.4.3). Findings are set out as follows.

The analysis in Table 39 is based on estimates of average annual catch taken from the site (Table 40) and economic data given in Table 41. The analysis assumes that all catch is lost (and not caught elsewhere in the relevant QMAs). MPI considers there will be some adjustment by the fishing industry to the options proposed below but it is impossible to predict exactly how the fishing industry will adjust. Some fishers will be able to adjust better than others. The economic impact numbers below are therefore considered a worst case scenario, but in any event indicate a maximum potential loss of around 1.7% in CAR8 (Carpet shark Fishery).



Annual Value Capitalised Future Value Total

Direct harvesting income lost $16,460.80 $51,194.53 $67,655.33

Processing income lost $30,287.88 $49,795.12 $80,083.00

Indirect income lost $36,872.20 $49,086.40 $85,958.60

Induced income lost $26,995.72 $0.00 $26,995.72

Quota value $0.00 $244,746.73 $244,746.73

TOTAL $110,616.60 $394,822.78 $505,439.38

Table 39: Estimated Annual Income Effects and Present Value of excluding fishing from site

Fishstock Average Annual catch

( )% of catch loss

School Shark (SCH8) 6841 1.298% Leatherjacket (LEA2) 4883 1.548% Trevally (TRE7) 4625 0.243% Rig (SPO8) 2580 1.159% Gurnard (GUR8) 1668 0.742% Snapper (SNA8) 1451 0.110% Skipjack Tuna (SKJ1) 1137 0.012% Kahawai (KAH8) 991 0.210% Barracouta (BAR7) 869 0.010% Spiny Dogfish (SPD8) 783 0.404% Blue Mackerel (EMA7) 745 0.026% Carpet Shark (CAR8) 475 1.658% Tarakihi (TAR8) 267 0.130% Jack Mackerel (JMA7) 266 0.001% Northern Spiny Dogfish (NSD8) 233 0.673% 10% bycatch 2781

TOTAL 30595

Table 40: Estimated annual average percentage of fishstocks harvested within site

An explanation of the adopted methodology can be found in section 12 of the Maui’s Dolphin Threat Management Plan Consultation Paper: Sections 10 to 13 Maui's Dolphin Threat Management Plan Consultation Paper downloaded from the following website:

http://www.fish.govt.nz/en-nz/Consultations/Hector+and+Mauis+Dolphins+Threat+Management+Plan/default.htm?wbc_purpose=Basic&WBCMODE=PresentationU



Species Average Annual landings (kgs)

MPI price estimate ($/kg)

2011/12 ACE price ($/tonnes)

Average quota price since Oct 01 ($/tonnes)

Total Revenue from Catch

Total Revenue + 10% (bycatch)

School Shark (SCH8) 527,010.38 $2.30 $1,260.90 $14,881.00 $1,212,123.87 $1,333,336.26

Leatherjacket (LEA2) 315,371.15 $0.74 $68.50 $504.15 $233,374.65 $256,712.12

Trevally (TRE7) 1,904,316.57 $1.20 $283.00 $5,210.72 $2,285,179.89 $2,513,697.88

Rig (SPO8) 222,641.04 $5.03 $444.50 $13,456.40 $1,119,884.43 $1,231,872.88

Gurnard (GUR8) 224,705.98 $2.85 $521.60 $2,716.01 $640,412.04 $704,453.24

Snapper (SNA8) 1,315,537.40 $7.00 $5,265.70 $48,783.10 $9,208,761.77 $10,129,637.94

Skipjack Tuna (SKJ1) 9,167,200.70 $1.64 N/A N/A $15,034,209.14 $16,537,630.06

Kahawai (KAH8) 472,361.02 $0.80 $258.80 $3,010.07 $377,888.81 $415,677.70

Barracouta (BAR7) 8,710,480.08 $0.35 $141.60 $991.50 $3,048,668.03 $3,353,534.83

Spiny Dogfish (SPD8) 193,906.81 $1.00 $35.90 $351.42 $193,906.81 $213,297.49

Blue Mackerel (EMA7) 2,857,485.52 $1.00 $152.30 $917.76 $2,857,485.52 $3,143,234.07

Carpet Shark (CAR8) 28,646.20 $2.70 N/A N/A $77,344.74 $85,079.21

Tarakihi (TAR8) 204,575.34 $3.00 $978.00 $5,512.43 $613,726.01 $675,098.61

Jack Mackerel (JMA7) 30,112,940.17 $1.00 $121.60 $322.67 $30,112,940.17 $33,124,234.18

Northern Spiny Dogfish (NSD8) 34,561.98 $1.00 N/A N/A $34,561.98 $38,018.17

TOTAL 56,291,740.32 $67,050,467.85 $73,755,514.64

Table 41: MPI estimates of fish prices, and averaged data on affected fishstock landings, ACE and quota prices



Effects on Recreational and Tourism (Including Charter Operators)

13.4.5.1 Overview of Recreational and Tourism

The Opunake area provides relatively easy access to fishing beaches for catching snapper, trevally, kahawai and spotty shark. Members of the Opunake Boat and Underwater Club, who were interviewed for this assessment, valued the access they have to some of the best snapper resource in the country and the variety of species available. Offshore fishing is predominately undertaken off the coast of Oeo and Manaia.

The main fishing areas from beaches are at Arawhata Beach (low to moderate value for fishing and gathering kaimoana), Mungahume Beach (moderate recreational value), Puketapu (moderate recreational value for surfcasting, fishing and diving), Oeo Cliffs (moderate recreational value for surfcasting, shellfish gathering and traditional fishing site) (TRC, 2004). Middeltons Bay is also popular for fishing, as a quieter alternative to Opunake beach (TRC, 2008).

Boat launching ramps are located at Middleton’s Bay and Puketapu (cut out of the rock face), and a wharf and jetty between Middleton and Opunake beaches. Boatsheds at Puketapu and Oeo Cliffs are carved out of the rock face. Jetski areas are also provided.

Fishing and boating is popular at Patea Beach and River Mouth, particularly for blue cod and whitebaiting. In a regional recreational survey undertaken in 2007-08, Patea Beach recorded the highest average number of participants fishing from a beach at all of the water-based locations surveyed in Taranaki (TRC, 2008).

Offshore fishing is particularly popular off the coast of Patea. A public boat ramp is located at Patea (Turi Street) and the Patea and Districts Boating Club operates from there, with approximately 135 members (90 boats). The number of boats using the boat ramp can be much greater because it is a public facility. Anecdotal information indicates that fishing tournaments off the coast of Patea can attract 150 boats. South Taranaki Fishing Charters operates from Patea (launching from Patea River).

The North and South Traps are located 6 km offshore from Patea. The Traps are the base for much of the recreational diving and fishing off the coast of Patea, and are classified as having high ecological value due to the diverse and abundant marine life, including large seaweed forests (TRC, 2004). The coastal waters off Patea, including North and South Traps, Graham Bank and Patea Bank, were the most commonly identified areas of importance for fishing identified in research undertaken by the Department of Conservation (DoC, 2006).

North and South Traps were the areas most frequently mentioned as important for diving in the Department of Conservation’s research (DoC, 2006). Fish species regularly seen at the Traps included terakihi, red moki, cod, snapper, rock lobster, Spanish Lobster, pack horse crayfish, kingfish, blue moki, big eye, leather jacket and other smaller reef fish (Whanganui Underwater Club, cited in DoC, 2006).

The mining site itself, is a very low use recreation setting which may be used only rarely for marine fishing. Sites of interest to this assessment of effects are the inshore recreation setting, the near-coast diving sites and the marine fishing opportunity within 20 km of the coast. At a national level, the scale of recreation activity in the relevant coastal setting is relatively slight, with higher levels of activity north of Cape Egmont and south of Patea.

13.4.5.2 Identification of possible effects

Potential effects of the sand mining proposal of interest to the recreation and tourism community are, as identified from concerns expressed at public meetings during interviews and technical data:

Turbidity effects (underwater visibility and smothering of biota) and the location of the sediment plume and sediment effects on onshore and offshore reef systems



Re-suspension of returned sand during storm events or other wave action and the potential for long-term turbidity issues

Recolonisation rates for biota in the mined area Toxicity of returned sand and effects on biota throughout the study area Changes to coastal wave patterns affecting surfing opportunities ‘Sand budget’ effects on the replenishment of beaches and sand bars (also an issue for

surfing) Exclusive use of the marine area in the mining area and interference with navigation

routes for recreation craft Effects on the environmental (‘clean green’) reputation of NZ

Based on the technical reports the following potential scales of effect are anticipated:

Potential adverse effect on recreation and tourism due to changes to water clarity are:

Minor in the inshore marine setting where most recreational activity occurs due to the very low scale of effect on water clarity and high level of background suspended sediment,

Minor in the important diving setting of the Traps due to a persistent but small scale change in water clarity, which will be most apparent only when the mining activity is occurring in the eastern part of the mining area (that is, not for the full period of mining activity). However, there is potentially a moderate scale of effect in water clarity during the rare periods of extreme water clarity (>10 m visibility for four days per year), which are likely to coincide with ideal settled diving conditions and are therefore likely to be experienced by divers.

Minor on the offshore surface recreation experience in the South Taranaki Bight (fishing, sailing and other boating) due to the scale of the offshore setting, the relatively low level of activity in the plume area and the transient characteristic of the experience.

Potential adverse effect on recreation and tourism due to changes to marine ecology are:

Minor on recreation and tourism in the mining area due to very low levels of use of the setting and the large scale of alternative and proximate activity areas, although site-specific effects on benthic marine organisms will be greater,

Minor for recreation and tourism activities outside the mining area due to the low scale of adverse effects on marine ecosystems.

There is also:

The potential for only very minor effects on recreation and tourism in the South Taranaki Bight due to exclusive occupation of the marine environment as proposed due to the very small area occupied by the activity, and

Very little potential for adverse effects on New Zealand’s tourism brand as the mining activity has limited adverse environmental effects and occurs well away from internationally important tourism settings.

Adverse effects of interest to recreation and tourism are therefore likely to be only local to the mining activity, and will relate to exclusive use of the marine setting, local turbidity effects (up to 10 km from the site) and short-term effects on habitat in recently mined seafloor.

13.4.5.3 Effects on Recreational Fishing

The Project will operate in waters that contain demersal fish and pelagic fish that are popular for recreational fishing. Media articles have indicated concern from some of the community that fish stocks will be reduced and negatively impact on one of New Zealand’s healthiest snapper fisheries.

Fishing from the shoreline and off-shore will be largely unchanged in terms of fish stock and location, particularly in relation to effects on North and South Traps.



Experience with other sand extraction operations (e.g. Kaipara Harbour) indicates that fishing potential around extraction areas will not be adversely affected, and that the outflow from the primary screens will contain larger organisms and shell fish which will provide food for fish species as they are returned to the sea.

Access to fishing and boating resources will be affected by the proposal as a result of the proposed 1 nm buffer zone area around the FPSO. The exclusion area covers an area where fish stocks exist, but it is located further offshore than most recreational boaters and recorded diving attractions are located. Accordingly it is concluded that recreational users will not be affected by the exclusion zone to a more than minor extent.

Other aspects of TTR’s operations are mobile, such as the FSO and export vessels, and therefore access for recreational fishers and boaters is not considered to be adversely affected any more than would occur from other large commercial and recreational vessel movements.

13.4.5.4 Effects on Diving

The Traps have been identified as significant from a recreational diving point of view. As part of the Optical Properties evaluation described in Section 11.6 of this IA, NIWA evaluated effects on underwater horizontal visibility as an indication of likely effects on diving.

Optical effects including horizontal visibility were calculated from the output of the NIWA hydrodynamic sediment plume model which was run for 1000 days, with statistics (percentiles, medians, etc.) calculated from the model data of the last 730 days. For the optical effects report, exactly the same time series of model output data was taken, but processed into the form of optical quantities, namely the horizontal visibility, vertical visibility (Secchi depth), euphotic zone depth and surface radiance. Statistical parameters were derived from this data in the same way as they were derived from the SSC data. In all these cases the base model runs were the same: one with natural sediment only, one with a mining source at location A (inner end of the project area), and one with a mining source at location B (outer end of the project area).

For the evaluation of effects on horizontal visibility, consideration was given to changes at the surface (< 1 m), in mid water (nominally 10 m) and at the bottom (nominally 20 m). The model does not include shallow reef features and therefore bottom depths are deeper, related to general bathymetry of the area. The mid water layer is likely to be of most interest and relevance to diver visibility.

Figure 106 and Figure 107 set out results for both the inner and the outer extraction area scenarios respectively. Results are broadly the same for both North and South Traps

For the outer area (Figure 107) there is very little change between pre and post operational scenarios.

For the inner scenario (Figure 106), results indicate that in the mid-water region there is no difference between pre and post TTR operations where water visibility is 10 m, although model output predicts a limitation in days of visibility greater than 10 m from around 4 per year to around 1 per year. When underwater visibility is less than 10 m, the apparent difference in horizontal visibility between pre and post TTR operations is predicted to be no more than 1 m.



Figure 106 Cumulative frequency plots of the horizontal visibility distance at the North and South Traps diving locations, for surface (top metre), middle (about 10 m) and bottom (about 20 m) depths, under natural and iron sand mining from release site a (nearest to the diving sites).



Figure 107: Cumulative frequency plots of the horizontal visibility distance at the North and South Traps diving locations, for surface (top metre), middle (about 10 m) and bottom (about 20 m) depths, under natural and iron-sand mining from release site b (furthest from the diving sites).

Changes in underwater visibility are unlikely to be observable and should be considered a minor-moderate effect in respect of the diving experience. However, given the recreational importance of the traps it is important to consider mitigation factors relating to this particular effect which is driven primarily by the outputs of NIWA plume modelling described in Section 11.5 of this IA. Potential mitigation actions relate to a number of assumptions behind the NIWA plume modelling as discussed in Section 15.2 of this IA. It will only be after operations commence, and monitoring is undertaken that any such mitigation measures may be realised.



13.4.5.5 Surfing

The coastline immediately to the north of Opunake township (from Arawhata Road Beach south to Opunake) has an almost continuous stretch of high quality or high value surfbreaks. These include Arawhata Road Beach, Arawhata Point, Arawhata Reef, Pohutakawas, Slaughterhouse Left and Right and Stepladders Left and Right.

Further south of Opunake, high quality or high value surfbreaks include Greenmeadows, Puketapu and South Point.

The principal effects on surf breaks arise from changes in the wave climate. The changes in wave directions mostly follow the changes in wave heights. Given the location over 20 km offshore of the closest breaks, it is likely to be insignificant. Due to the process of refraction over this distance, wave crests will likely be realigned to the seabed contours offshore of the breaks to a similar direction as they would without the presence of the seabed modifications.

NIWA model simulations show that there will be small changes in wave height – both positive and negative, but, averaged over many incident waves and extraction scenarios, this will be unlikely to affect shoreline erosion. The changes in wave height along the coast at the 10 m contour are less than 100 mm for waves 3 m high. Therefore impacts on wave heights are considered insignificant with respect to impacts on surfing quality.

TTR consulted with surfing organisations in Taranaki as there was a concern that the Project may have an impact on waves and surf breaks in the South Taranaki Bight. Surfing representatives were concerned about the effect the Project would have on surfing quality in South Taranaki. This included the impact the Project could have on: Wave height Swell direction Coastal erosion Sediment plumes Visual effects

The Chief Executive Officer of Surfing Taranaki was provided reports on the impact on surfing, coastal stability and sediment plumes. On the basis of the research and findings in those reports Surfing Taranaki assessed that the Project raised no alarm bells as the impact on swells will be minimal, there will be no visual effects from the shoreline, and the erosion is natural with rivers and long shore processing providing replenishment for coast.

13.4.5.6 Beach Access

For the purposes of this assessment, the recreational use of beaches includes activities such as swimming, walking, surfcasting and passive uses (picnicking, relaxing, sun bathing).

The effect of TTR’s proposal on the South Taranaki/Whanganui beaches has been assessed in terms of the extent to which the beaches will be physically altered, whether public access to the beaches will be altered, and whether the amenity value of the beaches will be altered. Based on the evaluation set out in Section 11.1 of this IA, the Project will not appreciably alter the wave climate. There will be no measurable effect on public access to the beaches not on associated amenity values.

Walking is an important leisure and recreation pursuit for Taranaki residents. TTR’s proposal will not affect access to or along these coastal walkways, nor will it affect associated amenity.

Commercial Operators under Continental Shelf Act and the Crown Minerals Act

Origin Energy is the operator for the Kupe Gas Project under Licence 38146. The Kupe Platform is an offshore platform with three production wells, a 30 km raw gas pipeline running from the platform to the shore, an onshore production station near Hawera, and light crude storage and export facilities near Port Taranaki. The Licence is due to expire on 26 June 2031.



The Kupe Platform and Pipeline have a 500 m exclusion zone around them and are outside the project area. However, there is an overlap between Kupe Licence area and the Project area.

While TTR’s operations should not impede Origin Energy’s ability to service the existing infrastructure or undertake future exploration, future exploration drilling in TTR’s permit area would sterilise the iron sand resource surrounding the capped exploration well if the drilling is on virgin iron sand. This risk becomes redundant if drilling takes place on areas which have been extracted.

The 2013 Petroleum Block Offer and the proposed 2014 Petroleum Block Offer, include areas which overlap with the Project area. TTR’s project should not impede the ability for petroleum exploration permit holders to undertake their work programme. However, TTR would seek to enter a formal relationship with the permit holders to avoid sterilisation of the iron sand and ensure the efficient extraction of the petroleum and iron sand resources.

TTR is trying to engage with Origin and New Zealand Petroleum and Minerals to come to an arrangement with regard to mine development and exploration in order to facilitate the development of the Kupe field and the iron sand in the region.

If any other petroleum permits are granted on or near the project area over the course of the project lifespan, TTR would seek to enter into a relationship agreement to enable the activities to co-exist.

Summary of Social Effects and Effects on Existing Interests

Table 42 summarises the effects on the social environment identified in relation to the TTR Project. In Section 15 detailed consideration is given to options to mitigate risks associated with TTR’s activities.




Table 42: Summary of “Pre-Mitigation” Social and Existing Interests Effects

Activity Effects Risk Rating Mitigation Factors Economic benefit New jobs. Positive The creation of around 258 new jobs will create social

benefits. The significance of this job creation will depend upon the

location of the workforce and the extent to which the local workforce is able to access those positions.

Economic benefit Businesses that provide services or supplies for the various aspects of TTR’s operations.

Positive Project will have a positive spin-off in terms of jobs and income for the communities in which these businesses are located, as well as increasing the viability of these businesses.

Overall operation Navigational safety. Minor Buffer zone. Marine traffic in the Project area is very light.

Navigational exclusion Commercial fisheries - extent of spatial displacement of the trawl fishery.

Minor The proposed mining operation overlaps with the bottom trawl fishery and the set net fishery.

Trawling effort is mainly concentrated beyond the 50 m depth contour seaward of the mining site.

Small exclusion zone. Navigational exclusion Commercial fisheries - set net catch and effort for school

shark. Moderate The overall proportion of school shark taken from the mining

area is likely to be small. However, even minimal displacement may be considered

significant by the affected fishers due to the history of spatial exclusion in the near-shore parts of the set net fishery where rig and blue warehou are targeted.

Cumulative effects may leave some set net fishers with limited flexibility to respond to even small additional exclusions.

Navigational exclusion Commercial fishing industry, generally. Minor Small buffer zone. Minimal use.

Navigation exclusion Tourism –charter operators Nil Small buffer zone. Site is outside the range for charter operators.

Extraction/deposition Recreational fishing from the shoreline and off-shore. Minor Small buffer zone. Minimal use. Low scale of adverse effects on marine ecosystems.

Extraction/deposition Tourism – effect on charter operators fishing Minor Small buffer zone. Minimal use. Low scale of adverse effects on marine ecosystems.



Activity Effects Risk Rating Mitigation Factors Extraction/deposition Underwater visibility effect on divers and fishing. Moderate Distance offshore.

Changes in underwater visibility are unlikely to be observable. Potential process optimisation which could effectively reduce

the level of output fines and consequently reduce to level of environmental effect to below that predicted in NIWA worst-case modelling.

NIWA modelling indicates that operations at the outer end of the Project area will have only a minor effect in respect of observable effects at the Traps. Mining the further offshore areas perhaps presents a potential measure to avoid adverse effects in sensitive areas at particular times.

Navigational exclusion Recreational boating and fishing. Minor Distance offshore. Small exclusion zone. Minimal use.

Extraction/deposition Public access to the beaches. Nil Distance offshore. Extraction/deposition Adverse effects on surf breaks. Minor Distance offshore. Extraction/deposition Access to or along coastal walkways and amenity. Nil Distance offshore. Extraction/deposition The potential for encountering shipwrecks in the South

Taranaki Bight EEZ is low. Minor The assessment by Clough & Associates Ltd concluded that no

shipwrecks were known to be present within the project area. TTR will adopt a ‘Discovery Protocol for Shipwreck Finds’ to

ensure that statutory requirements and processes are followed in the event that nineteenth century wreckage is encountered.

Extraction/deposition Effect on the ability for Origin Energy to undertake further exploration drilling of the Kupe Field.

Minor Formal relationship agreement to avoid sterilisation of either iron sand or petroleum resource.

No iron sand extraction over petroleum exploration wells. Extraction/deposition Effect on commercial fishing – creation of pits and mounds

and the potential effect the changes in bathymetry may have on trawling gear

Minor-Moderate

The proposed mining operation overlaps with the bottom trawl fishery and the set net fishery.

Trawling effort is mainly concentrated beyond the 50 m depth contour seaward of the mining site.

Undertake to enter a formal information sharing agreement with the fishing industry, and to regularly share mine plan information and updated bathymetry information.



14. OTHER EFFECTS

Introduction

Section 59 of the EEZ Act identifies a number of overarching effects which are required to be taken into account by the EPA, including cumulative effects, effects outside the EEZ and human health effects. These matters are each addressed in this section of the IA.

Cumulative Effects

Introduction

The effects on the environment required to be taken into account by the EPA include cumulative effects (section 59(2)(a)).

Cumulative impacts on environmental resources may result from incremental effects of an action, when combined with other past, present, and reasonably foreseeable future projects in the area.

The STB is not currently utilised by any other activity which might directly interact with TTR’s operations and create cumulative impacts. There is however one industrial discharge from Hawera which takes place in the same general geographic area as TTR’s operations, and there are existing navigational exclusion zones in the area which might act in a cumulative manner with TTR’s operations.

Fonterra Discharge

The one industrial activity which discharges into the STB is the Fonterra Hawera plant. This Plant discharges factory wastewater along with wastewater from the Hawera Sewage scheme via a 2 km pipeline and outfall into the STB. Plume modelling (Section 11.5) of this IA indicates that the Whareroa Plant discharge will not be affected by TTR’s plume, nor will the discharge impinge on TTR’s operations.

Navigational and Fishing Exclusion – Cumulative Effects

There will be a limited safety buffer zone located around the FPSO. This will occupy around 10 km2, based on a dynamic 1 nm, or 1852 m, radius around the FPSO. There is a concern expressed by some parties that TTR’s buffer zone will compound the impacts on commercial fishing arising from the existing Maui’s dolphin Threat Management Plan boundaries (and mooted extensions to those boundaries), and other exclusion zones in the STB associated with oil production (Kupe pipeline and platform exclusion zones).

In particular, navigational and fishing exclusion associated with TTR’s project will potentially displace set net catch and effort for school shark. As noted in Section 13.4.3 of this IA, the overall proportion of school shark taken from the Project area is likely to be small. However, even a minimal amount of displacement may be considered significant by the affected fishers due to the history of spatial exclusion in the nearshore parts of the set net fishery where rig and blue warehou are targeted. Regulatory closures to protect dolphins have pushed additional set net effort south into the Taranaki Bight and outwards into deeper waters beyond 7 nm. These cumulative effects may leave some set net fishers with limited flexibility to respond to even small additional exclusions.

As the amount of displaced catch in both the trawl and set net fisheries will be small, it is unlikely that there will be any wider negative impacts on the commercial fishing industry – in particular, no negative impacts on quota value, downstream businesses, or fish stock sustainability are anticipated as a consequence of spatial displacement.

Overall, the scale of TTR’s safety buffer area is relatively small in the broader context of the STB. Accordingly, TTR considers that the potential risk of any cumulative impact of the navigational safety buffer area in the STB is low.



Ecological – Cumulative Effects

The TTR project will create elevated suspended sediment levels immediately around the operational area. This effect will not present issues in respect of cumulative physical effects with any other activities, and consequently in respect of ecological effects.

Visual – Cumulative Effects

As noted in Section 11.7, in terms of visible cumulative effects, mining derived sediment will not add appreciably to the natural or background levels within the inshore and nearshore marine areas. There will however, be increased visual effects in terms of the offshore and distant offshore marine areas where currently there are no visible sediment plumes under most conditions. From the coastline cumulative effects are not likely to be particularly visible. From some marine areas, cumulative effects may be apparent, however, given the limited extent of views and the variability of the plume, cumulative effects are not likely to be perceived as being significant or adverse. From aircraft cumulative effects will be most apparent and are likely to be widespread in extent.

However, the assessment is that the significance of these cumulative effects will be no more than minor.

Mitigation – Cumulative Effects

The above considerations, combined with the limited overall impact significance, discussed elsewhere in this document, make it unlikely for the TTR Project to contribute to any significant cumulative impact.

Nevertheless, TTR will continue to seek to limit adverse effects through the use of Best Management Practices and numerous ‘designed in’ mitigation measures.

There is a risk of tensions occurring between recreational and commercial fishermen and local authorities around offshore mineral extraction possibly in conjunction with concerns about offshore oil exploration activities. Therefore, it will be important to monitor local attitudes towards TTR’s operations and respond to any community issues that are raised in a timely manner. TTR will continue to engage stakeholders (e.g. local fishermen) by informing them of both current Project activities and possible future activities will be part of TTR’s stakeholder engagement programme.

Effects outside the EEZ

Section 59(2)(b)(ii) of the EEZ Act requires the EPA to take account of effects that may occur in New Zealand or in the waters above or beyond the Continental Shelf beyond the outer limits of the Exclusive Economic Zone when considering an application for a marine consent and submissions on an application.

TTR’s activities will influence waters in the CMA in respect of suspended sediment concentrations (Section 11.5 of this IA), and potential effects on wave climate (Section 11.1 of this IA). Consequential effects in the CMA include potential effects on recreational activities (Section 13.4.5 of this IA), visual amenity (Section 11.6 of this IA), communities (Section 13 of this IA) and iwi (Section 9.11 of this IA).

The potential effects of TTR’s activities will not extend beyond the outer limits of the Exclusive Economic Zone or Continental Shelf.

Effects on Human Health

Section 59(2)(c) of the EEZ Act requires the EPA to take account of relevant the effects on human health that may arise from effects on the environment when considering an application for a marine consent and submissions on an application.

The TTR Project will not involve the discharge of any contaminants which might potentially result in adverse effects on human health. Evaluation of pore water



chemistry (Section 6.8) indicates potential for release of copper from the concentrate, but environmental dispersion calculations have shown that ambient (environmental) levels are within ANZECC Guidelines.

Noise levels generated on the vessels will be managed to avoid adverse human health effects.

Ground level concentrations of air contaminants will be within relevant guideline levels intended to protect health.

Effects of Anchoring Export Vessel during Ore Transfer

Introduction

Section 2.15.3 describes the procedure for transfer of concentrate from the FSO to the Export Vessel, which is anticipated to take place in a location to the south of the Project area or in an area such as Admiralty Bay, subject to maritime safety requirements.

No consents are required for these activities, but Section 59(2)(b)(i) of the EEZ Act requires the EPA to take account of the effects of activities that are not regulated under the Act when considering an application for a marine consent. Accordingly potential effects of the concentrate transfer to the Export Vessel are evaluated as follows.

Spillages during Transfer Process

Concentrate will be transferred from the FSO to the export vessel by covered conveyor. No spillage of product is anticipated, but in the unlikely event that it did occur, it is noted that the transfer process is closely managed and transfer operations could be rapidly stopped. Thus the risk of appreciable quantities being spilt is negligible. Any seabed effects of such inconsequential spillage would be less than minor given the inert nature of the concentrate.

Effects of Anchoring by Export Vessel

The export vessels will need anchoring around every 5 days throughout the year. Most times anchoring will take place in the STB near to the Project area, but around 2-3 events per year (each duration around 3 days) anchoring might be needed somewhere sheltered such as Admiralty Bay. Neither marine consents nor resource consents are required for either option (under the Marlborough Sounds Resource Management Plan occupation is permitted for up to 31 days).

Anchoring in STB

Anchoring in STB will avoid sensitive habitats, with the initial focus being on an area south of the Project area which has been assessed by NIWA as typical of the rest of the Project area and containing no sensitive habitats. .

Anchoring in Admiralty Bay

Admiralty Bay is typified by mud bottom communities. The Marlborough District Council in conjunction with the Department of Conservation has released ‘Ecologically Significant Marine Sites in Marlborough, New Zealand’. This report concluded that bottom trawling, dredging and fishing have modified the species assemblages in Admiralty Bay

Anchoring the export vessel will potentially disturb benthic habitat through setting of the anchors and the interaction between the seabed and the chains which secure the vessel. The area of seabed disturbed will be relatively small, temporary in nature and will involve a benthic community which is not considered a sensitive environment and which will be resilient to physical effects. Therefore, it is considered that adverse effects on benthic habitats from the physical presence of the export vessel anchors will be less than minor.



15. MEASURES TO AVOID, REMEDY, OR MITIGATE ADVERSE EFFECTS IDENTIFIED All adverse effects associated with TTR’s activities are discussed in Sections 9 to 0 of this IA. Section 39(1)(h) of the EEZ Act requires that this IA must specify the measures that TTR intends to take to avoid, remedy, or mitigate adverse effects identified.

This section sets out TTR’s proposed approach in relation to the requirement to avoid, remedy or mitigate any adverse effects on the environment or existing interests.

TTR has only a limited ability to vary the Project scope and retain a commercially viable operation (see Section 2.4.2). However, there are a number of measures that have already been already incorporated in Project design and there are a number of operational measures which collectively enable TTR to avoid remedy or mitigate adverse effects as discussed below.

Project Design - Effects Mitigation Factors

Location of extraction area

Initial project design involved operations within the Coastal Marine Area, as close as 11 km from the shore. However, hydrodynamic modelling indicated that operating in such close proximity to the coastline would result in high predicted suspended sediment levels in the water column along with unacceptably high sediment deposition rates near the shore. Even though it was understood that the modelling predictions were based on worst-case assumptions and were likely to overestimate the level of environmental effect, TTR opted to move the Project area off shore to its present location. Moving the TTR operation further offshore will help mitigate effects relating to suspended sediment concentrations.

Exploration drilling has determined that there are variably deep lenses of fine sediments at variable depths below the seabed of the STB. Experience has shown that there is a generally negative correlation between the presence of these fine sediments and iron ore concentrations. TTR is targeting higher levels of iron ore and thus will be in effect staying away from lenses of fine materials. Notwithstanding this, the NIWA modelling has assumed elevated levels of fines in the extracted seabed, so modelling outputs are conservative. Targeting areas of higher iron ore concentration will help mitigate effects relating to suspended sediment concentrations.

Extraction Methodology

As noted above, extraction operations will tend to focus on areas of higher iron ore concentration helping to avoid areas containing higher levels of fine sediments.

The original project plan entailed use of a Trailer Suction Hopper Dredge (“TSHD”). This would have been a broad extraction option technique which would not have provided the ability to target specific areas as can be done with the Crawler. The use of the Crawler in this manner will help mitigate effects relating to suspended sediment concentrations.

The TSHD option would also have involved use of hopper barge to transfer dredged material from the extraction area to the FPSO and to transfer de-ored sand to a tailing disposal area. This would have represented a significantly less efficient operation than the now-proposed “one-pass” extraction processing and deposition methodology. A “one-pass” operation will help mitigate effects relating to suspended sediment concentrations.

Use of the Crawler allows for extraction and re-deposition to occur in tightly defined, relatively narrow lanes. Use of the Crawler and narrow extraction “lanes” will help minimise the areal extent and duration of disturbance and maximise opportunities for recolonisation and recovery.



Processing

The processing operation relies on physical screening and magnetic separation, with no chemicals used in the process, and no chemicals potentially discharge to the environment. Avoidance of use of chemicals in the process removes the risk of accidental spillage and associated adverse environmental effects.

Any cleaning chemicals and on-board wastewater will be stored and transferred ashore for proper disposal, thereby avoiding adverse effects associated with discharge to the water column.

De-ored sand re-deposition

The original project concept involved dedicated de-ored sand disposal sites located away from TTR’s primary operational area. These earlier sites had been re-located away from recognised biogenic habitats in deeper water, but they did involve a significant expansion of the project footprint. Using the Crawler and the “one-pass” concept enables TTR to more precisely deposit de-ored sand mainly into areas which have been previously subject to extraction. This reduces the “footprint” of the Project and minimises the area of disturbance to benthic organisms.

De-ored sand will be dewatered to increase its density and thereby reduce the chances of sand movement away from the deposition area. The resultant particle size distribution of the de-ored sand will be close to the particle size distribution of the existing seabed. This will potentially enhance opportunities for recolonisation.

The original project concept involved bottom dumping from hoppers shuttling between the FPSO and the dredges. This would have resulted in elevated suspended sediments throughout the water column with associated potential for increased adverse effects. The current proposal involves discharge via a pipe, with the point of discharge located a few metres above the seabed, which will help to mitigate adverse effects of sediment re-suspension.

The original concept was to de-water the sediment in the hopper and discharge to the water though a “Green Valve”. Whilst being commonly used as a means of mitigating sediment plumes in dredging operations, this is a relatively coarse mitigation options in comparison with TTR’s solution.

Freshwater source

The original project concept involved sources rinsing freshwater from rivers, aquifers or from the Whanganui wastewater treatment plant. Any of these activities would have resulted in potentially more significant environmental effects than relying on reverse osmosis as now proposed.

Scale of project

The original project concept involved extraction of around 100 million tonnes per year of seabed material. The current proposal is just half that amount; with consequent markedly reduce scope for adverse environmental effects.

Shipping

The latest project design involves on two major vessels plus an Anchor Handling Tug. Earlier concepts involved significantly larger numbers of vessels, including dredged, hopper barges and multiple FSOs. Reduced vessel numbers decreases the likelihood of whale “ship strike” and interference with other users of the STB.

The only TTR vessels transiting through an apparent blue whale area to the northwest of the Project with will be the export vessels operating on an approximate fortnightly frequency. Such shipping use is negligible in comparison with present patterns of



shipping activity in the STB, and will minimise the risk of TTR-related whale “ship strikes”.

TTR will make shipping operators aware of possible presence of blue whales to the northwest of the site and will advise that operators to avoid that area if practicable and consistent with safe maritime operations.

All vessels will be compliant with a biosecurity management plan to be developed in consultation with MPI to minimise the potential for the translocation and introduction of NIMS.

Practical Refinements of NIWA Worst-Case Assumptions

The predicted level of suspended sediment concentrations are driven primarily by the outputs of NIWA plume modelling described in Section 11.5 of this IA. There are a number of potential practical mitigation factors relating to many of the assumptions behind this plume modelling. However, it will only be after operations commence, and monitoring is undertaken that any such mitigation factors may be fully realised. Such mitigation measures include:

NIWA worst-case modelling was based a scenario involving a double grind process with generation of fine grained particles at each grind step. TTR’s detailed project engineering is focusing on single pass grinding involving a coarser output consistency than originally envisaged. This would effectively reduce the amount of output fines and consequently reduce the level of environmental effect to below that predicted in the modelling.

NIWA modelling assumed a worst-case liberation of all fines from the re-deposited de-ored sand. Experience indicates that this is unlikely to be the case, with significant quantities of fines locked-up by overlying sand during the re-deposition process. This would reduce a further source element from NIWA’s assumptions and potentially reduce the actual level of fines experienced in suspension at the Traps.

The NIWA modelling assumed release of fines from operations at the 12 nm inner limit of the extraction area on a continuous basis. In reality this will not be the case. Extraction will occur right across the Project area out to 19 nautical miles offshore. NIWA modelling indicates that operations at the outer end of the Project area will have only a minor effect in respect of observable effects at the Traps. Mining the further offshore areas perhaps presents a potential measure to avoid adverse effects in sensitive areas such as the Traps at particular times.

Best Practice

TTR Project design has taken account of a range of best practice international conventions, guidelines and regulations as described in Section 4.10.

Social Impact Mitigation

Archaeological Effects

While there are no shipwrecks known to be present within the project area, TTR will adopt a ‘Discovery Protocol for Shipwreck Finds’ to ensure that statutory requirements and processes are followed in the event that nineteenth century wreckage is encountered.

Navigation and shipping

TTR will apply to Maritime New Zealand to establish a buffer zone around the FPSO when anchored on the mine site to safeguard other ocean users, members of the public and project vessels from harm. The buffer zone will extend in a circle with a radius of one nautical mile from the FPSO to extend beyond the extremities of the anchor pattern and cover the area where support vessels are manoeuvring and/or are constrained in their ability to manoeuvre.



The buffer zone will be monitored and all movements within the zone authorised by the Officer of the Watch on the FPSO. Up to date position information of the FPSO will be promulgated to mariners through the vessel’s AIS transmissions.

Commercial Fishing

The exclusion area will not cover the entire Project area. TTR is proposing a dynamic buffer zone of approximately 1 nm radius from the centre of the FPSO. This buffer zone will incorporate the FPSO, Crawler, anchors and the FSO. TTR proposes that this buffer zone will move with the FPSO when the anchors are moved approximately every 10 days. This will allow fishing operators to continue to fish in the remaining project area.

TTR has tabled the idea of developing a relationship agreement with the commercial fishing operators/industry in order to share information about TTR’s operations including mine plans and operations, buffer zones and updated bathymetry.

Effects on Recreational Fishing and Diving

TTR proposes that a recreational fishing and diving management and monitoring plan will be prepared and implemented. This plan will establish how the project operations will be designed to minimise effects of sediment plumes on popular fishing and diving locations, and how this will be monitored and reported back to the fishing and diving communities. The location of the areas to be monitored will be determined in consultation with representatives of the fishing and diving communities, and may include North and South Traps, Four Mile Reef, and the reefs off Waipipi and Waiinu beaches. The fishing and diving management and monitoring plan will be incorporated in the EMMP discussed in Section 17 of this IA.

Effects on Underwater Visibility 15.4.5

A number of the above mitigation measures relate to minimising effects on underwater visibility including:

TTR’s detailed project optimisation is focussing on single pass grinding involving a coarser consistency than originally envisaged. This would effectively reduce the level of output fines and consequently reduce to level of environmental effect to below that predicted in the modelling.

NIWA modelling also assumed a worst-case liberation of all fines from seabed-deposited de-ored sand. Experience indicates that this is unlikely to be the case, with significant quantities of fines locked-up by overlying sand during the re-deposition process. This would reduce a further source element from NIWA’s assumptions and potentially reduce the actual level of fines experienced in suspension at the Traps.

The NIWA modelling assumed release of fines from operations at the 12 nm inner limit of the extraction area on a continuous basis. In reality this will not be the case. Extraction will occur right across the Project area out to 19 nautical miles offshore. NIWA modelling indicates that operations at the outer end of the Project area will have only a minor effect in respect of observable effects at the Traps. Mining the further offshore areas perhaps presents a potential measure to avoid adverse effects in sensitive areas at particular times.

Comprehensive and Responsive Environmental Management

TTR’s operations will involve a focus on systems and formal response mechanisms to optimise environmental performance.

TTR’s operations will reflect and be based on the management concepts embodied in ISO 14001.

An Environmental Management Framework will be developed around the elements shown in Table 43. (This framework forms the basis for the Environmental Monitoring and Management Plan set out in Section 17).



ENVIRONMENTAL MANAGEMENT ELEMENT

1 Stakeholder involvement – ensure stakeholders are committed to adaptively manage the enterprise for its duration.

2 Project definition including clear identification of stages of development, and likely scope of associated environmental issues.

3 Definition of management objectives - identify clear, measurable, and agreed-upon management objectives to guide decision making and evaluate effectiveness over time; incorporating requirements set out in enforceable marine consent conditions.

4 Design and planning - preparation of management plans and programmes for monitoring and managing the resource and environmental effects.

5 Identify management actions required for decision making.

6 Monitoring and assessment - design and implement a monitoring plan - establish existing environment by robust baseline monitoring - monitoring the effects on indicators; develop clear and strong monitoring, reporting and checking mechanisms so that steps can be taken before significant adverse effects eventuate; – improve understanding of resource dynamics by comparing predicted and observed changes in resource status; use monitoring to track system responses to management actions;

7 Evaluation and decision making – analysis of monitoring results in relation to objectives and the management programme i.e. are the objectives being achieved - select management actions based on management objectives, resource conditions, and understanding.

8 Review and response reviewing and refining the hypothesis, management plan and programme to better meet the objectives. There may also need to be adjustment of policies, programmes, and budgets. After this stage the process starts again with design and planning; incorporating requirements set out in enforceable resource consent conditions which require certain criteria to be met before the next stage can proceed; there is real ability to remove all or some of the development that has occurred at that time if the monitoring results warrant it.

Table 43: TTR Environmental Management Framework



This page has intentionally been left blank



16. CONSENT CONDITIONS FRAMEWORK

Introduction

Section 63 of the EEZ Act provides for the EPA to grant a marine consent on any condition that it considers appropriate to deal with adverse effects of the activity authorised by the consent on the environment or existing interests. Conditions that the EPA may impose under s63 include, but are not limited to, conditions—

a) requiring the consent holder to—

(i) provide a bond for the performance of any 1 or more conditions of the consent:

(ii) obtain and maintain public liability insurance of a specified value:

(iii) monitor, and report on, the exercise of the consent and the effects of the activity it authorises:

(iv) appoint an observer to monitor the activity authorised by the consent and its effects on the environment:

(v) make records related to the activity authorised by the consent available for audit:

b) that together amount or contribute to an adaptive management approach.

This Section of the IA addresses a framework within which consent conditions can be imposed pursuant to s63 of the EEZ Act. Marine consents required for the TTR Project include those summarised in Table 44.

TTR Project Element Consent Required Part of Act

FPSO Anchors, Crawler Construction, mooring or anchoring long-term, placement, alteration, extension, removal, or demolition of a structure or part of a structure on, or under the seabed.

S20(4)(a)

FPSO Operations, Crawler Causing of vibrations (other than vibrations caused by the normal operation of a ship) in a manner that is likely to have an adverse effect on marine life.

S20(4)(b)

Excavation with Crawler, Grade Control Drilling

Removal of non-living natural material from seabed or subsoil.

S20(2)(d)

Excavation with Crawler, Grade Control Drilling

Disturbance of the seabed in a manner that is likely to have an adverse effect on the seabed or subsoil.

S20(2)(e)

Re-deposition of De-ored Sand, hydro-cyclone sediment discharge

Deposit of any thing or organism in, on, or under the seabed.

S20(2)(f)

Excavation with Crawler, Re-deposition of de-ored sand, Grade Control Drilling

Destruction, damage, or disturbance of the seabed in a manner that is likely to have an adverse effect on marine species or their habitat.

S20(2)(g)

Table 44: Marine Consents required for TTR Project



General Approach

The extent or nature of many of the effects of TTR’s project have been assessed in this IA on the basis of worst case modelling. As noted there are many mitigation measures which will help to ensure that likely environmental outcomes will differ from, and be less than, the magnitude of these worst-case predictions.

TTR proposes that setting consent conditions and monitoring them according to a management plan (the Environmental Monitoring and Management Plan or “EMMP”) is the most appropriate mechanism to ensure that the TTR Project incorporates measures to avoid, remedy or mitigate adverse effects to achieve the purpose of the EEZ Act.

TTR’s proposed consent condition framework is based around the following steps:

a) Where practicable, set defined performance criteria in conditions. Recognising that monitoring and review will be necessary to ensure that conditions remain relevant to effects once operations commence.

b) Where final criteria or standards are not yet able to be established, or where the extent or nature of effects is based on worst-case assumptions and are intended to be clarified at a later stage of the project, then the conditions should set out:

(i) A requirement for the EMMP to identify and address specified effects;

(ii) Environmental objectives to be achieved by the EMMP separately for each topic around which there is presently uncertainty;

(iii) How the EMMP will be designed and implements;

(iv) A requirement to monitor actual effects;

(v) A method for evaluation of monitoring results and reporting them to relevant parties; and

(vi) A method for reviewing monitoring to better meet the objectives (if required following (iv) and (v)).

The following sections of this IA set out a set of suggested General Conditions which would apply to all marine consents granted. Specific marine consent conditions will subsequently be established for each activity based on detailed evaluation of technical issues and matters raised by the EPA, stakeholders and other parties to the application.

General Conditions

Conditions and clauses such as those set out below will apply to all marine consents granted. The wording as set out here is intended as a basis of consideration by the EPA and other parties and is not intended as the final wording suggested or sought by TTR.

Details of consent

Name of Consent Holder: Consent Granted Date: Purpose of Consent Granted: Expiry Date: Review Date(s): Site Location: Legal Description:

Reference to Chief Executive

1. All references herein to the Chief Executive refer to the Chief Executive of the Environmental Protection Authority (or his or her designate appointed in writing).



Operations in Accordance with Application

2. This consent shall be exercised in general accordance with the application for marine consent dated 21 October 2013 including the Impact Assessment and all supporting documents.

3. At least 3 months prior to the exercise of this consent the consent holder shall provide, to the Chief Executive, detailed plans of the activity to confirm that the proposal is in general accordance with the application and supporting documentation and will comply with all of the conditions of this consent.

Insurance

4. The Consent Holder shall obtain and maintain public liability insurance in the amount of NZ$100,000,000 (or a lesser amount as agreed with the Chief Executive) to cover the potential costs of environmental restoration needed as a result of an unplanned event occurring as part of TTR’s operations which results in major unforeseen environmental consequences.

Public Safety

5. During the exercise of this consent, the consent holder shall take all practicable precautions to protect public safety at all times.

Operations in Accordance with Consent

6. The consent holder shall require all staff and contractors engaged to undertake work authorised by this consent to do so in accordance with the conditions of this consent. A copy of this consent shall be present at the consent holder’s office and on the vessels carrying out the works at all times while the work is being undertaken.

Management Plans and Reports

7. At least 3 months prior to the exercise of this consent the consent holder shall provide to the Chief Executive a written Spill Contingency Management Plan outlining measures to be undertaken in the event of unplanned events which might arise as a result of works authorised by this consent.

8. The Chief Executive shall review the Spill Contingency Management Plan and within 1 month of receiving the Plan from the Consent Holder either: certify that the Spill Contingency Management Plan is appropriate in terms of meeting the objectives set out in condition X [to be completed]; or require further amendments by the Consent Holder to the Spill Contingency Management Plan which must be certified by the Chief Executive prior to the exercise of this consent. The consent holder shall ensure that no fuel or oils enter or are discharged into the marine environment as a result of activities authorised under this consent. This shall include the maintenance of machinery at all times to prevent leakage of fuel or oil into the marine environment. In the event of contamination, the consent holder shall instigate remedial action in accordance with the Spill Contingency Management Plan.

9. At least 3 months prior to the exercise of this consent the consent holder shall provide to the Chief Executive a written Recreational Fishing and Diving Management and Monitoring Plan (RFDMMP). This Plan will establish how the project operations will be designed to minimise effects of sediment plumes on popular fishing and diving locations, and how this will be monitored and reported back to the fishing and diving communities. The location of the areas to be monitored will be determined in consultation with representatives of the fishing and diving communities.

10. The Chief Executive shall review the RFDMMP and within 1 month of receiving the Plan from the Consent Holder either: certify that RFDMMP is appropriate in terms of meeting the purpose of the Act; or requires further amendments by the Consent Holder to the Plan(s) which must be certified by the Chief Executive prior to the exercise of this consent.

Delivery of Reports and Information



11. That on receipt of a requirement from the Chief Executive, or as required as part of conditions of marine consents, the consent holder shall, within the time specified in the requirement or conditions, supply the information required relating to the exercise of this consent.

Reporting

12. Within two months of the commencement of the calendar year the consent holder shall provide the EPA with an annual updated Operation Extraction Schedule containing details of:

a) the areas intended for extraction and deposition over the next 12 months in the forthcoming period;

b) the periods during which extraction and deposition is expected to occur in each specified area;

c) any restrictions that will apply to navigation during the extraction and deposition;

d) volume of material extracted and deposited during the previous 12 month period;

e) GPS locations or chart reference of extraction and deposition; and

f) Cumulative total volumes of material extracted and deposited during the previous 12 month period pursuant to this consent.

13. Within two months of the commencement of the calendar year the consent holder shall forward to the EPA an annual report of the following:

a) Results of any monitoring done in the previous 12 months;

b) Outcomes of the working group meetings over the previous 12 months;

c) Monitoring proposed for the next 12 months; and

Community Liaison

14. Within three months after the commencement of this consent, the consent holder shall invite authorised representatives from entities with Existing Interests likely to be adversely affected by the Project, to form a “Project Consultative Group” (PCG), with the objective of facilitating ongoing consultation between Existing Interests and the consent holder.

15. The consent holder shall invite members of the PCG to meetings as follows:

(i) Annually to discuss and review the monitoring reports produced under the relevant sections of condition(s) of this consent;

(ii) At half yearly intervals to consider and discuss TTR activities over the preceding six month period and projected activities over the forthcoming six month period.

16. The consent holder shall invite representatives of the EPA to all meetings of the PCG.

17. The consent holder shall keep minutes of the meetings held and shall forward them to all attendees.

18. The consent holder shall provide final copies of the reports prepared in accordance with these conditions to the PCG at the meetings held in accordance with condition 13.

Iwi Engagement

19. Within three months after the commencement of this consent, the consent holder shall invite representatives of those iwi with Existing Interests to join a “Kaitiakitanga Komiti” (the Komiti). The consent holder shall invite a representative of the EPA to all meetings of the Komiti.

20. The purpose of the Komiti shall be to:

(i) Facilitate consultation between the consent holder and the Komiti;

(ii) Enable consultation on the Environmental Monitoring and Management Plan (EMMP), with reference to the development of cultural health indicators for key species of importance to Komiti representatives;



(iii) Review monitoring reports on an incremental basis. If necessary technical expertise shall be made available by the consent holder to assist representatives of the Komiti to interpret the monitoring data;

(iv) Identify methods to avoid, remedy or mitigate any adverse effects of the TTR Project on the cultural values, interests, and associations of the iwi with the South Taranaki Bight area; and

(v) Recognise the different cultural associations and interests iwi have in project.

21. The consent holder shall, in complying with the notification requirements of this consent to the consent authority, or when monitoring or research activities are being planned, or when results are to be submitted in accordance with this resource consent, invite the Komiti to a meeting to discuss any matter and share this information prior to submitting the information to the consent authority. The information shall be provided to the Komiti sufficiently in advance of the meeting so that the Komiti has time to review and consider it.

22. Notwithstanding clause 18 and clause 19 the consent holder shall, at least once per calendar year, invite representatives of the EPA and the Komiti to a meeting to discuss any matter relating to the exercise and monitoring of this consent. At this time the consent holder shall, in addition to any matters relating to the exercise and monitoring of this consent, use its best endeavours to inform the Komiti of the likely dredging to be undertaken in the following year.

23. The consent holder shall keep minutes of Komiti meetings and shall forward them to all attendees.

24. The consent holder shall provide final copies of the reports prepared in accordance with these conditions to the Komiti concurrently with them being submitted to the consent authority.

Technical Peer Review Group

25. Within six months after the commencement of this consent, the consent holder shall establish a Technical Peer Review Group (TPRG) with the following brief:

(i) to meet and receive monitoring data and reports from the physical and biological monitoring undertaken as part of the TTR Project as required by conditions [to be confirmed], to evaluate the physical and biological impacts of the TTR Project on the South Taranaki Bight and the receiving waters offshore on an ongoing basis;

(ii) to make recommendations to the consent holder on management actions to remedy and mitigate the adverse effects of extraction and deposition as part of the TTR Project; and

26. The Technical Group shall have but not be limited to the following membership:

(i) Iwi representative(s) appointed by the Komiti;

(ii) a representative of TTR Limited; and

(iii) representative of each of Taranaki and Horizons Regional Councils;

(iv) a suitably qualified technical representative nominated by the local fishing industry;

(v) a suitably qualified specialist in the field of marine ecology;

(vi) a suitably qualified specialist in the field of marine sediment behaviour; and

(vii) the Technical Group may also co-opt additional members to ensure that it has the requisite skills to be able deliver on its brief.

27. The Technical Group shall be serviced by the consent holder and shall meet as frequently as necessary, to undertake its functions listed in subsection 24 of these conditions.

Archaeological Remains (Shipwreck)

28. Where evidence of a potential shipwreck is found in a discrete area, or substantially intact wreckage is encountered, the consent holder shall make reasonable efforts to identify what it is and its likely age. In the first instance a description of the find should be communicated to a consultant archaeologist for identification. Individual finds do not



necessarily constitute an archaeological site, but may indicate the presence of a site nearby.

29. Work should cease in the immediate area while the find is identified. If the wreckage is not a legally protected archaeological site (post-dating 1900), a record should be made of the find and works can resume.

30. If the finds are confirmed as being a legally protected archaeological site (pre-dating 1900), the consent holder shall contact the New Zealand Historic Places Trust Regional Archaeologist in the first instance and obtain an archaeological authority from the New Zealand Historic Places Trust before works affecting the site can proceed.

Monitoring

31. The consent holder shall prepare an EMMP in general accordance with the framework set out in the Impact Assessment accompanying applications for Marine Consents. This EMMP shall be submitted to the EPA at least six months prior to monitoring investigations commencing for the purpose of the EPA certifying compliance and consistency with consent conditions.

32. The objective of monitoring undertaken under the EMMP shall be to confirm that the predictions regarding effects on water quality, marine biota and oceanographic processes as set out in TTR’s Impact Assessment documentation are consistent with actual effects

33. The EMMP shall be designed to guide environmental management for the duration of consented activities, and to inform measures by TTR to avoid, remedy or mitigate any adverse environmental effects associated with consented activities. The EMMP shall include, but not be limited to:

a) a list of key personnel and points of contact;

b) a description of how stakeholders will be kept informed and involved during the maintenance program and how complaints will be managed;

c) a description of the extraction and deposition locations, methodology and associated Permits;

d) a detailed monitoring plan, which describes the scale and intensity of monitoring of potential adverse effects on water quality, underwater noise, marine biota and oceanographic processes;

e) a summary and timetable of all reporting required under this consent;

f) the allocation of responsibility for updating the plan should future amendments be required;

Laboratories

34. All sampling and analyses undertaken in connection with this permit shall be performed by an IANZ registered laboratory or otherwise as specifically approved by the consent authority.



17. ENVIRONMENTAL MONITORING AND MANAGEMENT PLAN INITIATIVES

Introduction

TTR proposes to use an Environmental Monitoring and Management Plan (EMMP) to give effect to conditions relating to environmental and activity performance standards, as well as providing information on monitoring, risk assessment, activity management and reporting measures necessary to ensure the standards are maintained.

The EMMP is the underpinning element of TTR’s approach for environmental management and stakeholder engagement. TTR’s draft EMMP is provided as Appendix 10.

Scope of EMMP

TTR has adopted an EMMP framework based around widely accepted quality management concepts, covering the following matters:

relevant environmental performance objectives and performance standards how objectives and performance standards will be achieved detailed monitoring programme and on-going risk assessment procedures activity management procedures reporting measures necessary to ensure standards are maintained auditing and review

TTR’s approach to developing the EMMP is summarised in Figure 108 TTR proposes to finalise the EMMP in consultation with stakeholders.

Figure 108: TTR Environmental Monitoring and Management Programme



Environmental Objectives

Every management system must incorporate clear objectives against which management progress can be measured. The overall objective of the TTR EMMP is to set out a framework to achieve TTR’s environmental management objectives which are to demonstrate that the actual effects of TTR’s operations are consistent with those predicted in application documentation, in the following areas:

Benthic habitat in near and far field areas attributable to the Project Distribution and abundance of benthic organisms in near and far field areas

attributable to the Project Water quality including colour and clarity at identified sensitive locations Noise generated by extraction activities on marine biota beyond the extraction

area Commercial fishing Recreational fishing Customary fishing Surfing breaks Visual amenity (land and sea based)



18. OVERALL EVALUATION The purpose of the EEZ Act is to promote the sustainable management of the natural resources of the exclusive economic zone and the continental shelf.

This Impact Assessment supports applications under the EEZ Act for marine consents for the TTR’s Project, and has been prepared on the basis of the “best available information” from a range of studies commissioned by TTR from leading environmental specialists.

The Project design has incorporated a number of significant mitigation measures which have collectively enabled TTR to avoid remedy or mitigate many adverse effects.

In the IA, all of TTR’s proposed activities have been evaluated with potential environmental effects identified in respect of physical, ecological and social aspects.

The Project is not anticipated to adversely affect the nearshore environment including public access, and will not have a more than minor effect on the South Taranaki Bight wave climate.

The Project will result in adverse effects in the immediate vicinity of the extraction area primarily relating to sediment dispersion in the water column, but effects will dissipate nearer to shore. Ecological recovery within the extraction area is anticipated within a few years, and the operation is not considered to present any issues in respect of protection of biological diversity in the broader STB area. No rare or vulnerable ecosystems or habitats of threatened species have been identified as being potentially affected by the TTR Project.

Recreational and social effects are limited, and derive from the above bio-physical effects.

The Project will create tangible economic benefits to NZ, including the creating of more than 250 jobs.

It is concluded that granting consents for the Project as applied for, is consistent with the purpose of the EEZ Act.



REFERENCES

AWE (2013) “Taranaki Basin Exploration & Development Drilling 2013 AWE Limited” Impact Assessment AWENZ-RPT-1304, AWE Limited (2013) 20th September 2013

Barlow (2013) Trans-Tasman Resources Limited, South Taranaki Bight, Offshore Iron Sand Extraction and Processing Project, Report on the Maritime and Navigational Impacts of the Project, August 2013. Prepared by Captain R N Barlow Master Mariner MNI; R. N. Barlow and Associates Limited.

Boffa (2013a) “Other Marine Management Regimes Assessment: South Taranaki Bight Offshore Iron Sand Project” prepared for TTR, October 2013.

Boffa Miskell (2013b) “Seascape and Natural Character and Visual Effects Assessment” October 2013

Cawthorn (2013) Cetacean Monitoring Report, Report prepared for Trans-Tasman Resources Ltd Cawthorn & Associates Limited (October 2013

Clough & Associates (2013)

“TTR South Taranaki Bight offshore iron sand project: archaeological assessment” August 2013

Corydon (2013) ”Social Impact Assessment of TTR Iron Sand Mining Proposal” October 2013

Fathom (2013) “South Taranaki Bight iron sand mining proposal Assessment of potential impacts on commercial fishing” Fathom Consulting Ltd July 2013

Greenaway (2013) “Trans-Tasman Resources Ltd Seabed Mining, South Taranaki Recreation and Tourism Assessment of Effects”, Greenaway (2013) “Trans-Tasman Resources Ltd Seabed Mining, South Taranaki Recreation and Tourism Assessment of Effects Final” October 2013.

Hegley (2013) “Trans-Tasman Resources Ltd - Offshore Iron Sand Extraction And Processing - Assessment Of Noise Effects” Report No 9101, prepared for TTR by Hegley Acoustic Consultants Limited (October 2013)

IMAS (2013) “Assessment of sediment deposition and re-suspension behaviour of tailings. Phase 2: influence of surface waves” A report prepared by IHC Mining Advisory Services, MTI Holland and Svasek Hydraulics in cooperation with Delft University of Technology for TTR, July 23 2013.

LG Torres (2013) “Evidence for an unrecognised blue whale foraging ground in New Zealand”, New Zealand Journal of Marine and Freshwater Research, Volume 47, Issue 2, 2013..

Marico (2103) “South Taranaki Bight Shipping Study” report prepared for TTR by Marine and Risk Consultants Ltd, July 2013”

Ecoast Marine (2013) “Potential Effects of Trans-Tasman Resources Mining Operations on Surfing Breaks in the Southern Taranaki Bight” October 2013

MFE (2005) “New Zealand Marine Environment Classification” NZ Ministry for the Environment 2005.

NIWA (2011) “South Taranaki Bight Factual Baseline Environmental Report” NIWA Client Report: WLG2011-43 September 2011

NIWA (2012a) “South Taranaki Bight Iron Sand Mining: Oceanographic measurements data report” August 2012

NIWA (2012b) “Schedule N, Part 2: Sediment characterisation analysis: particle size of samples from cores STH010RC and STH012RC” June 2012

NIWA (2012d) “Coastal stability in the South Taranaki Bight”

NIWA (2013a) “Benthic flora and fauna of the Patea Shoals Region, South Taranaki Bight” October 2013



NIWA (2013b) “Benthic habitats, macrobenthos and surficial sediments of the nearshore South Taranaki Bight” June 2013

NIWA (2013c) “Geological Desktop Summary Active Permit Areas 50753 (55581, 54068 and 54272, South Taranaki Bight”

NIWA (2013d) “Habitat models of southern right whales, Hector's dolphin, and killer whales in New Zealand” NIWA Client Report No: WLG2012-28 October 2013

NIWA (2013e) “Satellite ocean-colour remote sensing of the South Taranaki Bight from 2002 to 2012” October 2013

NIWA (2013f) “Seabirds of the South Taranaki Bight” NIWA Client Report No: WLG2013-15 March 2013

NIWA (2013g) “South Taranaki Bight Fish and Fisheries” NIWA Client Report No: WLG2012-13 January 2013

NIWA (2013h) “Zooplankton and the processes supporting them in Greater Western Cook Strait April 2013

NIWA (2013i) “Coastal stability in the South Taranaki Bight - Phase 2 Potential effects of offshore sand extraction on physical drivers and coastal stability” October 2013

NIWA (2013j) “South Taranaki Bight Iron Sand Extraction Sediment Plume Modelling - Phase 3 studies” October 2013

) NIWA (2013k) “Optical effects of an iron-sand mining sediment plume in the South Taranaki Bight region”, NIWA Client Report WLG2013-45, October 2013

NIWA (2013l) “South Taranaki Bight Iron Sand Mining Nearshore Wave Modelling Phase 4 Studies” NIWA Client Report No: HAM2013-091 October 2013

NIWA (2013m) “Effects of ships lights on fish, squid and seabirds” NIWA Client Report No: WLG2013-16, April 2013, NIWA Project: TTR11301

NZIER (2013) Economic assessment of the Trans-Tasman Resources Ltd Iron Sand Project Modelling assumptions and main results NZIER draft report to Trans-Tasman Resources Ltd. October 2013

Page M, Murdoch R, Battershill C. (1992)

“Baseline Environmental Survey of the Macrobenthic Community at the Proposed Kupe South Oil and Gas Condensate Field August – September 1992”. A report to Western Mining Corporation, Perth, Western Australia by National Institute of Water and Atmospheric Research, Report No. 1992/20.

Subacoustech (2013) “Modelling of subsea noise during the proposed piling operations at the Dudgeon Wind Farm” Report prepared for Royal Haskoning DHV by Subacoustech Environmental ref: E438R0106, July 2013

Tonkin and Taylor (2013a)

“Air Dispersion Modelling Study – Gas Turbines”

Tonkin and Taylor (2013b)

“Air Dispersion Modelling Study – Reciprocating Engines””

Vopel K, Robertson J and Wilson P.S. (2013)

“Iron sand extraction in South Taranaki Bight: effects on seawater trace metal concentrations” AUT Client report: TTRL 20138 October 2013

methodology - evaluation of effects - epa · 2019. 4. 6. · wellbeing framework which has been...

Documents