Before the EPA Trans-Tasman Resources Ltd Ironsands Extraction Project

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Before the EPA Trans-Tasman Resources Ltd Ironsands Extraction Project In the matter of the Exclusive Economic Zone and Continental Shelf (Environmental Effects) Act 2012 And In the matter of a board appointed to consider a marine consent application made by Trans-Tasman Resources Ltd to undertake iron ore extraction and processing operations offshore in the South Taranaki Bight Statement of Evidence in Chief of Martijn Schouten on behalf of Trans-Tasman Resources Ltd 15 February 2014

Introduction 1. My name is Martijn Schouten. I hold a Bachelor s degree in Accounting from Avans University, The Netherlands, and am in the process of obtaining a Masters of Business Administration from INSEAD. 2. I have held various positions at IHC companies since 2006. IHC Merwede is a technology company which designs, builds and supplies vessels and equipment for the dredging and offshore Oil & Gas construction industries. 3. I am currently the Managing Director of IHC s Mining Division. My other roles have included the Head of Subcontracting at IHC Merwede B.V., the Head of Business Development & the Shipyard Manager at IHC Dredgers and IHC Alblas, and the Director of Business Development, Mergers and Acquisitions at IHC Merwede Holdings. I have also worked as a Corporate Recovery Consultant at LEADING EDGE BV, and gave risk management and corporate finance advice at PricewaterhouseCoopers. 4. In my current role at IHC Mining I am responsible for: (a) The establishment of a new division with a high growth ambition including worldwide operations and sales activities (in The Netherlands, South Africa, Singapore and Sydney); (b) Building an international management team consisting of senior colleagues from other divisions and senior professionals from outside the company with a proven track record; (c) The Initiation and set up of global partnerships and joint ventures; (d) Leading the "global first mover in deepsea mining" ambition by managing an R&D program, building a team of highly educated experienced staff, establishing strategic partnerships and "educating" the global capital market and management of mining houses; and

(e) Building a global sales and business development organization. Code of Conduct 5. I confirm that I have read the Code of Conduct for Expert Witnesses as contained in Schedule 4 of the Judicature Act 1908 and the Environment Court Consolidated Practice Note 2011. I agree to comply with these Codes of Conduct. In particular, unless I state otherwise, this evidence is within my sphere of expertise and I have not omitted to consider material facts known to me that might alter or detract from the opinions I express. Scope of Evidence 6. This evidence covers the expertise of IHC Merwede in marine mining, and describes the subsea sediment extraction device (the Crawler mining machine) technology that Trans-Tasman Resources Limited (TTR) proposes to use to mine ironsands in the South Taranaki Bight (the Project). 7. IHC Mining will provide the design of the floating offshore installation, the Crawler mining machines, the launch & recovery systems for the Crawlers and the tailings disposal system for the Project. Methodology and Limitations 8. There are a number of important issues IHC Mining focuses on during the complete cycle of design, construction, commissioning, training and handover of the vessel and equipment: (a) Corporate social responsibility (please see IHC s Corporate Social Responsibility Annual Report attached as Appendix B); (b) Working in close co-operation with the client to ensure environmental requirements are met; (c) Working in close co-operation with the client to ensure health and safety requirements are met;

(d) Providing sustainable and efficient equipment and systems; (e) Balancing the interests of the client's operability (people), environmental protection (planet) and operational efficiency (profit); and (f) User manuals and operator training to ensure a proper use of the supplied equipment. IHC Merwede 9. As noted above, IHC Merwede, with a history spanning over 300 years, is a technology company which designs builds and supplies vessels and equipment for the dredging and offshore Oil & Gas construction industries. IHC Merwede has in-house expertise in engineering and manufacturing innovative vessels and advanced equipment, as well as providing life-cycle support. Its integrated systematic approach has helped to develop optimum product performance and long-term business partnerships. The company's broad customer base includes dredging operators, oil and gas corporations, offshore contractors, mining corporations and government authorities. 10. IHC Merwede has over 3,000 employees based at various locations in Australia, The Netherlands, China, Croatia, France, India, the Middle East, Nigeria, Russia, Serbia, Singapore, Slovakia, South Africa, the UK and the USA. 11. Within IHC Merwede a specialised division, IHC Mining, focusses on the design and development of mining vessels and equipment for the mining of underwater mineral deposits found onshore, near-shore and in the deep sea. Please see IHC Mining s marketing brochure giving more detail on the company attached as Appendix A. 12. IHC Mining has been contracted by TTR to design the floating offshore installation (mining support vessel), the Crawler mining machines, launch & recovery systems for the Crawlers and tailings disposal system for the Project.

13. IHC Mining has a proven track record for the mining of underwater deposits onshore and near shore spanning many decades. Onshore mining installations utilise IHC standard dredgers to mine heavy mineral sands, platinum, gold and other minerals from ponds and rivers. Near shore mining installations include the dredge mining of tin from the sea in water depths of up to 20 m and the remote Crawler mining of diamonds from the sea in water depths up to 150 m. 14. With the declining deposits and grades on land, IHC has over the last 5 years invested intensively in developing the technology for mining deposits from the deep sea, in water depths up to 5,000 m. Crawler Technology 15. IHC Mining will provide the design of the floating offshore installation, the remote Crawler mining machines, the launch and recovery systems for the Crawlers and the tailings disposal system. The design will comply with the latest rules and regulations from the maritime and flag state regulatory bodies, as applicable. In addition IHC Mining, as an ISO 9001-2007 certified organisation, will follow a process that complies with good engineering practice and established norms for the offshore industry. This will allow the TTR to perform its mining activities in a safe manner, taking into account the client's requirements for minimising the impact on the environment and to assure the safety of all persons on board. 16. The remote Crawler mining machines each have its own launch & recovery systems and are individually powered and controlled from the floating offshore installation. Launch & recovery of each Crawler is achieved utilising a lift winch and A-Frame together with a passive compensator for keeping the wire rope safely deployed whilst the Crawler is operating on the seabed. 17. The Crawler mining machines consist of a tracked frame and propulsion system which forms the support of the suction boom, suction nozzle and dredge pump for transferring mined material to the process plant on the floating offshore vessel via a rubber slurry transport hose. Power and control is provided to each of the Crawlers by means of an

umbilical cable which is deployed using a specialised winch. All safety systems will be provided for the transfer of power to the Crawler and environmentally friendly fluids will be used for the powering of hydraulic systems or the lubrication of equipment. 18. In order to realize this, the design of the remote crawler mining machines, their launch and recovery systems and the tailings disposal system will be based on known and developed technology and engineering experience that IHC Mining have applied in previous projects for mining clients. For the design of the floating offshore installation, we make use of our in-house naval architects, Vuyk Engineering. Vuyk Engineering will provide a Statement of Evidence in Chief separately. 19. The floating offshore installation will have an overall length of about 350 m and a width of about 60 m. Two remote Crawler mining machines will be installed on the vessel, one operating with the other under maintenance and on standby. Each will be equipped with a 900 mm pumping system for delivering the run of mine (ROM) to the floating offshore installation. The tailings dispotal system on the other hand will return 90% of the treated ROM back to the seabed and deposit it into previously mined areas in a controlled manner as the mining installation advances. In line with the client's requirements the tailings disposal system outlet will maintain a height of 4 m from the seabed. 20. The size and operating water depth of the underwater remote Crawler system to be supplied to TTR relate well to the remote diamond mining Crawlers previously supplied to De Beers for their offshore mining vessel MV Mafuta (previously named the MV Peace in Africa).

21. This system, designed for mining operations off Namibia in water depths of up to 150 metres, included the remote-controlled subseamining crawler, launch and recovery systems, electrical systems, control and instrumentation systems, hydraulic systems, and a fourpoint vessel-mooring system. 15 February 2014