Under The Resource Management Act 1991 In The Matter of the application by the Astrolabe Community Trust to the Bay of Plenty Regional Council for Resource Consents in relation to the remains of the MV Rena. Environment - Julian Fitter Background 1. I am an environmental consultant with an Advanced Diploma in Environmental Management from the University of Oxford (UK). I have extensive knowledge and experience of island ecosystems, namely; Galapagos Islands, Falkland Islands , Tristan da Cunha and New Zealand. I am an author of several books on the natural history of Galapagos and New Zealand. I am a Vice-president of Falkland Conservation and an Ambassador of the Galapagos Conservation Trust (UK). I am Chair of Friends of Galapagos New Zealand and of the Maketu Ongatoro Wetland Society Inc. (MOWS). 2. I have good knowledge and understating of ships and the sea; I have sailed from UK to Galapagos three times in small vessels, twice as captain, and ran a yacht charter business in Galapagos. I have further marine experience in both the Falkland Islands and Tristan da Cunha and own an 11m. yacht in Tauranga harbour. 3. I am resident in Maketu and was significantly involved in work to mitigate the impact of the MV Rena oilspill. As part of my management responsibilities with MOWS I manage the Biodiversity Management Plan (BMP) on Maketu Spit, which plan is supported and funded by BOPRC, WBOPDC and DOC. MOWS is a social enterprise and a Registered Charity. Maketu - Environmental significance 4. Maketū and its surrounding area is an important ecological area with both national and international recognition. 5 Maketu Spit is the best preserved duneland in the Tauranga ecological District and home to a large colony of Northern New Zealand dotterel. A survey in 2009/10 discovered four species oif invertebrate that are undescribed or new to science. 6. The lower Kaituna River, Maketu and Waihi harbours have been identified as a potential Ramsar Site - a wetland of international significance. 7. Maketu has been designated an Important Bird Area (IBA) by BirdLife International. It is one of only 17 such sites on the North Island. 8. Much of the work that I do is focussed on Maketu Spit, Newdicks Beach and Dotterel Point Pukehina, much of this is to do with either monitoring the native wildlife, or managing the ecosystem to remove invasive pest animals and plants. While the area did suffer from the initial oilspill, the area has fully recovered, and the population of the Northern New Zealand dotterel while initially suffering a significant numerical loss, is now greater than it was prior to the grounding. Negative aspects of full wreck removal 9. While in an idea situation, the complete removal of the wreck would be the correct course of action, a number of factors make this the less attractive option compared to leaving it in situ, subject to a range of caveats and conditions. 10. The salvage work that has taken place on the wreck site has to date, had minimal impact on the immediate coastal environment, but the longer that work continues, the greater the possibility of a second accident which might have a significant impact on the local coastal environment, possibly greater than the original one - this is an eventuality that, while unlikely, must be considered a possibility. A tsunami while the barge is at work does not bear thinking about - White Island is clearly visible from Astrolabe reef 11. I have discussed the matter of the removal with overseas experts, and have been advised that because these large container vessels are essentially of a 'monocoque' construction, in other words their strength rests in their being entire. Once you break the integrity of the whole, then the structure has very little inherent strength and is liable to 'fall to pieces'. 12. While pollution needs to be avoided, it is a fact that all of the larger vessels operating in the bay are coated with antifouling paint which by its nature is a continuous state of dissolution. The antifouling paints on MV Rena include both Copper and TBT, however the rate of dissolution slows down over time as the paint becomes encrusted with marine growth, and the current rate of dissolution is minimal or nugatory. Likewise the rate of decay of copper clove and other potential pollutants is very slow. 13. Should an attempt be made to remove the remains of the vessel, this can only done by cutting it into sections using a very primitive technique - a chain saw. This process in itself will release greater amounts of pollutants and contaminants, in particular any remaining fuel and lubricating oils, However the real danger is that in the process the vessel will simply break into pieces, and that we will end up with the worst of both worlds, the release of significant amounts of pollutants and contaminants, and the wreck still on the reef. 14. The barge that will be needed to do the work will need to be secured by a number of very large anchors, they and their cables, the latter being in a fairly constant state of motion, will do significant damage to the sea bed around the reef. there is also the very real possibility of damage to the reef itself. 15. The wreck is at such a depth, that the removal of the entire vessel would be an extremely hazardous enterprise and there is the very real possibility that one or more people could be seriously injured or killed during the operation. Such an event would have a serious negative impact on the mauri of the reef. Positive aspects of leaving the wreck in situ 16 The sea is adept at taking over whatever it finds, there are countless thousands of man-made items littering the sea floor, in many instances these add additional and beneficial habitat for marine creatures. There is little doubt that the Rena has increased fish habitat and numbers around Otaiti. 17. The tourism and recreational benefits of leaving the vessel are clear, bird watching, diving and fishing would once again be permitted and a significant recreational resource would be restored for the use of the local community. Given that total removal is estimated to take up to five years, this is a very clear and obvious benefit. 18. Much has been made of the damage to the 'mauri' of Otaiti. The concept of mauri or life force is common to most cultures, but over time all natural features, such as reefs, change. Otaiti was once an active volcano, but is being gradually eroded away, so the mauri is changing. I would argue that the ship has its own mauri, this is also a common concept among seafarers, and that far from damaging the mauri of Otaiti, Rena has added her own mauri to it. 19. I am strongly of the opinion that once the debris field has been cleared of all easily removable items that the wreck should be left in peace to gradually decay and become part of Astrolabe reef. The sooner this happens the better, and the less the risk of further environmental damage. It will also ensure that the reef can return to being the important recreational and economic feature that it was prior to the wreck. Conditions 20. The owners and their insurers should be required to meet any and all clear-up costs and provide bonds to cover future eventualities. 21. Funding for benthic research in the Bay of Plenty. 21. Owners to fund a documentary film about the disaster, the community response and the amazing wildlife of the reef and the nearby coast. Julian Fitter, Maketu, 14 September 2015.