BEFORE THE EPA CHATHAM ROCK PHOSPHATE MARINE CONSENT APPLICATION IN THE MATTER of the Exclusive Economic Zone and Continental Shelf

(Environmental Effects) Act 2012 AND IN THE MATTER of a decision-making committee appointed to consider a marine

consent application made by Chatham Rock Phosphate Limited to undertake rock phosphate extraction on the Chatham Rise

__________________________________________________________

STATEMENT OF EVIDENCE OF GERARD VAN RAALTE FOR

CHATHAM ROCK PHOSPHATE LIMITED

Dated: 28 August 2014

__________________________________________________________

__________________________________________________________

Barristers & Solicitors

J G A Winchester / H P Harwood Telephone: +64-4-499 4599

Facsimile: +64-4-472 6986 Email: james.winchester@simpsongrierson.com

DX SX11174 P O Box 2402 Wellington

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CONTENTS

EXECUTIVE SUMMARY ..................................................................................................... 4

INTRODUCTION .................................................................................................................. 6

Qualifications and experience ..................................................................................... 6

Code of conduct ............................................................................................................ 7

Role in marine consent application ............................................................................ 7

Scope of evidence ......................................................................................................... 8

THE MINING CONCEPT AND MINING VESSEL ............................................................... 9

Mining concept .............................................................................................................. 9

The mining vessel ......................................................................................................... 10

Dredge mining unit ....................................................................................................... 12

Processing sediment on-board the vessel ................................................................. 15

The management of the returns .................................................................................. 17

Seabed mining plan ...................................................................................................... 18

Vessel activity cycle ..................................................................................................... 20

Crewing .......................................................................................................................... 20

OPERATIONAL CONTROL ............................................................................................... 21

Monitoring and compliance with thresholds ............................................................. 21

Suspended sediment or sedimentation threshold ............................................... 22

Change in oceanographic ....................................................................................... 22

Different sediment composition ............................................................................. 23

Disruption in the mining system ............................................................................ 24

Sound threshold ....................................................................................................... 24

Vessel safety .................................................................................................................. 25

On-board vessel environmental matters .................................................................... 27

Waste management.................................................................................................. 27

Wastewater................................................................................................................ 27

Oily waste .................................................................................................................. 27

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Emissions to air ........................................................................................................ 28

Ballasting .................................................................................................................. 28

Vessel lighting .......................................................................................................... 28

VALIDITY OF THE MINING METHOD ............................................................................... 29

Decisions on mining approach made as the project has progressed .................... 29

RESPONSES TO SUBMISSIONS ..................................................................................... 31

Deepwater Group .......................................................................................................... 32

Moriori ............................................................................................................................ 33

Paua Mac ........................................................................................................................ 33

KASM .............................................................................................................................. 35

ECO ............................................................................................................................... 37

Greenpeace .................................................................................................................... 37

CONCLUSION .................................................................................................................... 38

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EXECUTIVE SUMMARY

1. The proposed mining method is a combination of existing state of the art

techniques, applied in a new context. The proposed method combines the best

available technology with the best environmental practices. Every effort has been

and will be made to ensure safe and environmentally responsible operations, and

this commitment will be maintained through regular monitoring of the system

performance and on-going refinements of the equipment and operations.

2. The mining concept is based on modern, but conventional trailing suction hopper

dredger operations, widely used around the world to dredge seabed materials.

While the proposed mining method has not been undertaken previously in this

depth of water, the technology involved is well understood and, based on our

research and experience, we have no doubt it will work effectively and as intended

for this project. There is no issue with the technical feasibility of the mining

technology we propose to use.

3. Designing the mining system required knowledge of the nature of the sediments

and their physical properties and the shape of the sea floor. CRP’s research has

been essential for the design of the mining system. The design of the mining

system requires consideration of the physical properties of the sea floor sediments.

During the planning and design stage extensive analysis was carried out into all

geotechnical and geophysical parameters known about the Chatham Rise from

various research cruises.

4. The actual mining tool, the drag-head, will be based on conventional designs,

modified for the sediment properties on the Chatham Rise. The drag-head will have

jets that will direct high-pressure water into the seabed to loosen the sediments,

which will be captured and transported through the pipes and pumps of the

dredging and pumping unit to the riser.

5. After being pumped to the mining vessel all seabed material will be processed on-

board by a nodule separation plant. This system, tailored for this specific

application, is composed of elements and processes that are commonly used in

sediment handling, separation and dewatering. No new or untested components

are used in this set-up.

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6. Processed sediment less than 2 mm in size will be returned to the seabed via a

sinker pipe and a diffuser that will release the material near the seabed. The

sinker, transporting the non-phosphorite material back to the seabed, consists of a

large diameter pipe (current design is 750 mm diameter). At the lower end of the

sinker, a diffuser will be installed to limit the turbid plume generation and the spatial

extent of the sedimentation footprint. Returns will be released at 10 m above the

seabed on average because analysis of the dynamics of the sinker and diffuser

system indicated that deployment of the diffuser in this way offers the best control

of operations.

7. The seabed mining plan is governed by two factors: the operational efficiency of the

mining vessel and the minimisation of seabed disturbance. To optimise the mining

process and utilisation of the mining area, a pattern of mining tracks has been

developed in close consideration of the prevailing metocean conditions. Mining will

be in long parallel tracks, with a 180 degree turn at the end to continue mining in

the opposite direction. This technique forms a mining pattern of long stretched

loops.

8. In an optimised dredging process the draghead is kept on the seabed as long as

possible. It is therefore preferable to sail straight tracks with a section length as

long as possible before turning. By systematically working along this pattern, an

ever wider spiral will form. The optimal block width is 2 km.

9. The mining vessel will generally operate on a 10 day cycle. Allowing for average

workability conditions, it is expected that about 30 trips can be made per year.

Each cycle will generally operate as follows:

(a) a mining, processing and hopper filling phase (4 to 5 days);

(b) transit to port (1.5 days);

(c) offloading and re-provisioning (3 days); and

(d) transit to Chatham Rise to commence the next mining cycle (1.5 days).

10. While I am confident in our predictions of the mining activity and its effects, in the

unlikely event that identified environmental thresholds are exceeded, I am equally

confident in our ability to adapt operations to bring the operation into line with the

conditions of consent. Because of Boskalis' experience and track record, we are

prepared for all foreseeable contingencies.

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11. Safety has been a priority within the Boskalis organization for years and Boskalis'

safety record in recent years is exemplary. Processes onboard the mining vessel

are highly automated and centrally controlled to maximise working safety.

Emergency systems are installed and are in continuous operation.

12. In terms of environmental management on the vessel, its operation will be adhere

to the international laws and standards (specifically MARPOL), as well as the

additional requirements that follow from New Zealand law. A project specific

environmental management plan will be drafted and agreed before start of the

works, outlining all project rules. This applies to oily waste, hazardous substances,

wastewater, garbage (solid waste), emissions to air, ballasting and hull biofouling.

13. The proposed mining concept, tailored to mining on the Chatham Rise, is based on

a combination of techniques, methods and procedures that are already used in

dredging and seabed material reclamation, on a large scale. The proposed system

has been designed based on best available practices, supported by dedicated

studies and expert assessments. In my opinion, the system is able to cope with the

variable seabed conditions, and will, whilst operating, provide adequate survey data

for further optimisation and fine-tuning of the processes. Based on substantial

study and development, founded on many years of experience in dredging, dredged

material handling and management of the environmental effects of dredging and

disposal, my team and I are confident that the design is fundamentally sound, and

will perform as expected.

INTRODUCTION

Qualifications and experience

14. My full name is Gerard Henri van Raalte.

15. I have a degree in Civil Engineering from the University of Technology, Delft,

Netherlands. I am a member of the Royal Dutch Society of Engineers (KIVI), the

Central Dredging Association (CEDA) and the Permanent Institution of Navigational

Congresses (PIANC). In the latter two organisations I am a regular member of

international working groups that provide guidelines and establish standards for the

industry.

16. I am a Senior Expert at Boskalis / Hydronamic bv, Port & Waterway Engineers,

Papendrecht, The Netherlands, and have held that position since 2004. Prior to

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that, I worked for Boskalis / Hydronamic as a specialist / engineer / project

manager.

17. My principal role has a special focus on dredging and marine infrastructure project

design and environmental related aspects, during project development and

execution.

18. Within the Building with Nature Research Programme, Netherlands, I have been

responsible for the preparation of the Eco-dynamic Development and Design

Manual, disseminating results of the 5-year research program (2008—2012). (see

www.ecoshape.nl)

19. Throughout 2007 to 2010, I was responsible for the design and engineering tasks

associated with the design and construct contract for the new Khalifa Port and

Industrial Zone Project in Abu Dhabi, U.A.E. This involved dredging, reclamation,

quaywall and bridge construction and breakwater and revetment construction,

inside an environmentally sensitive marine area (corals and seagrasses).

20. Throughout 2004 to 2006 I provided specialist advice to the Alliance between the

Port of Melbourne Corporation and Boskalis Australia on environmental aspects of

dredging during project preparation for the large scale channel deepening project in

Port Phillip Bay, Melbourne Australia: a technically challenging project in an

ecologically valuable environment. (http://www.portofmelbourne.com/port-

development/port-projects/channel-deepening-project)

Code of conduct

21. I confirm that I have read the Code of Conduct for expert witnesses contained in the

Environment Court of New Zealand Practice Note 2011 and that I have complied

with it when preparing my evidence. All statements in this evidence are based on

the work performed within the Boskalis’ project team, supplemented with my own

personal expertise. I have not omitted to consider material facts known to me that

might alter or detract from the opinions that I express.

Role in marine consent application

22. I have been involved in a number of aspects of this project in relation to the

planning, engineering, and design for the project.

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23. I have been responsible for and actively contributing to the design and planning of

the mining process and equipment. A key part of my role has been to assess the

environmental implications of all alternative options to select the best mining

method.

24. I have also been involved in deriving the mining process parameters that were to be

used by Deltares as input to their plume modelling studies: mass flow and material

composition of material to be returned to the seabed after onboard separation of

mine product from the mined seabed material. Boskalis’ in-house models, based

on many years of project data and experience have been applied for this study.

Based on outcomes of these studies, adaptations have been made to the mining

process, to further reduce environmental impact, while maintaining technical

feasibility. This has resulted in the material return system as described further

below (paragraph 50 and further).

25. Furthermore, I have been providing operational and environmental data of the

equipment intended to be used for this project, as well as the records of previous

environmental performances of Boskalis’ equipment and procedures, as input to the

environmental impact assessment studies (refer paragraphs 94 and 101).

Scope of evidence

26. In this brief of evidence, I will describe and discuss:

(a) the mining concept and the mining vessel;

(b) how mining will occur on the seabed;

(c) how phosphate will be separated from the seabed material;

(d) how non-phosphatic material will be returned to the seabed

(e) aspects of the operation of the mining vessel; and

(f) vessel safety;

(g) validity of the mining method.

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THE MINING CONCEPT AND MINING VESSEL

Mining concept

27. The mining concept is based on modern, but conventional trailing suction hopper

dredger operations, widely used around the world to dredge seabed materials

(sand, gravel, clay, soft rock).

28. A key feature of the mining vessel is a detached, suspended drag-arm with drag-

head, capable of dredging in the water depths associated with the mining area and

under harsh metocean conditions. The mined material will be transported through a

riser pipe up to the vessel for on-board separation of the phosphorite nodules from

the finer sediments. The product material will be stored on board for transport to

shore, and the non-phosphorite material will be returned to the seabed through a

sinker (similar to the riser) with a diffuser.

29. Designing the mining system required knowledge of the nature of the sediments

and their physical properties and the shape of the sea floor. CRP’s research has

been essential for the design of the mining system. The design of the mining

system requires consideration of the physical properties of the sea floor sediments.

The size of the draghead, the water jet design (number, configuration and flow), the

power in the pump unit, and the size of the riser, sinker and the processing plant

are all based on how the sediments react to jetting (like clay or like silt) and how

much of the underlying clay may be included in the mined material.

30. Understanding of the composition of the seabed is essential for designing and

operating the mining system, and more specifically for the draghead and separation

system (see Figure 1). As stated in other evidence the Chatham Rise phosphorite is

comprised of phosphorite nodules that are loosely distributed within a layer of

glauconitic sand. The glauconitic sand is commonly about 20 centimetres thick but

ranges up to 70 cm maximum thickness (Figure 1). The sand matrix is a pelagic

lag deposit comprised of 20-40% silt and 30-60% fine to very-fine sand. Thickness

of the glauconitic sand varies significantly over distances of tens of metres or less.

The concentration of phosphorite nodules varies both vertically and laterally.

31. Underneath this surficial sediment is an ooze or chalk layer which is composed

primarily of foraminiferal nanofossils. The ooze/chalk is usually stiffer than the

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overlying sandy silt layer. In many places the boundary between the two layers is

distinct and in others it is gradational, affected by bioturbation.

Figure 1: Schematic of Chatham Rise seafloor composition

The mining vessel

32. The mining vessel design and size are dictated by Chatham Rise sea conditions,

required production tonnage and hopper volume, requirements for the storage of

phosphorite nodules, and the space required for on-board processing of dredged

seabed material. The mining vessel is basically a bulk material carrier or tanker,

modified for seabed mining, along the concept of Trailing Suction Hopper Dredgers

used worldwide for capital and maintenance dredging and for the offshore

extraction of reclamation materials (Refer Figure 2 and Figure 3).

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Figure 2: Trailing Suction Hopper Dredger Seaway.

Figure 3: Deck Overview of a Trailing Suction Hopper Dredger with suction pipes and dragheads on both

sides of the vessel.

33. The proposed seabed mining operation requires accurate positioning and

movement of the drag-head to follow the mining plan. The position of the vessel

and drag-head will primarily be controlled by a dynamic positioning (DP) and

dynamic tracking system (DT) on the vessel, in conjunction with two electrically

driven, azimuth thrusters on the drag-head.

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Dredge mining unit

34. The dredging unit consists of a pumping unit and suction pipe with a drag-head.

The pumping unit is suspended above the seabed, with the drag head being trailed

over the seabed. One pump will suck up the seabed material and another pump will

push the mixture through the riser to the mining vessel. A third pump will be used to

provide the jet water for the draghead. The total calculated pump power for suction

operation and transport via the riser to the ship is 10 to 12 MW. This pumping

power is divided over the electrically driven pumps, which will be used in series.

The dredge pumps are of common design and have a high efficiency.

35. The electro-motors used for driving the pumps are modified from an existing design

for high voltage use. To compensate for the pressure of the water depth, the motor

compartment is oil filled and pressure compensated. This is also a commonly used

system for underwater dredge pump motors.

36. The drag-head will be based on conventional designs, modified for the sediment

properties on the Chatham Rise. The drag-head will be about 5 m wide and 1 m

long. It will have jets that will direct high-pressure water into the seabed to loosen

the sediments. Jet-water pressure and jet-water flow can be modified to account for

differences in sediment properties to reduce disturbance of the underlying chalk.

The drag-head will capture the loosened sediments and they will be transported

through the pipes and pumps of the dredging and pumping unit to the riser. A

screen on the drag-head will ensure that material greater than 150 mm is not taken

up into the pumping unit and riser. That material will return directly to the seabed .

37. As in all drag-head operations, the details of its configuration (e.g., number and size

of jets) may be modified based on an on-going assessment of its performance.

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Figure 4: Dredging unit designed to minimise chalk disruption

38. The suction pipe is 750 mm (internal diameter) and is attached to the end of the

drag-head, with a pipeline to feed jet water to the drag-head for seabed fluidisation.

39. The pump-frame, suction pipe and drag-head are suspended from the ship on four

steel wires. Two hoisting wires are connected to the pump-frame, one to the drag-

head end of the suction pipe and one long forward tow-wire to the forward end of

the suction pipe that is an active pulling wire. The system is capable of

compensating for speed variations caused by wave-induced variations in the motion

of the ship.

40. The dredging unit will be equipped with navigational aids. The pumping unit is likely

to be equipped with hydraulically driven thrusters and the drag-head with a single

thruster. These thrusters will, in conjunction with the vessel positioning system, be

able to position the frame and the attached suction pipe onto the desired mining

track. The total weight of the pump-frame will be approximately 300 tons and the

drag-head will weigh between 30 and 50 tons. The expected force on the sea floor

is 15-20 tons.

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41. Hydraulic transport of the material from the pump unit to the surface vessel will be

through the riser pipe. This ‘riser’ is composed of 12m long sections connected by

bolted flanges, lowered and hoisted by a system comparable to systems used on

deep ocean rock placing vessels.

Figure 5: Diagram of mining vessel

42. During the planning and design stage extensive analysis was carried out into all

geotechnical and geophysical parameters collected during the investigative cruises

described by Mr Wood in his evidence.

tow line

riser

sinker

pump unit

draghead

diffuser

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43. Within the Boskalis contribution to these material studies, special attention was

given to working out how to excavate the upper sandy silt layer containing the

phosphorite material without dislodging the underlying chalk or ooze layers, as this

material would hamper the processing of the mined material and could contribute to

the fine component of the returned material. Design of the drag-head is also based

on extensive laboratory testing of the effectiveness of jet size and power on

fluidizing the seabed material.

44. These studies enabled a mining drag head to be designed to efficiently collect

phosphorite nodules from a layer that varies in thickness from 0 to 50 cm (35 cm in

average), while minimizing the disruption of the underlying chalk/ooze layer. Where

the phosphorite-bearing sediment is thicker than 50 cm the drag-head will not be

able to mine the entire layer and will therefore may leave some of the phosphorite

behind.

Processing sediment on-board the vessel

45. After being lifted to the mining vessel all seabed material will be processed on-

board by a nodule separation plant. The plant will be located in an area on the

vessel that is safely accessible for those operating the plant, and as close as

possible to the vessel’s centre of gravity to ensure that the vessel's stability is not

affected, see Figure 6.

46. The processing plant contains three or four parallel processing streams for the

coarse fraction (>8 mm) separation, and a set of ‘log-washers’ and two to four

processing streams for the finer (2 to 8 mm) fraction separation. The configuration

of the processing streams depends on the size of space available and its location in

the mining vessel. No chemicals are used in this operation.

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Figure 6: Basic arrangement of separation system

47. A 2mm cut-off for the minimum size of material to be retained was chosen for the

operations because there is relatively little phosphorite smaller than this size and

recovery of the finer fraction would significantly increase the complexity and cost of

the processing system. The 2 mm cut-off means that all sand sized material and

smaller is returned to the seabed.

48. The transport within processing streams is based on gravity. Conveyor belts

transport the material between the components of the separation system.

49. This system, tailored for this specific application, is composed of elements and

processes that are commonly used by Boskalis Dolman, the operating company

specialising in sediment handling, separation and dewatering. No new or untested

components are used in this set-up. The system will be comparable to the floating

separation plant for gravel extraction operated by Boskalis on the Grensmaas

project (www.denieuwegrensmaas.nl), see Figure 7 .

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Figure 7: Example of a floating separation plant for gravel extraction

The management of the returns

50. Processed sediment less than 2 mm in size will be returned to the seabed via a

sinker line and a diffuser that will release the material near the seabed. This

decision was made following numerical modelling that showed dispersion of

sediment plumes was minimised when the material was released at or close to the

seabed.

51. The sinker, transporting the non-phosphorite material back to the seabed, consists

of a large diameter pipe (current design is 750 mm diameter). At the lower end of

the sinker, a diffuser will be installed. The diffuser is designed to ensure that the

non-phosphorite sediment returns flow gently back to the seabed. The diffuser is

designed to limit the turbid plume generation and the spatial extent of the

sedimentation footprint. This is accomplished by avoiding contact interaction

between the diffuser and the seabed (average separation will be approximately 10

m), and minimising the velocity with which the sediment flowing out of the diffuser

touches the seabed. Ballast weight of around 20 tons will be added to the return

system to stabilise the diffuser.

52. Returns will be released at 10 m above the seabed on average because analysis of

the dynamics of the sinker and diffuser system indicated that deployment of the

diffuser in this way offers the best control of operations.

53. However, the performance of the system will be monitored during operations and if

it becomes apparent that deployment at the seabed is environmentally preferable

and can be safely achieved, the decision on deployment height will be reviewed.

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54. The diffuser is being specially designed to minimise the velocity of the sediment

landing on the seabed. This design will result in the highest depositional efficiency

and lowest turbidity/plume generation. This procedure is based on procedures and

techniques commonly applied in the dredging industry, particularly when depositing

fine sediments on weak soils, as when backfilling pipeline trenches, to reduce

material losses to the environment.

Seabed mining plan

55. The seabed mining plan is governed by two factors: the operational efficiency of the

mining vessel and the minimisation of seabed disturbance.

56. To optimise the mining process and utilisation of the mining area, a pattern of

mining tracks has been developed in close consideration of the prevailing metocean

conditions. With the currently proposed layout of the dredging vessel, the material

will be loaded on starboard side and the returns will be discharged on port side.

57. Based on extensive dredging experience, supported by numerical modelling studies

of diffuser performance, it is expected that the majority (95 to 100%) of the sand

component, and a portion of the finer sediment, will settle in a concentrated strip at

the seabed. The deposition is described further in the evidence of the plume

predictions presented by Jamie Lescinski. The distance between the centre of the

drag-head track and the centre of the diffuser track will be in the order of 20 to 45

m, depending on the mining vessel configuration, so there is little chance that the

drag-head will recover substantial amounts of previously deposited material.

58. Mining will be in long parallel tracks, with a 180 degree turn at the end to continue

mining in the opposite direction. This technique forms a mining pattern of long

stretched loops. This pattern is the most efficient way to return as much of the

mined sediment to areas that have been mined, to minimise covering unmined

areas with mined sediment, see Figure 8.

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Figure 8: Mining pattern – ‘spiralling out’. The green area is not mined and the yellow areas are mined or have sediment deposited on them.

59. In an optimised dredging process the draghead is kept on the seabed as long as

possible. Turning of the mining vessel results in decreased efficiency because the

drag-head must be lifted above the seabed. The time required to turn the vessel

(determined by its dimensions and weight, wind and Metocean conditions, and the

navigational power) will be about 15-20 minutes, with a turning diameter of at least

125 m.

60. It is therefore preferable to sail straight tracks with a section length as long as

possible. Analysis of the production process showed that if the straight sections

have a length of 5 to 6 km, the effect of turning the vessel (180°) on the production

efficiency is reduced. The straight sections will always be orientated parallel to the

wave propagation direction (200 - 210 deg), to improve the workability of the vessel

by reducing the effects of wave induced motion.

61. By systematically working along this pattern, an ever wider spiral will form. When

the spiral becomes wider than 2 km the increased turning times make the system

too inefficient to continue. For this reason the optimal block width is 2 km.

62. Studies performed by Deltares showed that if the returned sediments are released

just above the seabed (10 m in average), a 10 to 20 m wide strip of material is

discharged on the seabed. Re-dredging of deposited sediments leads to

inefficiencies, therefore the returned sediments are required to be released on an

area which has already been subject to the mining process, or that will be left un-

mined.

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63. The mining vessel will sail in a counter clockwise direction around an un-mined

area (see Figure 8). This area will be affected by the tailings but consideration of

the sedimentation thresholds in Dr. Hewitt’s evidence indicates that it is likely that at

least some of the epifauna and infauna will survive.

64. As soon as the area has reached dimensions that are no longer efficient for mining,

a new area will be approached and the "spiralling" pattern will begin again.

65. Three mining blocks of 5 km by 2 km in size will be mined each year. A complete

block may be mined in an unbroken series of voyages, or mining may move from

block to block for operational reasons (e.g. to maximise resource productivity or

reduce environmental impacts).

Vessel activity cycle

66. Depending on its final configuration, the mining vessel will generally operate on a

10 day cycle, as follows:

(a) a mining, processing and hopper filling phase (4 to 5 days);

(b) transit to port (1.5 days);

(c) offloading and re-provisioning (3 days); and

(d) transit to Chatham Rise to commence the next mining cycle (1.5 days).

67. Allowing for average workability conditions, it is expected that about 30 trips can be

made per year.

68. During a year, a few weeks have been reserved for larger maintenance and repair

works on the vessel. It is expected that this period will be scheduled to coincide with

the worst meteorological periods for mining operations.

Crewing

69. All crew will be competent sailors, specially trained to operate a mining vessel

under offshore conditions. All on-board staff will have acquired seaman’s

certificates (registered mariner) for offshore work and meet Boskalis' competency

standards.

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70. Crew will initially be sourced from within Boskalis. However, New Zealand

personnel will be hired and trained during the initial phases of the project. Crew

changes will only take place in port.

71. Accommodation for at least 50 people will be provided on the vessel. This will

consist of about 20 single cabins and 30 cabins capable of fitting two beds. This

provides accommodation for a maximum of 80 people, who might be on-board

during the initial phases of the project or during periods of special activity (such as

research or monitoring). Under normal conditions about 50 people will be working

on the mining vessel.

72. The accommodation includes a common room and galley. Cold stores, sports room,

leisure facilities, laundry room, meeting room, hospital, office and all modern

communication and TV systems will be on the vessel.

OPERATIONAL CONTROL

Monitoring and compliance with thresholds

73. Boskalis and CRP have put together what in my view is a comprehensive draft

monitoring plan that aligns with best practise on other projects I have been involved

in. That plan is set out in chapter 11 of the EIA and is further described in Mr

Wood's evidence. The monitoring plan for physical mining impacts will mainly be

receptor based, related to the draft conditions.

74. In addition to the use of AUVs or towed sensors and moorings to monitor

environmental effects, the performance of the mining vessel during mining

operations will be monitored on-board. In relation to material returned to the

seabed, the density (sediment concentration) and flow velocity will be measured,

providing information on the total mass of material being released over time.

75. In the unlikely event that the thresholds (turbidity or underwater sound) are

exceeded, operations will be adapted to bring the operation into line with the

conditions of consent. I have set out below some examples of the steps we would

take if needed to address these issues.

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Suspended sediment or sedimentation threshold

76. While we have full confidence in our predictions, if monitoring indicates that a

turbidity or suspended sediment threshold is exceeded, the first action will depend

on whether the elevated turbidity level was detected during an AUV survey or by

one of more of the moorings. If it was detected during an AUV survey, then the first

action will be to repeat the measurements and check that the event is not a short

term local anomaly.

77. If the elevated turbidity level was detected only by one or more of the moorings,

then it was not detected by the AUV survey which means that the effect is short-

lived. In this case the first action will be to analyse the time series mooring data

and determine whether the elevated turbidity level is likely to be correlated with

mining activities.

78. If the repeat measurements confirm that a threshold is exceeded or if the analysis

of the mooring data indicates that the elevated levels are likely to be correlated with

mining activities, then the next step will be to determine the cause of the incident.

Possible causes for threshold exceedance are:

(a) extreme or severe oceanographic (hydrodynamic or metocean) conditions;

(b) significant changes in sediment composition; or

(c) a disruption in the mining system.

79. One of the main purposes of the proposed monitoring system is to provide the

information for this analysis of possible causes.

Change in oceanographic conditions

80. To determine if there has been a change in oceanographic conditions, data from

the moorings deployed around the mining block will be obtained (if this has not

already been done) by either retrieving the moorings or remotely triggering a data

download. If other relevant information such as turbidity or current data collected

by an AUV or similar instrument are available then this will also be obtained. These

data will be analysed and integrated with satellite data used to monitor changes in

currents around New Zealand to determine whether there has been a change in

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oceanographic conditions in the vicinity of the mining block. The recovery and

analysis of these data is likely to take at least a week.

81. If this analysis indicates that oceanographic changes are the cause of the threshold

exceedance then mining operations will not be stopped. The oceanographic

conditions on the Chatham Rise are dynamic, and the available data indicate that if

these conditions change sufficiently to cause suspended sediment thresholds to be

exceeded then the changes will be temporary.

82. I understand that planning to deal with the possibility of oceanographic changes

includes collecting long-term oceanographic data that will be freely contributed to a

national database.

Different sediment composition

83. The likelihood of operations being affected by unexpected changes in the

composition of the mined material will be reduced by conducting detailed surveys of

the mining blocks before mining. As a proactive measure to determine the sediment

properties that might affect mining operations, every mining block will be surveyed

before mining starts to obtain detailed knowledge of the nature and distribution of

the phosphate deposit (including concentration and thickness, and consequently

depth to the chalk layer). This will allow CRP to vary the mining operations and

pattern, including moving to other mining blocks, if required to achieve production or

environmental targets.

84. The performance of the on-board sediment processing system will be continuously

monitored, and this information can be used to identify significant changes in the

composition or physical properties of the material returned to the sea floor. This

change could be due to an increase in the clay and silt fraction, an increase in the

phosphate content, or to an increased amount of chalk in the mined material.

85. If a significant increase in fine material content is detected then actions to return

operations to below the threshold values could include mining more slowly

(reducing the flow of material returned to the sea floor), or moving to another area

where the sediments are expected to contain a smaller proportion of fines (reducing

the amount of material returned to the sea floor). If this is a recurring problem then

modifications to improve the performance of the mining system will be investigated

and implemented. Such possible modifications include adjustments to the

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draghead and pump system to match the varying amount of fine material taken to

the mining vessel, or changes to the sinker and diffuser system to increase the

settling rate of the finer discharged sediments.

86. If there is a significant increase in the amount of chalk in the mined material, then

actions to return operations to below the threshold values would include reducing

the power of the jets in the draghead or increasing the speed of the draghead

across the sea floor (reducing the depth of jet penetration and thereby reducing the

amount of chalk included in the mined sediment), modifying the design of the skids

at the rear of the draghead, or moving mining operations to an area where the

sandy/silt layer is thicker (making it less likely that chalk will be reached by the

draghead jets). If this is a recurring problem then the jetting configuration at the

draghead will be adjusted to reduce this chalk uptake.

Disruption in the mining system

87. The performance of all components of the mining system will be monitored on

board. If any of these monitors indicate either failure of a unit or loss of

performance, which could be the cause of the threshold exceedance, then mining

will be stopped while the unit is replaced or repaired.

88. Problems with components of the mining system are not expected to cause a

threshold exceedance because they are most likely to cause the mining operations

to stop until they are fixed, or the environmental effect of their failure or loss of

performance will be minimal (e.g., see discussion of blocked riser or sinker in the

EIA).

89. The components of the mining system will be chosen for their reliability and

performance. Routine maintenance of the mining system will be designed to ensure

that all components of the system perform as expected to achieve production or

environmental targets.

Sound threshold

90. I understand the reports on sound levels associated with the mining activity explain

why the predicted sound levels are likely to be maximums for the operations. In the

unlikely event that the sound monitoring indicates exceedance of the predicted

sound levels then the first action will be to repeat the measurements and confirm

the result. If the result is confirmed then the next action will be to determine if the

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increased sound level is due to a change in the sound generated by the mining

system.

91. A more detailed analysis of the sound monitoring data would be completed to

determine if a component of the mining system can be identified as the source of

the change in sound levels. If the source of the change can be identified then

mitigation could involve more intensive maintenance (‘greasing’) or replacement of

parts. Mining operations will be stopped while these actions are completed, if

required.

92. Other options include exploring changes to the system design or to the mining

operations. Temporary changes to the mining operations could reduce sound levels

while more permanent solutions are identified. These might include moving to a

mining area where the sediment properties are predicted to be different (finer, less

sound producing) or where impacts are estimated to be less critical.

93. Changes to the system design would potentially require considerable engineering

research. There are several techniques currently used to mitigate sound from

activities such as drilling and dredging (e.g., bubble curtains and hydro sound

dampers) but these may not be effective or practical at 400 m water depth and with

the proposed mining plan and configuration of the mining system. It might be

possible to reduce the level of sound emissions by shielding or packing the pumps,

but this has never been done and research would be required to identify an

appropriate material and method of application.

Vessel safety

94. Boskalis Offshore is certified with ISO 9001 and 14001 and OHSAS 18001 and

assures through relevant procedures full SHE-Quality Assurance in its contracting

business. As part of Royal Boskalis Westminster NV the renowned safety program

NINA (No Injuries, No Accidents) will be enforced.1

95. Safety has been a priority within the Boskalis organization for years and this has

resulted in a clear improvement of our safety record. To further improve our safety

culture and reach our goal of an incident-free working environment, Boskalis has

launched the NINA safety program –which sets clear standards and explains what

we expect from our people with regard to their safety behaviour.

1 Visit www.boskalis-nina.com for more information.

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96. At the heart of the NINA safety program are five core values and five rules. NINA

makes people aware of their own responsibility regarding safety and encourages

them to take action if operations are unsafe and approach others if they are at risk.

Health and safety risks differ from project to project and from location to location, so

it is important to have the right tools at hand to assess the risks, take appropriate

measures and communicate them to all involved.

97. NINA is supported by an extensive training and workshop program so that all our

employees understand the NINA principles and how to lead by example. NINA is

embedded in our organizational systems and managed by leading indicators.

98. In addition, processes onboard the mining vessel are highly automated and

centrally controlled to maximise working safety. Emergency systems are installed

and are in continuous operation.

99. The table below presents the safety track record of Boskalis for 2013, expressed in

Lost Time Injury data, with LTIF being defined as ‘number of incidents resulting in

absence from work for every 200,000 hours worked’. Besides the Boskalis overall

numbers, also the numbers for the two disciplines relevant to the proposed mining

operations are shown separately.

There were no fatal incidents affecting the Boskalis staff in 2013.

LTIF Hours (million) LTI’s

Boskalis 0.11 57.70 31

- dredging 0.09 11.48 5

- offshore energy 0.07 5.99 3

100. The development of LTIF over the recent years is shown in Figure 9, with the

improvement in LTIF largely due to the implementation of the NINA program.

Figure 9: Boskalis Safety (LTIF) record

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On-board vessel environmental matters

101. In relation to Waste and Emissions Management all Boskalis’ vessels operating in

international waters adhere to the international laws and standards (specifically

MARPOL), with special attention to the additional requirements that follow from the

national regulations of the country under which jurisdiction the vessel is operating.

A project specific environmental management plan is drafted and agreed before

start of the works, outlining all project rules. This applies to oily waste, hazardous

substances, wastewater, garbage (solid waste), emissions to air, ballasting and hull

biofouling. The joint CRP-Boskalis approach to meet these requirements is stated in

the Marine Consent Application, section 4.7.4. More detail on these issues is given

in following paragraphs.

Waste management

102. All waste management on the vessel will comply with the requirements of New

Zealand law and Annex V of MARPOL. All garbage from the vessel will be returned

to New Zealand and disposed of at the arrival port's solid waste reception facilities,

except the ground or comminuted food waste which is permitted to be discharged.

The vessel will also have a Vessel Solid Waste Management Plan (WMP) and

Garbage Record Book. Boskalis will comply with its internal environmental policy,

which requires reducing garbage volumes and evaluating options to improve waste

recycling.

Wastewater

103. The vessel will have a wastewater treatment facility that complies with Schedule 6

of the Resource Management (Marine Pollution) Regulations and will hold an

International Sewage Pollution Prevention Certificate.

Oily waste

104. The vessel will comply with MARPOL and the relevant requirements of the Marine

Protection Rules. It will have appropriate certificates of insurance, a Shipboard Oil

Pollution Emergency Plan (SOPEP), and an International Oil Pollution Prevention

Certificate (IOPPC).

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Emissions to air

105. CRP will ensure its vessel complies with Appendix 1, Annex VI (Prevention of Air

Pollution from Ships) of MARPOL.

Ballasting

106. The vessel will have a ballast water system that will take care of the proportional

distribution of the bending movements in the ship's construction when the vessel is

being loaded or unloaded.

107. The vessel's biosecurity activity will meet New Zealand's Import Health Standard for

Importing Ballast Water from all Countries and New Zealand's obligations under

international treaties and agreements.

108. The vessel will re-ballast enroute to New Zealand, before first arriving in the

country. Once in New Zealand, the vessel will ballast at New Zealand ports and

discharge the water on the Chatham Rise. This means there will be no ballast

biosecurity issue and re-ballasting will not need to occur unless the vessel goes

overseas (for example, for inspection or dry docking).

109. The vessel's hull will be clean when it arrives in New Zealand and will be kept free

of visible biofouling (except for a slime layer), in accordance with the Biosecurity Act

1993. The vessel's hull will be cleaned appropriately when necessary, for example if

the vessel goes to a port that is known to have unwanted marine organisms or

marine pests, and then to another port that does not have an infestation.

Vessel lighting

110. Standard lighting used on Boskalis’ ocean going vessels will be used, with special

attention given to measure to reduce bird strike. Measures will be taken to reduce

birds' attraction to the vessel and to minimise the potential for seabirds to strike the

vessel and be injured or killed as a result in accordance with the Vessel Lighting

Management Plan.

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VALIDITY OF THE MINING METHOD

111. Seabed mining has been the subject of numerous studies since the early 70’s.

Throughout this period Boskalis has invested heavily in these studies. Due to

market conditions, however, these never led to the instigation of deep water mining

projects.

112. Recently, further research, under various national and international initiatives has

been undertaken to understand and address the impacts deep-sea mining

operations might have on the environment. Boskalis participated in the Dutch

research program ‘Towards Zero Impact’ (soon to be published).

113. The results of these studies, along with dredging equipment developments over the

past 20 years, have meant that deep-sea mining is now feasible both economically

and environmentally.

114. The proposed mining concept, tailored to mining on the Chatham Rise, is based on

a combination of techniques, methods and procedures that are already used in

dredging and seabed material reclamation, on a large scale, usually to depths of up

to 150 m. As dredging or dredge-mining has not been attempted at depths of 400

m, a system has been designed based on best available practices, supported by

dedicated studies and expert assessments.

115. In my opinion, the system is able to cope with the variable seabed conditions, and

will, whilst operating, provide adequate survey data for further optimisation and fine-

tuning of the processes. The initial phase of mining will be used as a

pilot/prototyping period to test and optimise the system in all conditions. Based on

2.5 years of study and development, founded on many years of experience in

dredging, dredged material handling and management of the environmental effects

of dredging and disposal, my team and I are confident that the design is

fundamentally sound, and that refinements to the system, if any, will be minor.

Decisions on mining approach made as the project has progressed

116. During the planning and design phase, before a final mining plan was adopted,

many alternative options were studied. Options considered were:

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(a) Mining method: The performance of free sailing surface mining vessels

(like the present trailing suction hopper dredge concept (TSHD)),

stationary surface vessels (like cutter suction dredgers or grab dredgers)

and underwater mining equipment (crawlers or remote operated vehicles)

operated from surface support vessels were evaluated. The main reason

the TSHD concept was chosen was because it is the most reliable

technology, least vulnerable to metocean conditions and is most likely to

deliver the required output (refer EIA section 12.4.2).

(b) Seabed excavation method: A draghead operated from a TSHD collects

material by hydraulic suction. To break the cohesion of the seabed

material additional forces are needed which can be provided either by

water jetting or by mechanical cutting with teeth. Water jetting was chosen

as the primary excavation tool in the draghead because it has proven (in

other projects and in studies) to be more effective than mechanical cutting

in the types of sediments expected to be encountered on the Chatham rise

and to reduce the amount of clay/ooze that is dislodged, increasing

production and reducing environmental effects (refer EIA section 12.4.2).

(c) Separation cut-off: Work was also undertaken to assess the percentage

of nodules retained as a result of using various fraction separation options.

An evaluation of whether a 1 or 2 mm cut-off should be utilised to extract

the phosphorite from the mined material demonstrated that at 2 mm the

highest overall efficiency could be achieved (refer EIA section 12.4.3).

(d) Material return location: Studies have been undertaken to determine the

location (with numerical modelling) at which the release of unwanted

material would have the least environmental impact. Release at the

surface was immediately rejected as it resulted in the worst environmental

mixing effect. Release at mid-depth, below the photic zone, was

considered undesirable as it is relatively uncontrolled and led to

widespread sediment dispersal. Release at or just above the seabed was

chosen because it is predicted to result in the least sediment dispersal

(refer EIA section 12.4.4).

(e) Material return method: Research has been done to the most effective

method for releasing the return material from the sinker pipe diffuser, in

order to achieve a high depositional efficiency and low turbidity generation

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(refer EIA section 12.4.4). The current design includes features that slow

the flow of discharged sediments from approximately 7 m/s in the fall pipe

to about 0.75 m/s (the speed of the mining vessel, but in the opposite

direction)

(f) Mining patterns: Several patterns have been studied to systematically

sail mining tracks. Evaluation criteria were the ability to accurately sail

tracks, efficiency of track overlap and turning times, reduction of

mining/dredging the same sediment twice, and reduction of plume

dispersion. The pattern of ‘spiralling-out’, as described earlier in this

evidence, was found to best meet all criteria (refer EIA section 12.4.5).

(g) Material transfer method: Studies were undertaken to assess whether

the mined material could be transferred to dedicated transport vessels

without the mining vessel having to return to port. This option was rejected

for several reasons, primarily maritime safety (the proximity required for

two large vessels at sea) under the prevailing metocean conditions and

the ability to transfer mined product safely and reliably.

(h) Vessel selection: The mining vessel has not yet been chosen but the

design and performance criteria are established. The vessel could be

constructed by modifying existing Boskalis owned vessels and equipment,

by purchasing and modifying an existing vessel, or by building a purpose-

designed vessel. As well as meeting all international standards and

requirements for an offshore work vessel, evaluation criteria for selecting a

vessel are good workability and manoeuvrability, safety and reliability of

operations, a draft suited for New Zealand's main ports, sufficient carrying

capacity to meet production requirements, and low investment cost. The

final vessel decision is awaiting completion of an evaluation of the relative

costs of modifying an existing vessel and building a new vessel.

RESPONSES TO SUBMISSIONS

117. A number of submissions raise issues that it is appropriate for me to respond to.

Set out below are the issues raised and my responses.

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Deepwater Group

118. At paragraph 10.6 of its submission, it states "Unplanned events such as

malfunctions in the mining equipment, oil spills, vessel accidents, and biosecurity

incursions will increase the risk of significant adverse effects on marine ecosystems

on the Chatham Rise and potentially around the Chatham Islands and New

Zealand’s coast".

119. As discussed in the EIA, the mining vessel will comply with all New Zealand and

international maritime safety and environmental regulations. The risk of an oil spill,

vessel accident, or biosecurity incursion is no greater for this vessel than for the

fishing vessels that operate on the rise. In some months there are more than 20

fishing vessels operating on the rise, all with similar risks of oil spills, vessel

accidents, or biosecurity incursions.

120. Also as discussed in the EIA, a catastrophic failure of a component of the mining

system will not have a significant adverse effect on the environment. Failure of the

riser or sinker would release a few cubic metres of material that came from the sea

floor. Failure of a pump might release a small amount of oil to the environment but

not enough to have a significant effect. The processing plant uses no chemicals

that might be released into the environment.

121. The DWG submission, at 15.1 suggests that CRP's proposal "Lacks basic

information about proposed mining approach (e.g., configuration of drag head and

on-board processing equipment, preferred port and shipping route)".

122. The configuration of the draghead and onboard processing equipment are

described in the EIA, and this information is summarised in my evidence. CRP will

continue to evaluate the physical properties of the seabed sediments as part of its

pre-mining work commitment, and the results of this analysis may refine details of

the design such as the number of jets, the diameter of the jets, the maximum

pressure, etc.

123. Several ports on the east coast of both islands are currently being considered. A

final decision will not be made until a vessel is chosen, as the draft of the vessel

may affect the evaluation of the ports. Factors such as distance to the mining site,

port charges, and convenience for transhipment to export vessels will affect the

final decision.

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Moriori

124. Paragraph 30 of this submission states "The CRP application relies heavily on

predictive modelling rather than a precautionary approach. The mining

methodology proposed by CRP has no international precedents for working at

these depths, so no data has been provided by CRP on the actual or likely effects

of this type of dredging."

125. Trailing suction hopper dredgers operate in up to 155 m water depth, and rock

dumping takes place in depths greater than 1,000 m. Most of the components of

the mining methodology are the same or very similar to equipment already used

on other dredging or rock dumping projects. The only significant change

proposed for this project is that the riser will not be a rigid, one-piece unit. It will

be based on the same technology currently used for the sinker in rock dumping

projects. This change is not expected to have any effect on the predicted

environmental impacts. The more relevant issue is the likely effects of the use of

this technology, but this is more a function of differences in sediment uptake and

sediment release at prevailing oceanic conditions, which is extensively addressed

in various sections of this and other evidence.

Paua Mac

126. Paragraph 3. of Paua Mac's submissions states "The mining activity will inevitably

result in a higher level of shipping traffic on the Chatham Rise, including the mining

vessel, support vessels and vessels used for environmental monitoring. The EIA

does not specify the "home port" of the mining operation, but it does note that the

mining vessels may seek shelter at the Chatham Islands when bad weather

prevents the mining operation. The increased vessel traffic and presence of mining

vessels in Chatham Island waters will inevitably result in a higher risk of:

• Oil spills or other pollution events; and

• Marine biosecurity events."

127. I have addressed this concern in my answer to paragraph 10.6 of the Deepwater

Group's submission.

128. At paragraph 4.of its submission, Paua Mac submits that in relation to both the risks

identified in para 3 of its submission:

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• It is not possible to accurately assess either the level of risk or the

consequences for the Chatham Islands because the EIA contains no

information on the preferred home port or the shipping route. We consider

this to be a significant information gap in the EIA; and

• Although the probability of events resulting in oil spills or biosecurity

incursions affecting the Chatham Islands may be small, the special

characteristics of the Islands - including their relative isolation and

economic dependence on a healthy marine environment - mean that the

consequences of such an event would be severe.

129. In response, I refer to my answer to the Deepwater Group points 10.6 and 15.1

above.

130. At paragraph 5 of its submission, Paua Mac states: "the EIA provides no

information on the maximum amount of oil that might be spilt by a mining vessel,

but it is highly likely to be beyond the limited response capacity of the Chatham

Islands in terms of both containment and remediation. It is therefore unlikely that

the Chatham Islands could mount a timely and effective response to a significant oil

spill in the vicinity of the Islands, and the effects on marine ecosystems would be

catastrophic."

131. In response, I refer again to my answer to the Deepwater Group point 10.6. The

maximum amount of oil spilled, if any, is not significantly different from what could

be spilled from a large fishing vessel.

132. Paua Mac also raise biosecurity concerns in their submission at paragraph 6 and 7,

as follows:

6. PauaMAC 4 notes that the Islands may be affected by biosecurity

events associated with the mining vessel seeking shelter at the Chatham

Islands in bad weather, including the risk of shipwreck (such as the sinking

of the undaria-infested trawler Seafresh at the Islands in 2000). We

therefore submit that the specific biosecurity issues that apply to the

Chatham Islands must be addressed by CRP irrespective of the final

location of the port.

7. PauaMAC 4 expects CRP to provide a higher level of certainty as

to how biosecurity risks will be addressed prior to the consent being

granted (if consent is granted) - this important matter should not be left to

the yet-to-be­ completed EMMP. At the very least we would expect CRP to

prepare a project­ specific Biosecurity Management Plan that sets out how

CRP will detect, mitigate and respond to biosecurity threats for all project

activities, including risks from ballast water, vessel biofouling, and

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introduction of non-indigenous species via other equipment such as

sinkers and risers, tow lines, the dredge head, the pump unit, monitoring

equipment and associated storage lockers.

133. There is little that I can say in response, other than repeat my earlier evidence that

we will follow all New Zealand and international maritime regulations regarding

biosecurity risks. As to the actual level of risk to the Chatham Islands from CRP's

activities, the mining vessel will be checked and approved when entering New

Zealand, and thereafter stays in New Zealand waters. Risers and sinkers are only

lowered on the Rise, not near the NZ mainland, so any risk of "infection" between

the mainland and the islands will not result from dredging gear.

KASM

134. Page 39 of KASM's submission states that "CRP has no provision for any

unplanned events or environmental restoration and will leave any adverse

environmental impacts to for the tax payers of New Zealand to pick up the tab for

those costs. CRP has opted out of volunteering a bond utilising Section 65 of the

EEZ Act. It demonstrates that CRP potentially are a company that does not wish to

avoid, remedy or mitigate adverse effects, our have sound company ethics."

135. Most catastrophic environmental risks are the same as for those of any other vessel

operating on Chatham Rise, such as those resulting from damage to the vessel or

sinking. Like every other responsible maritime company, Boskalis has plans and

procedures to deal with emergencies at sea, as being used on their vessels

operating in national and international waters.

136. Environmental risks specific to the mining operations, such as loss of the draghead

and pump unit, are not catastrophic as the materials are inert and the size of the

units is relatively small, comparable to that of lost trawling gear. In the unlikely

event that the draghead and pump unit are lost, then every effort would be made to

recover them as they are unlikely to be seriously damaged and could be used again

for mining.

137. KASM also states that "The seafloor will be blasted with high pressure water jets

along with being ripped up and ground by huge cutting teeth to allow the material

that is sought after by CRP to be sucked up the hose to the vessel for processing.

The dredging drag head will remove up to a depth of 1m or more of the seabed

material. The skirt of the drag-head will allow for the entrainment of fish and other

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biota and the intake for the water jet system will also entrain fish, larvae, eggs and

potentially other biota resulting in adverse effects to fish and biota thereby causing

more than minor adverse effects."

138. The mining operations are described in the EIA and in more detail in responses to

EPA requests for further information. The seabed sediments will not be ground by

huge cutting teeth. Teeth are not foreseen to be used, but small teeth may be

incorporated in the draghead to help passively break up the sediments if the early

stages of production show that they are necessary. The mining system is designed

to have a maximum depth of 0.5 m. The volume of water affected by the intake and

draghead is very small and the effect on fish, larvae, eggs and other biota will be

correspondingly small.

139. KASM state at page 40 that lights on the draghead could create adverse effects.

As described in the EIA, the environmental impacts of lights on the drag-head will

be negligible as they will be used infrequently, for relatively short periods, and will

have a limited range (approximately 2 to 5 m around the drag-head).

140. Also at page 40 of its submission, KASM states: "There is the potential to snap or

break those wires completely, possibly leaving stranded the equipment on the

seafloor as litter or unwanted material. CRP has not provided an effective

contingency plan to remove, or to replace the mining tools. Nor has CRP provided

robust information on rocks or smaller rocky outcrops that the mining tool will

encounter, but instead has just stated that large rock outcrops are not common in

the mining area."

141. This issue is dealt with above in regarding the potential loss of equipment on the

sea floor. As stated in the EIA, CRP will undertake comprehensive surveys of the

sea floor prior to mining any area. These surveys will identify rocks or rocky

outcrops.

142. KASM states at page 40: "The water intake for the drag-head jets is about 20 m

above the seabed, and it will suck in about 1000 m3/s, creating a mixing zone on

the seafloor and around the drag head that is unnatural and will create adverse

effects." Natural mixing due to tides and currents occurs in the lower part of the

water column. There is no significant mixing effect from the draghead and pump

unit.

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143. Also at page 40, KASM states that: "The sieves, log-washers and cyclones will

crush; smash larger particles to small ones and in doing so, will result in ground up

lighter particles being discharged into the sediment plume." This is not an issue

because separation of the larger pieces occurs at the first stage of processing,

before there is any significant chance to break the material. Just for clarity, the

onboard processing system is not designed to crush the material.

144. KASM's submission, at page 40, states that: "CRP downplays the effects from the

distribution of the sediment and underestimates the speed of the ocean currents at

the depth of the seafloor the sediment plume. While the larger particles may settle

closer to the adjacent areas, it is the sediment fines that also create significant

adverse effects and travel larger distance than 15 km as well as rise to the surface."

145. Extensive modelling has been used to derive reliable estimates of the distribution of

sediment deposition and plume extent. The significance of the suspended

sediments (the sediment fines) is related to their concentration and duration. If the

speed of the ocean currents is underestimated then the material will be spread

more widely and more quickly, effectively reducing the adverse effects. All of the

model results show that the suspended sediments will remain close to the sea floor

and never reach the surface.

ECO

146. In ECO's submission, it suggests that that the method of mining is "only conceptual

at this stage". Based on my evidence, I disagree. There is a significant amount of

information which clearly demonstrates how the mining will be undertaken.

Greenpeace

147. In its submission, Greenpeace suggests that: "The applicant has not committed to

one technology, and will not undertake the mining itself. This approach introduces

unacceptable uncertainty in the application: the applicant does not even know what

ship will be used: “specially built or modified vessel”." CRP and Boskalis have

committed to a mining system and plan, both of which are described in the EIA and

CRP's evidence. Whether the mining vessel is specially built or is modified from an

existing vessel will have no effect on the environmental aspects of the project.

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148. Greenpeace also assert that: "After phosphatic material is removed, the finer

sediment will be pumped back to the seabed, from a pipe discharging some 10

metres above the seabed, causing an enormous plume of unknown size, duration

and effect." In my view this assertion is completely inaccurate. Extensive

modelling has been used to derive reliable estimates of the distribution of sediment

deposition and plume extent. This is described in the EIA, Appendices 10, 23, 24,

25 and 26, and in the responses to EPA questions.

CONCLUSION

149. The proposed mining method is a combination of existing state of the art

techniques, applied in a new context. The proposed method combines the best

available technology with the best environmental practices. Every effort has been

and will be made to ensure safe and environmentally responsible operations, and

this commitment will be maintained through regular monitoring of the system

performance and on-going refinements of the equipment and operations.

Gerard van Raalte

28 August 2014