Monday, May 24, 2010

Schedule 4 Submission

Wednesday 26 May 2010 is the last opportunity to make a submission regarding the review of Schedule 4 of the Crown Minerals act. You can make a submission online from here. My submission was as follows

Q1 On the areas proposed for removal from Schedule 4:  
Section 7 of the discussion paper 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? (Your response may be in relation to any one or more of the areas discussed. Please clearly identify the area(s) to which your response relates.)  

No. If you are considering a case-by-case basis then it would seem more sensible to have Schedule 4 protection also removed on a case-by-case basis. A tragic outcome would be for some company to pick up the land for cheap should no other company want it.

Q2 On the areas proposed for addition to Schedule 4:  
Section 8 of the discussion paper 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? (Your response may be in relation to any one or more of the areas discussed. Please clearly identify the area(s) to which your response relates.)  

I'm indifferent to this. On the one hand if the proposed land has notable conservation status then it should be added to Schedule 4, regardless of what happens to any other land. On the other hand if it is being proposed, as I suspect, to make people feel good about giving up pre-existing Schedule 4 then I don't think it should be. In one sense if it isn't worth putting in schedule 4 it shouldn't be put there, and secondly that it sets a precedent that Schedule 4 land could be taken out later if the powers that be change their mind about the worth of the land.

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?  

In general fine. I do note that seemingly when the mineral wealth is potentially high usually removal is proposed only if there are no cultural values attached, conservation values seem to be ignored in terms of making the final decision.

(b) Do you have any additional information that may be important for Ministers to make their decisions?  

The maps seem a bit vague conservation wise. It seems to me that it would have been sensible to look within schedule 4 at where important populations of native flora and fauna are centered and then overlay the proposed areas for mining. Afterall conservationally not all land is equal.

(Your response may be in relation to any one or more of the areas or values discussed. Please clearly identify the area(s) to which your response relates.)  
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.  
Areas include 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?

(b) Are there any particular areas that the Government should consider including in its investigation programme?  

I'm probably going to get myself into trouble for saying this but I don't think anywhere should not be considered for investigation (note I say this not being fully aware of how destructive, if at all, investigation is). Even if it's not pursued in the immediate future it seems sensible to know approximately what mineral worth is located where.

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?  

I would have to say I'm against this. Firstly "The fund would not be used to mitigate the effects of modern mine sites or to provide compensation as appropriate for mining activities. Mining companies would be responsible for that themselves (it would continue to form a part of their resource consent and access conditions)." although mining companies should indeed make sure the impacts are minimal there is no mention here of how it would be monitored. Having the companies themselves also monitor it seems a recipe for disaster.

I'm not clear why DOC has been ruled out of receiving it.

Additionally "It would not be restricted to public conservation areas." seems rediculous. So land is taken out of schedule 4 for mining, generates revenue, and that money potentially doesn't go back into public land?! Really?

(b) What do you think the fund should be used for? What should its priorities be?  

Dammit Jim, I'm a mathematician not an ecologist.

(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?  

Potentially, although it seems to be lacking people concerned with tourism and/or cultural values.

(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?  

I don't know enough to answer that question.

(e) Do you have any other comments that might help the Government to make decisions on a new conservation fund?

How could DOC and other related organisations fit into the scheme? Presumably there shall be similar aims and requirements for expertise that DOC, et al. probably already have.
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?  

Not completely. Surely the Minister of Conservation should be in there as well since it seems likely a lot of the mining will be happening within or next to conserved land.

Q7 On any other issues:  
Do you have any further suggestions or comments on what has been said in this document?


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