Tāngaro Tuia te Ora, The Endangered Species Foundation has submitted strong opposition to the inclusion of sand on the government’s proposed Draft Critical Minerals List. The classification of sand as a critical mineral is unnecessary from an economic perspective and poses significant risks to marine ecosystems.
Sand is plentiful and environmentally less harmful extraction and manufacturing options already exist. Auckland's total concrete sand demand needs can be met - there is plenty of sand, there is no sand crisis and there is no economic justification to sand mine our seabed.
Why Sand Is Not a Critical Mineral
According to international guidelines and best practices, critical minerals are defined by their rarity and essential role in the production of high-value technology, often without sufficient substitutes. However, aggregate and sand don’t meet the criteria for critical minerals as outlined in the Wood Mackenzie Report[1] here in Aotearoa New Zealand. These materials are neither rare nor at risk of supply shortages, nor are they indispensable for producing critical products. Including aggregate and sand is inconsistent with established guidelines and lacks support from international practice.
Sand and aggregate have a low supply risk rating, with ample substitutes available. Their inclusion in the critical minerals list is unnecessary and could lead to over-extraction from sensitive environments when alternatives can be sourced without harming ecosystems. New, substitute supplies have opened at Brookby quarry and alternative, sustainable sources have been developed, for example Kayasands. Another fast-track project is also proposed for the Te Ara Precinct development, further adding to sand supply needs.
Sand and aggregates are also not included in the “International Partner Critical Minerals List” for the USA, UK, EU, Australia or Canada.
Alternatives Exist
Kayasand
There are sustainable sand substitutes, including Kayasand, a Waikato company with innovative solutions to produce sand from quarry materials and waste products. Kayasand plants utilise a specialist crusher and air screen technology developed by KEMCO in Japan. This technology was originally developed because of a ban on dredging that severely disrupted concrete sand supply in Japan. Since its launch in early 2000s, there are now over 300 plants in Japan, China and India.
In 2023 Kayasand opened the first V7 high-technology demonstration plant in Waikato, New Zealand showcasing this revolutionary crushing technology which processes crusher dust, a by-product of quarries, to create quality sand aggregates that can be used in concrete production.
This process:
Recycles waste materials, turning glass, concrete, and quarry by-products into valuable sand for concrete production.
Produces high-quality sand from quarry materials like basalt and greywacke using advanced crushing and grading technology
Produces consistent quality – they cuboidal shape of Kayasand’s product allows for up to 20% less cement in concrete production, reducing material use and emissions.
Integrates recycled waste and cement substitutes like limestone filler and slag, contributing to a lower carbon footprint for the construction industry.
Kayasand plants have production capabilities of 50,000 - 60,000 tonnes per annum. Their v7-120 model plant would be well suited for existing Auckland quarries, enabling roughly 300,000 tones per annum of production per plant.
Brookby Quarry
Other key operations include Kaipara Ltd who are mining sand on-land, and who run the Brookby Quarries manufactured sand plan. When McCallum Bros Ltd Pakiri dredging operation was scaled back at Mangawhai / Pakiri, Brookby quarry invested in equipment to increase their manufactured sand supply.
This new operation is now producing 300,000 tonnes of product a year and a second stage - which would increase that to 500,000 tonnes annually - could be up and running in six months, if demand requires[4][5]. This would cover 45% of Auckland’s needs within six months.
Ngāti Manuhiri's Te Arai Precinct Proposal
A new fast-track proposal by Ngāti Manuhiri[2] further south in Te Arai would also supply up to 300,000 cubic metres of sand a year for as long as 35 years[3]. The accessible sand reserve is estimated at over 6 million cubic metres, which would help to ensure security of supply for development and infrastructure projects for decades to come. At current values, such sand, once extracted, washed and graded, has a market value of over $180 million.
This project will also provide long-term economic gains for Ngāti Manuhiri with planned parks, accommodation and cultural tourism experiences in the Te Arai Precinct.
“We know that bold steps are needed to undertake development in a way that is also environmentally conscious and the ability to expedite consents and permissions for environmental remediation have a great deal of appeal,” says Ngāti Manuhiri Settlement Trust Chief Executive, Nicola MacDonald[4].
Auckland's total concrete sand demand needs can be met. There is plenty of sand and there is no sand crisis.
Currently, it is standard practice in New Zealand to replace 55% of natural sand in concrete. However, the new technology now available allows for 100% replacement using high-quality engineered sand produced in quarries.
Auckland's total concrete sand demand is 1.2-1.4 million tonnes per annum. This means that four of Kayasands v7-120 plants could meet all of Auckland's concrete sand demand. Likewise, Brookby's new manufactured sand production could meet 25-50% of concrete sand demand in Auckland[5].
McCullum Bros Ltd have applied to extract 8.5 million cubic metres and they can take it out of the environment at very little charge, providing no local benefits. Approving sandmining by McCallum Bros Ltd doesn’t just come at the expense of the fishing industry, eco-tourism, and local wellbeing, it’s also allowing anti-competitive behaviour that creates barriers to entry to innovation and more sustainable sand solutions.
More viable, innovative and sustainable sand aggregate solutions need to be supported and scaled. In regards to Northland, there is the potential create new and sustainable jobs, employing local people, using waste product from three existing quarries. Nationally, more of these plants could operate in other regions of the country, where there are existing quarries.
Sandmining will Negatively Impact Local Environments and Economies
Sandmining creates massive sediment plumes, dead zones on the seabed, and destroys fishing grounds and kaimoana (seafood) stocks that sustain local families and recreational fishers.
Natural coastal buffers are also depleted by eroding shorelines, reducing their ability to absorb wave energy and protect against storms. Over time, this accelerates coastal erosion, increases the vulnerability of coastal communities to flooding and sea-level rise, and drives up the costs of mitigation efforts, such as seawalls and dune restoration. In severe cases, it may even necessitate the costly relocation of communities and infrastructure.
Sand mining devastates eco-tourism by eroding beaches, damaging marine habitats, and disrupting the scenic landscapes that attract visitors. As natural coastal features disappear, wildlife declines, and recreational opportunities diminish, tourism revenue suffers. Additionally, the environmental degradation caused by sand mining tarnishes the reputation of coastal communities, making them less desirable destinations and undermining their long-term economic sustainability.
Biodiversity at Risk
With over 7,500 species in Aotearoa at risk of extinction, including 800 listed as high-risk by the Department of Conservation, Tāngaro Tuia te Ora believes the Draft Critical Minerals List ignores the pressing need to prioritise environmental health. Instead of promoting sustainable innovation, the list encourages mining practices that will exacerbate environmental degradation.
Endangered species such as the critically endangered tara iti, our most endangered bird, currently nests and breeds at Mangawhai, Pakiri and Waipū Cove, and there are 26 other at-risk bird species that live in the Mangawhai area. The critically endangered Hawkes Bill Turtle has been spotted near the proposed Bream Bay sand extraction site. The sand extraction zone is also close to the Hen and Chicken Islands Nature Reserve and the Whangārei Harbour Marine Reserve.
Calls for Sustainable Economic Solutions
Tāngaro Tuia te Ora the Endangered Species Foundation, is calling on the government to revoke its classification of sand as a critical mineral, advocating for the promotion of recycled sand and quarry-manufactured alternatives. Supporting such innovation would reduce the need for harmful extraction practices while helping New Zealand meet its economic growth, biodiversity and climate goals. This would also alleviate the huge risk of further tarnishing our reputation on the international stage.
“We need to support sustainable alternatives and stop the unnecessary extraction of sand from our sea beds,” says Natalie Jessup, General Manager of Tāngaro Tuia te Ora. “We have the opportunity to embrace environmental innovation for sand aggregates, which could be scaled across the country to create local jobs, ensure economic growth and preserve our marine life, beaches and the wellbeing of our people.”
For comment and further information please contact:
Natalie Jessup
General Manager Tāngaro Tuia te Ora, Endangered Species Foundation
[1] https://www.mbie.govt.nz/dmsdocument/29467-draft-critical-minerals-list-for-public-consultation-september-2024-pdf
[2] https://environment.govt.nz/assets/what-government-is-doing/Fast-track-listed/Integrated-Development-Plan-for-Te-Arai-South-Precinct-and-Regional-Park/327.09-FTA327-Integrated-Development-Plan-for-Te-Arai-South-Precinct-and-Regional-Park-Sch-2A-MfE-assessment-form-Stage-1_Redacted.pdf
[3] https://www.localmatters.co.nz/environment/thirty-five-years-of-sand-mining-included-in-te-arai-fast-track-bid/
[5] The use of manufactured sand versus dredged sand in Auckland concrete, December 2024, Kayasand