Only three ‘bedrock’ samples in the Hawera Patea region Gravelly sand, particularly coarse over the rolling ground The map shows the variability in the STB seafloor. These variations offer a different habitat for species. E.g. gravel and shell ‘encourages’ diversity – whereas mudstone less so.
A map showing the area which will receive the highest levels of sediment from the plume, when mining is at point A. Note the importance of shell hash to the area. It is important to note the Project site will not have this shell hash layer. Benthic Joint Witness Statement mentions sediment grain size important in structuring benthic organisms (pt 15) but fails to note shell hash! Note the importance of shell hash to the region that falls under most exposure to the sediment plume from mining at site A. The replaced sand at the project site will not have this shell hash cover, the shell will be all mixed up.
The following is a list of deficiencies (reported on by Dr Paavo, 24 February 2014,) with the reports and methodologies on the benthic ecology. I had also identified a number of these in my submission. (pages 112-116 of my submission). A VERY IMPORTANT OBSERVATION, IS THAT DR PAAVO CANNOT SIGN OFF ON THE BENTHIC ECOLOGY JOINT STATEMENT BECAUSE OF A WHOLLY INAPPROPRIATE EDITING JOB Macro-faunal abundance can change 2-3 fold over seasons – NIWA sampling didn’t account for Gross design error – inadequate measures to mitigate the dredge samples, but not the core NIWA used methods with very low likelihood of recording the important community of certain shell species – T laticostata and Panopea Sampling methods would not enable the detection and quantification of communities most likely to be negatively impacted Using a single core sample for faunal and sediment analysis is outmoded and unacceptable practise & extraction of data from imagery well below internationally accepted standard and international practise MEIO-FAUNAL – IMPORTANT COMMUNITY, WHICH OFTEN PROVIDE THE READILY DETECTABLE ANIMAL COMMUNITY RESPONSE TO TRACE METALS AND NUTRIENTS – sampling from a small subset with a RESTRICTED BATHYMETRIC RANGE COLONISATION EXPERIMENT must be entirely withdrawn from DMC consideration. The authors draw conclusions from inappropriate data. Scientifically egregious. The investigators did not do due diligence on re-colonisation studies of subtidal sandy Dr Paavo disagrees that re-colonisation of de-ored sediments will be primarily through juvenile substrates. ‘Grey literature’ has information on this. planktonic recruitment.
IMPACT ON ‘PRIMARY PRODUCTION’, the ‘Euphotic zone’ – THE START OF THE FOODCHAIN NUTRIENTS LIGHT Post-grind Filtered ‘run At the mining site the tailings of mine’ ‘euphotic zone’ goes from sediment sediment 30m – 3m (PGT) (NSC) The sediment reduces the amount of 10km from the mining site the light reaching the plankton in the sea ‘euphotic zone’ goes from 25m and the algae on the seafloor to 12m The start of the FOOD CHAIN Energy/primary production (PP) They live and PHYTO PLANKTON – which die within a needs light for photosynthesis few km, and only live for a day or two. So STB pyto- plankton have been ALGAE ON THE SEABED – which needs light for photosynthesis produced in *seaweed (macro-ALGAE) & *micro-ALGAL cells (benthic-ALGAE) the STB NIWA approach to finding the percentage of reduction in ‘primary production’ PP – due to the reduced light. (point 16: 18 th March report) Average water column ‘primary production’ PP reduction across the STB due to the shading by sediment – is half the change of light. The logic
Some of the environmental considerations Perhaps in future there could be a ‘standardised tick box’ where experts acknowledge they have read which reports. Their findings can then be read in light of this. i.e. limitations to their findings understood. Sulphur Chemicals dioxide added to emissions desalination from process; Souter burning pt 17 heavy fuel oil De-salination chemicals FPSO Ship Concentrated metals from rinsing and grinding sand MOUNDS BRINE from 8 – 9 Fine de- metres sediment, salination high, 2.4 plant – without million Fine changes sea shell hash tonnes plume from 35pt p.a into Total from to 37pt the water approx. suction column 14km long head PITS As saline denser than seawater – forms a plume 5- 9-10m 10m from the seafloor Recovery time from the tens to hundreds of Sea floor without shell hash layer (important for biota) and metal years. concentrations, e.g chromium, copper and nickel considerably greater e.g. mg kg̅ ¹ chromium <0.34 goes 8.23, 15.92, 27.75 etc
The picture illustrates the ecological importance of the area close to and including the project site for primary productivity 650 km ² is the area getting more than 1% of surface light – a mere 4.9% of the STB WITH MINING at site A (close by the EEZ border of 12nautical miles). A reduction of 48% from 650 km ² to 316km² due to mining at site A. WITH MINING at site B (getting towards the bottom area of the Project site). A reduction of 57% from 650 km² to an area of 263km² due to mining at site B. RECOMMENDATIONS TO THE DMC
GRAHAM BANK – EUPHOTIC ZONE – SIGNIFICANT CHANGE FOR THIS ECOLOGICAL NICHE Euphotic depth Days that euphotic 24.2m depth is more than 1% : 213 days 31% / 47% 65% / 37% reduction reduction 74 days/site A Euphotic depth 12.7m /site A 133 days/site B 16.7m /site B
TTR’s ‘social license to date Community Trust -clarify ecological compensation Experts in commercial fishing Reports on metal recommend that EPA be provided with toxicity effects not further information on uptake of done at at March heavy metals within fish and shellfish flesh, any human risks, and market 2014 acceptability risks 26 March 2014 "open door policy' Bill Bisset - yet K Pratt's e-mail in Need to publish concentrated November regarding metal testing on site available "Social License necessary dilution for to the public. Metallurgy metals was testing and bio-assays. acknowedged by TTR but no further information provided No subsequent letter to Maori When Impact Assessment issued, TRC, the tribes or Council retracting the local fishing community and Nelson issues of Vanadium and the lack fisheries were unaware of a 'metals issue'. of sea life Letter issued by TTR in 2009 to Maori tribes and Councils about underwater work showing the sands are toxic to sea life because of the presence of Vanadium, the seabeds in these areas containing no shellfish or vegetation
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