The government has recently released a discussion paper proposing the removal of several areas of land from Schedule 4 conservation status. While the document seems to more or less capture and consider the conservation value of the land itself, the government seems to be paying little attention to the wider potential environmental impacts of mining in these areas - especially the possibility for coal mining in the Inangahua sector of Paparoa National Park. NASA's James Hansen - one of the world's leading climatologists - says that coal-fired power plants are literally death factories, having huge impacts on human health and the planet. These are my responses to the discussion document submission questions. If you'd like to make a submission yourself, the online submission form is here.
Q1 On the areas proposed for removal from Schedule 4:
Section 7 of this document sets out the areas proposed for removal from Schedule 4. Do you think these areas should be removed from Schedule 4 so that applications for exploration and mining activity can be considered on a case-by-case basis? Yes or No? And why?
I oppose the removal of the areas proposed for removal from Schedule 4, and especially the removal of the Inangahua sector of Paparoa National Park and Coromandel Peninsula areas. While the general conservation value of these areas has been identified in the discussion document, my primary concern is the potential greenhouse gas impacts of allowing the potential for mining activities in these areas. Specifically, the possibility for coal mining at the Inangahua section of Paparoa National Park, and to a less extent the potential for peat mining in the Coromandel Peninsula has the potential for resulting in significant quantities of greenhouse gas emissions – both during the mining and processing process, and during the eventual use of these materials (e.g. in power production). Methane, a greenhouse gas many times more powerful than carbon dioxide, is released during the process of coal mining. Carbon dioxide is also released in very substantial quantities as the result of the burning of coal for power production. Similarly, methane and carbon dioxide are released in the peat mining process, and carbon dioxide is released if the peat is burned as fuel.
In addition to greenhouse gas impacts, the burning of coal as fuel also produces other significant air pollutants, including sulfur dioxide (which can result in acid rain), and produces other dangerous waste products such as fly ash, arsenic, lead, mercury, barium, and radium.
While the government has taken pains to point out the potential for “surgical” mining operations to minimise environmental impacts, much of the potential for environmental damage of mining (and coal mining in particular) occurs after the mining process. If we are to open these Schedule 4 areas up to mining, New Zealand must take responsibility for all the resulting environmental impacts – not merely those at the mining site itself.
Anthropogenic climate change has the potential to produce significant damage to this planet that lasts for centuries or millennia, affecting the lives of our children and grandchildren for many generations to come: history will not look kindly on us as the generation to see the problem but not take action. To aggressively pursue fossil fuel (e.g. coal) resources even in areas we have already established as being of great conservation value is the very opposite of what history and the planet demands of us right now: to swiftly and significantly reduce our greenhouse gas emissions, before it is too late.
Q2 On the areas proposed for addition to Schedule 4:
Section 8 of this document sets out the areas proposed for addition to Schedule 4. Do you agree with the proposal to add these areas to Schedule 4? Yes or No? And why?
I support the addition of these areas to Schedule 4 classification. I further believe that the Crown Minerals Act should be amended so that these additions should be automatic each time new lands are gazetted into National Parks and the other land classification types listed in Schedule 4.
Q3 On the assessment of areas:
The assessment of areas covered by Schedule 4 and those proposed for addition is outlined in sections 7 and 8 of this document and Appendices 1 and 2.
(a) What are your views on the assessment of the various values (conservation, cultural, tourism and recreation, mineral, other) of the land areas discussed?
The discussion document seems to provide a roughly adequate, if limited, coverage of the conservation and cultural values of the Section 4 land areas themselves. However, more detailed analysis of the environmental impacts of possible mining at these sites (beyond merely potential damage at the actual mining site) is conspicuously missing. Environmental impacts that should have been assessed in details include possible greenhouse gas emissions produced during the mining, processing and usage of mined minerals and organic deposits, the potential polluting effect of the processing of minerals and ore, the potential for very large quantities of mining waste products, and air pollution potentially resulting from the eventual burning of mined fuels such as coal.
Q4 On the proposal to further investigate the mineral potential of some areas:
The Government is carrying out a research and investigation programme on the mineral potential of areas with significant mineral potential over the next nine months, including the Coromandel, parts of Paparoa National park and Rakiura National Park, and a number of non-Schedule 4 areas.
(a) Do you have any comments on the type of information that would be the most useful to mineral investors?
I find this question problematic in that I believe that the investigation should produce information that is useful to other stakeholders rather than only mineral investors (e.g. information about the potential environmental impacts involved in pursuing mineral deposits in the areas mentioned). The wording of this item implies that the government prioritises mineral investors over other such stakeholders.
(b) Are there any particular areas that the Government should consider including in its investigation programme?
I believe that any further investigation of the mineral potential should include a comprehensive assessment of the expected greenhouse gas/carbon “footprint” that would eventuate as a result of the mining of mining resources identified. This investigation should incorporate information about the greenhouse gas footprint involved in mining, processing, and use of any minerals and fossil fuels to be mined (including uses such as the burning of organic minerals for power production).
Q5 On a new contestable conservation fund:
Section 9 describes a proposed contestable conservation fund the Government proposes to establish, which would be made up of a percentage of the money the Crown receives from minerals (except petroleum) from public conservation areas.
(a) A broad objective, to enhance conservation outcomes for New Zealand, is proposed for the fund. Do you agree with the proposed objective?
No. Given the growing interconnectedness (and interdependencies) of countries across the world, and especially in light of the global climate change crisis, New Zealand must extend the focus of its conservation efforts to global conservation issues. An alternative goal could be “to enhance local and global conservation outcomes”.
(b) What do you think the fund should be used for? What should its priorities be?
I believe that the fund should have as one of its priorities the aim of making a positive contribution to the understanding of global climate change and the potential for mitigating this change. This could be achieved by the funding of research examining climate change and the technological possibilites for its mitigation, as well as practical mitigation efforts such as promoting the planting and retention of forests to remove carbon dioxide by photosynthesis.
I furthermore believe that this fund should absolutely not be used to fund mining companies for remediation work on mined land. The mining companies themselves should bear the full cost of such work.
(c) An independent panel appointed by the Minister of Energy and Resources and the Minister of Conservation is proposed to run the fund. Do you think this is a good idea?
No. If the fund is genuinely intended as a conservation fund, the Minister of Energy and Resources should have no role in determining its administrators. The independent panel should be appointed by the Minister of Conservation, preferably in consultation with the environmental spokespeople of the other political parties represented in parliament.
(d) It is proposed that half of royalties from public conservation areas are contributed to the fund, with a minimum of $2 million per year for the first four years, and a maximum of $10 million per year. Do you think the amounts proposed for the fund are appropriate?
While the minimum amount may be appropriate, there seems to be little reason to cap the possible contributions at the relatively moderate amount of $10 million pa. I would propose applying no limit to the contribution; this policy could be amended at a later stage.
(e) Do you have any other comments that might help the Government to make decisions on a new conservation fund?
While this fund would be a positive step, I note that the government cut $54 million from the Department of Conservation’s core budget last year. I strongly believe that conservation should be a major priority for New Zealand, and that this funding should therefore be reinstated. The current proposed conservation fund should not in any way be used to justify reductions in funding for DOC.
Q6 On approval of access arrangements:
In section 6 it is proposed that the joint approval of the land-holding Minister and the Minister of Energy and Resources be required for an access arrangement on Crown land for mineral exploration or development. Do you think this is appropriate? Why or why not?
No. This change seems to be focused on sharing decision-making power over access arrangements to public conservation land with a development-focused minister. Conservation land is land that has been designated of primary conservation value: decisions about access arrangements to such land should be made by a competent Minister of Conservation, not a Minister whose portfolio focus is concerned with economic development.
Q7 On any other issues:
Do you have any further suggestions or comments on what has been said in this document?
I strongly believe that any proposal to increase access to New Zealand's mineral and fossil fuel reserves should be made with the potential impact on New Zealand's greenhouse gas emissions as the first and most important focus. The mining and use of coal is a particularly important issue to consider. In a paleoclimate study, Hansen et al. (2008) have argued that swiftly phasing out the use of coal in power production is a vital step in reducing the atmospheric level of carbon dioxide to a safe level of 350 ppm, a proposal I strongly agree with.
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