As I was saying the other day, I felt my submission opposing mining in the high-quality Schedule 4 conservation areas, was too long.
Here is my shorter version, weighing in at 642 words.
Schedule 4 stock-take
Ministry of Economic Development
PO Box 1473
Submission on Schedule 4 stock-take discussion document
Please accept this submission in response to your notice of 22 March 2010.
Q1 On the areas proposed for removal from Schedule 4:
I oppose the proposal to remove the suggested conservation areas from Schedule 4 and therefore remove their protection from mining because:
1.Mining will harm biodiversity. It will reduce the habitats of New Zealand's endemic species, many of which are endangered, and make range contraction and species decline more likely.
2.Mining will involve removal of mature native forest. This deforestation and further coal mining will release additional volumes of the greenhouse gas carbon dioxide into the atmosphere.
3.Mining will increase the pollution of freshwater environments caused by acid mine drainage.
4.Mining involves significant earthworks and roading and tailings dams. These are frequently not adequately managed to prevent excess nutrient-rich sedimentation running off into streams and other natural freshwater ecosystems. This will impose further adverse cumulative effects (in conjunction with intensive agricultural run-off) on the already declining water quality in New Zealand's rivers, streams, lakes and estuaries.
5.Mining will conflict with recreational use and scenic values of the conservation areas.
6.Mining is a destructive, damaging and exploitative land use that is completely inconsistent with the statutory conservation purpose for which these conservation areas are held.
7.Allowing additional mining in conservation areas detracts from New Zealand's international image and makes our marketing of tourism and our exports appear hypocritical, especially in the eyes of our competitors and in the view of environmentally conscious consumers in the OECD countries.
Q2 On the areas proposed for addition to Schedule 4:
I support the addition of the listed protected areas to Schedule 4.
I also request that all places that match the land classifications listed in Schedule 4 should be automatically added to Schedule 4 when gazetted to ensure protection from mining.
Q3 On the assessment of areas:
For all areas I consider that the environmental and conservation values (biodiversity, native species habitat, wildlife, cultural, recreational, amenity, scenic, carbon sequestration) outweigh the highly speculative economic values ascribed to the minerals that these areas are alleged to have.
Q4 On the proposal to further investigate the mineral potential of some areas:
I oppose this proposal. I oppose subsidising the minerals industry with $4 million of taxpayers’ money to investigate the mineral potential in New Zealand's conservation areas.
Q5 On a new contestable conservation fund:
I completely oppose forming this fund. Conservation of biodiversity is an important enough matter to have adequate funding without having to be “in debt” to mining within conservation areas. Conservation outcomes can be best enhanced by reversing the $50million cut (over three years) in the Department of Conservation’s budget.
The tying of conservation funding to mining and the “greenwashing” of this proposal would further undermine New Zealand's current international reputation for excellent management of biodiversity and conservation areas.
Q6 On approval of access arrangements:
I oppose adding the approval of the Minister of Energy and Resources to the access decisions of the Minister of Conservation because this would introduce energy, economic and mineral considerations into the Ministerial decision on granting mining access arrangements to conservation areas.
I support the status quo where the Minister of Conservation must consider the statutory land management purposes and land management plans and the potential adverse effects of access against conservation purposes.
In summary, I remain unconvinced by the assertion that mining in conservation areas can be environmentally responsible.