Salmon farming

This work forms part of the Institute’s OneOceans Project and ClimateChangeNZ Project.

The Department of Conservation’s website states: ‘New Zealand is a world hotspot for biodiversity … We have over 17,00 known species and more are being discovered all the time. Experts estimate up to 85% of New Zealand wildlife could be in the ocean … In a 2008 global study on known marine wildlife found that New Zealand ranked the highest in the world for our proportion of native species. This is because of the isolation of Australia and New Zealand, which separated from other land masses about 83 million years ago. Over half of our 17,000 reported species are endemic, which means they are only found here. This includes over 6000 known species of invertebrates, and hundreds of seaweeds and fish.’

Inshore waters, generally speaking, have the greatest biodiversity. The MarineBio Conservation Society (MarineBio), a large non-profit volunteer marine conservation and science education group state: ‘The epipelagic zone stretches from the surface down to 200 m and is home to the greatest biodiversity in the sea, largely because of the availability of sunlight that enables photosynthetic organisms to thrive’ (learn more here).

In order to understand the issues confronting our oceans, the Institute has focussed on applications by New Zealand King Salmon (NZKS) to extend water use in the Marlborough Sounds. The Institute believes all applications that are likely to impact the biodiversity of inshore waterways, require special consideration.

About New Zealand King Salmon

New Zealand King Salmon Investments Limited, together with its subsidiaries, engages in the farming, processing, and sale of premium salmon products in New Zealand, China, North America, Australia, Japan, Europe, and internationally. NZKS is listed on the New Zealand Stock Exchange, learn more here.

As a result of rising water temperatures, NZKS is becoming an early victim of climate change. Recently, NZKS is changing its business model to account for and seek out cooler water to farm salmon. However water temperatures are rising even in the Cook Strait, where they are currently applying to farm salmon (see the Blue Endeavour application below). See Working Paper 2021/14 – The Role of Water Temperature in Climate Change Policy – A New Zealand King Salmon Case Study.

NZKS also contributes to climate change by emitting carbon when importing fish feed, cooling water, and exporting salmon.

The table below lists submissions made by the Institute in response to applications made by NZKS. These insights have also led to working papers (found here) and letters to Ministers (found here).

Table of McGuinness Institute Submissions on NZKS applications

MI Date of SubmissionMI SubmissionStatus/Decision on Application Recipient of Submission (by Entity) Being Heard by? (e.g. Court or Commissioners)Full title of Invitation to Comment/SubmissionTheir descriptionTheir Reference Number (e.g. application number/court number) - if applicable
February 2021Marlborough District Council Variation 1: Marine Farming and Variation 1A: Finfish Farming [submission]

Memorandum of Counsel for the McGuinness Institute (11 January 2022)

Supplementary Responses (11 January 2022)
In progressMarlborough District Council (MDC)Councillors: Trevor Hook (Chairperson); David Oddie
Commissioners: Shonagh Kenderdine; Rawiri Faulkner; Sharon McGarry
Variations 1 and 1A to the Proposed Marlborough Environment Plan (PMEP)
[see here for MDC files]
Variation 1: Marine Farming
Variation 1A: Finfish Farming
September 2020NZKS’s application to vary condition 36 of U140294 [submission]

NZKS’s application to vary condition 40 of U140294 [submission]

NZKS’s application to vary condition 40 of U140296 [submission]

ENV-2021-CHC-074 Party Notice (12 July 2021)

ENV-2021-CHC-105 Party Notice (27 October 2021)
[see decision here]
Marlborough District Council (MDC)Commissioner: Sharon McGarryThe New Zealand King Salmon Company Limited - Section 127 Variation to Conditions - Coastal Permit - Waitata Reach, Pelorus Sound/Te Hoiere & Ngamahau Bay, Tory Channel/Kura Te Au (U140294 & U140296)Section 127 Variation to change:
condition 36 of U140294 (increase the Maximum Initial Feed Discharge); condition 40 of U140294 (alter the Environmental Quality Standards and the definition of Enrichment Stages); and condition 40 of U140296 (alter the Environmental Quality Standards and the definition of Enrichment Stages)
March 2020Marlborough District Council - The New Zealand King Salmon Co Limited (NZKS) and Te Atiawa o Te Waka-a-Maui Limited (U160675): Te Uira-Karapa Point (Clay Point), Tory Channel/Kura Te Au [submission]Withdrawn
[see here]
Marlborough District Council (MDC)N/ANZKS Section 127 RMA application to vary U160675
[see here for MDC files]
An application pursuant to s 127 to amend condition 25 of U160675, to provide for a maximum discharge of 9,000 tonnes of feed across two consecutive yearsU160675
December 2019The New Zealand King Salmon Co Limited (U190438) North of Cape Lambert, North Marlborough [Blue Endeavour] [submission]

Memorandum of Council for the McGuinness Institute (18 February 2022) [clarification from hearing]

Figure 1 (November 2021) [REVISED from Submission]

NZKS Application U190438 (22 October 2021) [McGuinness Institute presentation]

Statement of Evidence in Reply (Wendy McGuinness)
(14 October 2021)

Outline of Legal Submission (McGuinness Institute) (14 October 2021)

Statement of Evidence (Wendy McGuinness) (7 October 2021)

Statement of Evidence (Professor Slooten) (7 October 2021)
In progressMarlborough District Council (MDC)Commissioners: Craig Welsh (Chairman); Rob Enright; Liz BurgeThe New Zealand King Salmon Company Limited Application for Resource Consent – U190438 – Coastal Permit (Marine Farm) – The New Zealand King Salmon Co. Limited – North of Cape Lambert [Blue Endeavour]
[see here for MDC files]
To establish and operate new salmon farms within a 1,791 hectare site located between 5 kilometres and 12 kilometres due north of Cape LambertU190438
July 2019Marlborough District Council Resource Consent Application U190357 New Zealand King Salmon Co Limited Variations sought to Waitata Farm consent conditions [submission]

Oral presentation to New Zealand King Salmon (NZKS) Hearing (U190357): Waitata Reach, Outer Pelorus/Te Hoiere (November 2019) [Note: Edited with references added]

Attachment 1: U190357: NZKS Waitata Applications: “Baseline” for Effects Assessment – Letter from Morgan Slyfield (26 November 2019)

Attachment 2: The environmental cost of animal source foods (Hilborn et al., 2018)
[see decision here]
Marlborough District Council (MDC)Commissioner: John MillsThe New Zealand King Salmon Co. Limited - Application for Resource Consent - Coastal Permit - Waitata Reach, Outer Pelorus/Te Hoiere (U190357); and The New Zealand King Salmon Co. Limited - Section 127 Variation to Conditions - Coastal Permit - Waitata Reach, Outer Pelorus/Te Hoiere (U140294)Coastal Permit to increase the maximum area of net pen surface structures at the existing Waitata salmon farm (site 8632) from 1.5 hectares to 2.25 hectares, by installing four additional net pens, 10 additional anchors and 10 additional surface floats, and changing the associated conditions 2 and 14 on existing resource consent U140294U190357
May 2017Statement of Evidence of Wendy McGuinness, McGuinness Institute, in opposition to the potential relocation of salmon farms in the Marlborough Sounds (2 May 2017) [submission]

Proposed Marlborough Salmon Farm Relocation (9 May 2017) [presentation]

Attachment 1: Working Paper 2017/02 – Letter to the Minister on New Zealand King Salmon (May 2017)
[see Report and Recommendations of the Panel here]Ministry for Primary Industries (MPI)Advisory Panel: Peter Skelton (Chair); Ron Crosby; Alan DormerPotential relocation of salmon farms in the Marlborough Sounds
[see MPI proposal here]
Proposal to amend the Marlborough Sounds Resource Management Plan to enable the relocation of up to six existing salmon farms by regulations made under sections 360A and 360B of the Resource Management Act 1991N/A
March 2016Submission on a new Marine Protected Areas Act [submission]Policy under reformMinistry for the Environment (MfE)New Zealand GovernmentA New Marine Protected Areas Act
[see consultation document here]
The Government is consulting on a new policy for marine protected areas in the territorial sea. The reforms aim to achieve an appropriate balance between protecting our marine environment and maximising commercial, recreational and cultural opportunities now and into the futureN/A
May 2012New Zealand King Salmon Company Limited Application to the Environmental Protection Authority (Part 1) [submission]

Statement of Evidence  (Part 2) (10 August 2012)

Final Statement of Evidence (Part 3) (27 September 2012)

Submissions on proposed conditions of consent (Part 4) (16 October 2012)

Comments on minor or technical aspects of the Draft Report (Part 5) (8 February 2013)
[see Final Report and Decision here]Environmental Protection Authority (EPA)Board: Gordon Whiting (Chairperson); Helen Beaumont; Edward Ellison; Mark Farnsworth; Michael Briggs Board of Inquiry New Zealand King Salmon Plan changes and Applications for Resource Consents
[see press release here]
In the matter of the Resource Management Act 1991 and a referral to a Board of Inquiry under Section 147 of the Act of requests for plan changes and applications for resource consents by The New Zealand King Salmon Company LimitedN/A