The date for sending in a submission on this issue has passed.
Lyttleton Port plans to expand a quarry, tear down a hill, dredge a bit of harbour and 'reclaim' another part.
Make your submission online now
Read on for guidelines on making a submission.
The environmental impact will be massive. Lyttelton Port shareholders stand to make a short-term profit but our children will be picking up the long-term costs. We think there's a different and better way towards prosperity for all New Zealanders.
If you agree, Environment Canterbury is taking submissions on the coal expansion proposal right now. Take a few moments to tell Environment Canterbury that you oppose any expansion of the Lyttelton Port coal facility.
Submissions close this Friday 12th February.
Making a submission
Read about Lyttleton Port Company's plan on the ECANZ website
Scroll to the bottom of their webpage to make your submission or:
Make your submission online now
Our submission guide
On the online submission form:
- Oppose the 12 proposals
- In the box that says Your reasons, outline your reasons for opposing the proposals. Suggestions below for each of the 12 proposals.
1. Timing of Application
The timing of public notification of the application for the above consents occurred over the Christmas and New Year holiday periods when many locals, community groups and organisations would have been away from Christchurch. The potential for affected individuals and groups to make considered submissions has been much diminished.
2. Insufficient Rationale
Increased extraction and export of coal is an insufficient rationale for the expansion of the port on several counts.
The larger, national and global issue of climate change has been overlooked.
The LPC justifies the project as an opportunity for " 'future proofing' a currently often constrained supply chain for the long-term coal export business."
There is no future for long-term coal exports in light of the national responsibility for combating climate change. Any future proofing should involve long-term sustainable energies and exports with a minimum detrimental effect on climate damage.
Any economic benefit derived from increased coal extraction and export cannot outweigh the impact of coal combustion in terms of exacerbation of climate change. Increasing exports of coal is contradictory to the Government's policy of New Zealand "doing its fair share" to combat climate change.
There is considerable support for the view that climate change and its consequences will impose considerable economic costs that far exceed any of the short-term economic gains to be obtained. Failure to address climate change will cost the planet 5-20% of global GDP each year, now and forever. Increasing coal extraction and exports is a prime example of one such failure.
For Canterbury the regional GDP is about $18.8 billion.ii Failure to address climate change now will cost the region at best $0.94 billion, at worst $3.76B, each and every year.
3. Air quality
Air quality will be further comprised by the proposed expansion and there will be a greater and unacceptable incidence of coal dust drift over Lyttelton township.
This will occur because there will be a large increase in the quantity of coal being handled and stored. This will result in a significant increase in the surface area of the coal stockyard and a large proportion of this would be out in the open harbour (and no longer all sheltered behind by Battery Point as is currently the case). These factors mean that there is an increased likelihood that any wind from the NE to SE quadrant will pick up coal dust from the stockyard and disperse it over Lyttelton.
The dust dispersion modelling undertaken by LPC and described in the AEE shows the average emission rates will increase.
It is difficult to accept the claims by the LPC that this not will translate to increased off-site impacts. The reasons they give include a larger separation from residential areas (no more than 50-100m) and a greater coal surface area; hence greater dust dispersion, appear to us to be highly improbable.
Health issues associated with coal dust in the community including ingestion (by young children in particular), and respiration. The accumulation in soils of coal dust which may contain toxic heavy metals is also a concern.
In assessing air quality, it is not just the average monthly emission rates that need to be considered but the number of days where emission rates exceed acceptable levels.
i) Stern Review on the economics of climate change (2006)
ii) LPC - Economic assessment (Appendix 18 of the application)
4. Use of high quality potable water
LPC intends to mitigate dust through the availability of 24 hours watering per day. Use and any increased use of high quality potable water for damping down coal exports is not workable. Water is a valuable resource and one under pressure in Canterbury at the best of times.
Under a certain combination of climatic conditions the existing water supply is insufficient to adequately service both city supply and coal spraying, and priority is given to the former.
Further increase of the coal stockpile will require a great deal of additional water for spraying, thus increasing the likelihood of reaching the insufficiency threshold. There would be more frequent and longer periods when coal could not be sprayed adequately to mitigate dust.
5. Land reclamation
There are concerns about both the legal and the environmental impacts of the proposed land reclamation. Legal issues around who ( if anyone) actually 'owns' the sea bed and the de facto privatisation of 10 ha of sea bed need to be clarified.
6. Landscape, Visual Amenity
There are concerns about the diminution of visual amenity values associated with the additional quarrying at Gollans Bay, Te Awaparahi Bay and of the negative visual impact of the enlarged coal stockpile itself, especially since it is the very first and last impressions of Lyttelton that are gained by all tourists who visit the town by cruise ship.
7. Water quality
LPC intends to upgrade its storm water treatment system in advance of expanding the stockpile, however we fear that there will still be detrimental effects to water quality in the harbour as a result of the reclamation and operation of the expanded coal-yard. There are concerns about the cumulative effects of coal particulates and heavy metals on water quality and potential adverse effect on marine life .
8. Economic considerations
As indicated above in section 2 (insufficient rationale) the claimed economic benefits do not outweigh the negative contribution to climate change consequences.
Another consideration is that once initial construction activity is complete, the economic gains will accrue predominantly to the LPC and Solid Energy while the burden of the negative environmental impacts will predominantly be borne by the local residents. While there may be a handful of new jobs at the port and in associated coal transport, the direct economic benefits to Lyttelton and surrounding area will be minor.
9. Summary
I oppose this application because:
The purpose of expansion (predominantly coal export) is so completely at odds with our responsibilities at all levels, from local to international, to address climate change as to invalidate any economic benefit;
The local impacts borne by Lyttelton and local communities such as loss of air and water quality, use of potable water etc. plus cumulative negative impacts from existing environmental damage, all combine to render the application untenable.
I wish the consent authority to decline all 12 applications.
Make a submission
Read
about Lyttleton Port Company's plan on the ECANZ website
Scroll to the bottom of their webpage to make your submission or:
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