Ministry for the Environment report (2016): adaptive management in relation to seabed mining: ‘ it is clear that adaptive management cannot compensate for a lack of baseline environmental data or inadequate modelling. In the words of the King Salmon Board of Inquiry, some information gaps cannot “be simply filled by invoking adaptive management ”.’
Questions • Have TTRL used the best available information? • Is the baseline data adequate for designing a fit-for- purpose adaptive management plan? • Will the adaptive management and monitoring proposed adequately protect the environment? • Primary productivity • Reefs • Marine mammals • Sea birds
Primary Production • Large reduction in light: 10-40% over 704 km 2 mining @ Site A • Only provided averages of PP over Sediment Model Domain • No modelling to assess PP downstream of mined area • No measurements of primary productivity i.e. growth or photosynthetic rate at all • Monitor biomass using chlorophyll a : Photoadaptation? • Not adequate to assess knock-on effects within foodweb • Raises serious concerns about impacts within the wider ecosystem
Reefs • Limited benthic sampling within the area of the plume • Large sections within area of plume: not been surveyed
Reefs – multibeam surveys
Reefs
Reefs • DOC GIS package indicates many reefs within influence of plume:
Reefs • South Taranaki Underwater Club, Karen Pratt & local fishermen have reported many reefs within influence of plume • High biodiversity values: CoastBlitz Patea (on NatureWatch NZ)
Reefs • Project Reef (South Taranaki Underwater Club )
Reefs • Project Reef (South Taranaki Underwater Club )
Reefs • Project Reef (South Taranaki Underwater Club )
Reefs • Project Reef (South Taranaki Underwater Club )
Reefs • The Crack (South Taranaki Underwater Club )
Reefs • Inadequate baseline information on rocky reefs in application • Large areas of plume not yet surveyed e.g. Graham Bank • Missed the Crack (4 nautical mile long, close to mining area) • Adequate baseline data is required at the application stage for designing a fit-for-purpose adaptive management plan
Marine Mammals • Multiple witnesses demonstrate: TTRL not used best available info in application e.g. Torres, Slooten, val Helden • Orca data in TTRL application inadequate: 6 sightings 25 years • Project Hotspot: 84 orca sightings 1 year, 29 different days
Marine Mammals • TTRL Habitat Model: Taranaki poor to moderate habitat for orca • Project Hotspot sightings and observations: Taranaki good habitat for orca • Often observed actively feeding on rays (50% of sightings ‘feeding’)
Urenui Beach feeding on rays 30 Oct 2016
Marine Mammals • Inadequate baseline information on marine mammals in application • Adequate baseline data is required at the application stage for designing a fit-for-purpose adaptive management plan
Seabirds • TTRL not used best available info in application (see NMMRS submission & Cockrem evidence) • TTRL used eBird: No sightings of little blue penguins in Taranaki • Compare with NatureWatch NZ: 236 Taranaki little blue penguin sightings
• Evidence: Waters off South Taranaki are important feeding ground for little blue penguins: • Observations from fishermen • Tracking penguins from Motuara Island, Marlborough Sounds (Poupart et al ., accepted by NZ J. Ecology)
Poupart T, Waugh S, Bost C, Bost C-A, Dennis T, Lane R, Rodgers K, Sugishita J, Taylor GA, Wilson J, Zhang J, Arnould JPY. Variability in the foraging range of Eudyptula minor across breeding sites in central New Zealand. New Zealand Journal of Zoology • GPS trackers • Motuara Island • Spring 2015 • Incubating eggs • 11 of 14 penguins tracked: swam to South Taranaki • Must be a reason for this
Seabirds • Two genotypes of little blue penguins (see submission) • Only handful of large populations (>200) of NZ genotype • Sediment plume: increased water turbidity and disruption to food web: affect penguin foraging efficiency • Sand mining: put further stress on struggling penguin colony at Motuara Island, low breeding success • Potential impacts at taxon level
Seabirds • Inadequate baseline information on seabirds in application • Available data indicates: shelf waters of South Taranaki important feeding ground for ‘at risk’ little blue penguin • Potential for impacts at the taxon level (NZ genotype) • New Zealand Coastal Policy Statement: avoid adverse effects • Decision Making Committee must favour caution and environmental protection and decline this application
Questions • Have TTRL used the best available information? NO • Is the baseline data adequate for designing a fit for purpose adaptive management plan? NO • Will the adaptive management and monitoring proposed adequately protect? NO
NMMRS Submission “It is not clear how long-term ecological impacts from the mining will be separated and identified from natural variability in order to trigger a management response prior to tipping points being reached and unacceptable impacts occurring ”
Additional question • Can TTRL correctly interpret the data and respond in order to prevent long-term unacceptable impact from occurring?
Govier Evidence (para 182) “I have seen areas completely covered by more than 1 m of sand and then within a year of the sand retreating, the reef was healthy again with high species diversity and high abundances of both intertidal seaweeds and animals. I took a photograph of a section of reef at the end of Greenwood Road, Taranaki which is a control site for the TRC in September 2003 and when I returned to the reef in January 2014 the sand had receded and the marine life was recovering which was supported by the monitoring results. Ongoing ecological monitoring by the TRC also concurs with this observation of sand inundation and recession along the Taranaki intertidal coastline .”
TRC Rocky Shore Report https://www.trc.govt.nz/assets/Documents/Environment/Monitoring- SOE/Coast/RockyShore2008-2015.pdf
TRC Rocky Shore Report • Trend analysis shows a significant decrease in diversity at Greenwood Rd Reef over 21 years, p20 • The sand adjusted trend indicates that this decrease in diversity was related to an increase in sand accumulation
TRC Rocky Shore Report • TRC report concludes: • Greenwood Rd is prone to periodic sand inundation • Trend analysis indicates that there has been a significant decrease in species richness and diversity at this site which appears to have been caused by an increased sand supply from the mountain, combined with oceanographic conditions that shift this sand onshore • In his evidence, Govier fails to recognise that ongoing periodic sand inundation has resulted in a significant long-term decrease in species diversity at Greenwood Rd Reef • This example relates to naturally occurring events inshore • Is the TTRL monitoring plan and adaptive management sufficient to avoid similar misinterpretation re the offshore reefs?
Questions • Have TTRL used the best available information? NO • Is the baseline data adequate for designing a fit for purpose adaptive management plan? NO • Will the adaptive management and monitoring proposed adequately protect? NO • Can TTRL correctly interpret the data and respond in order to prevent long-term unacceptable impact from occurring? Concern
Conclusion • Adaptive management will not adequately protect given the inadequate baseline data • Tipping points may be reached before a management response is triggered • The application is not in line with the Information Principles of the EEZ Act and policies of the New Zealand Coastal Policy Statement • The Decision Making Committee must favour caution and environmental protection and DECLINE this application
Ngā mihi
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