Dear Chatham Rock Phosphate shareholder,
This letter has just been sent to Green MP
Gareth Hughes, filed with NZX and sent to the media.
Regards,
Chris Castle
CEO
Chatham Rock Phosphate
Limited
P.O. Box 231, Takaka
7142
Mobile: +64 21 558 185
chris@crpl.co.nz
Skype: phosphateking
www.rockphosphate.co.nz
17
September 2013
Open
letter to Gareth Hughes, Green MP
Dear Gareth
I was very disappointed to see you had aligned
yourself publicly with the bottom trawling industry in a news item on TV3 at
the weekend.
In our briefing to you last year you indicated you had
not reached any conclusion about the merits of our project. I would have
thought that you would make an informed decision, including discussion of your
concerns with us, before going public for the sake of a TV sound bite.
You have publicly said you are not against mining per
se and will evaluate each project on its merits. We wonder how much faith to
put in that statement if the evaluation is based on so little consultation and
so few facts. If you have ruled out
this mining project as well as countless others, are there any you do support?
We’re astonished you have formed such a negative
opinion about our project given the compelling potential environmental and
economic benefits it offers and its minimal environmental impacts.
To remind you:
1.
Chatham Rise rock phosphate, as an ultra-low cadmium direct-application
fertiliser, has proven to be as effective as processed fertilisers while
reducing run-off effects on New Zealand waterways by up to 80%.
2.
This resource provides fertiliser security for farming by providing a local
alternative source. Most rock phosphate
used to make fertiliser now is
imported from Morocco.
3.
Moroccan rock phosphate is high in cadmium, involves high transport costs and
has a significant carbon footprint.
4.
New Zealand is predicted to be $900 million richer as a result of our
new industry and we’ll be generating annual exports or import substitution of
$300 million, plus supporting farming, our biggest earner.
5. By area, the economic value of the phosphate
resource is 500 times greater than fishing; it is expected
to yield $9.1 million per km2. In
contrast, bottom trawling yields less than $20,000 per km2.
So while our operations will have some environmental
impacts, they also offer very significant environmental and economic benefits.
The TV3 news item noted your alliance with the fishing
industry is an unlikely one. I agree,
given bottom trawling’s massive environmental impacts and lack of environmental
oversight.
Our proposed mining operation is subject to a rigorous
environmental evaluation and monitoring process. The story that should be
getting your attention is not the potential environmental impact of our
project, but the freedom of the fishing industry to devastate as much of our
EEZ as they like (currently about 50,000 km2 per year, or 385,032 km2 or 9.3% of the EEZ since 1989) with no environmental
oversight or monitoring.
We wouldn’t consider extracting phosphate nodules from
a very limited area of the Chatham Rise if we expected it to cause more than
very minor environmental impacts. Our operations will lift the top 30cm of
sandy silt and redeposit 85% of it on the same area of seabed after extracting
the nodules. Modelling indicates the material returned will not be widely
dispersed, and the sediment that doesn’t immediately settle will rapidly dilute
to insignificant levels.
Our draft environmental impact assessment (EIA),
supported by more than 30 expert reports, has identified no long-term impacts
on key spawning, juvenile and young fish habitat. Any potential impacts are
predicted to be confined to our limited extraction areas, and are short-term,
reversible, and of low environmental risk.
But while bottom trawling – ploughing vast tracts of
the EEZ seabed decade after decade - requires no environmental consents, our
project needs a mining licence and a marine consent. These cost millions of
dollars, require years of research, consultation and official process, and
involve full public scrutiny.
Chatham’s planned 15-year extraction project will
touch a total of 450 km2, far
less than 1% of the Chatham Rise. In
contrast, over the same period fishing will bottom trawl 750,000 km2, about
three times the size of New Zealand.
Year after year, weighted nets scrape about 50,000 km2 of
seabed, with bottom-dwelling animals disturbed or destroyed – mostly repeatedly
so areas never have the chance to regenerate.
Up to 3,000 km2 of new territory is disturbed annually - an
environmental impact 100 times greater than predicted for phosphate
extraction. Each year we plan to touch
just 30 km2.
Scientific research shows that hoki
spawning is concentrated on the West Coast of the South Island and in Cook
Strait, and juvenile growth occurs over the entire
189,000 km2 rise. The
annual fish trawl footprint on just the
Chatham Rise during the 2009-10 fishing year was 19,051 km2.
The Deep Water Group members therefore
already know they can continually disturb the ecosystem of 10% of the Chatham
Rise area without harming juvenile fish stocks.
Chatham’s extra annual 30 km2 are likely
to have no significant additional effect on the hoki fishery.
In summary, fishing destroys the benthic
habitats of 100 times the area of previously untouched sea floor every year than we plan to, and every
year fishing stops regeneration on an area of seafloor almost 2,000 times
greater than our planned area of impact.
Thanks partly
to Chatham’s $20 million investment, the rise’s benthic environment is now one
of the best-known parts of our marine territory, and this information can now
inform resource and environmental management decisions, possibly including
modifying the location of benthic protection areas. We’ve spent three years collecting data
on oceanographic conditions (tides, currents, turbidity), benthic life, and
analysing the impacts of disturbances on the seafloor and in the water column
so we can design a mining system and operational plan that minimises
environmental impacts and protects areas of benthic habitat.
Rather
than being of environmental concern, ours is a project of national significance offering
significant economic and environmental benefits.
A word or
two about BPAs
Benthic Protection Areas were promoted by the fishing
industry, for the fishing industry, and were specifically designed to avoid fishing areas, especially those
relating to bottom trawling. BPAs include a representative sample of benthic
habitats, spread geographically to ensure adequate latitudinal and longitudinal
variation. The map shows how they avoid
bottom- trawling areas.
BPAs were designed without regard for New Zealand’s
other important natural resources such as rock phosphate or massive
sulphides.
BPAs were implemented to protect benthic biodiversity,
not fish spawning grounds or nurseries, though that may be a side benefit for
some species.
BPAs are only covered by fisheries legislation. They do not relate to other legislation
covering other ocean activities, such as the newly enacted EEZ legislation,
which expressly excludes any direct reference to BPAs. Consideration of the
relative importance of BPA’s will be part of the environmental impact
assessment process managed by the Environmental Protection Authority.
The fishing industry also used the introduction of the
BPAs to substantially reduce its monitoring costs, even though establishing
BPAs made no difference to its ability to bottom trawl in the vast majority of
the EEZ. In recognition of the
contribution BPAs would make to marine protection, the government agreed any
research relating to the potential effects of bottom trawling on the benthic
environment or its biodiversity should be two-thirds Crown funded and one-third
industry funded.
Chris
Castle, Managing Director Chatham Rock Phosphate
Attached: graphic showing the fish bottom trawl footprint of the EEZ
prior to establishing the BPAs
+64 21 5581985
chris@crpl.co.nz
PhosphateKing