Salmon farming
Part of the McGuinness Institute’s OneOceanNZ project
Our interest in salmon farming
The Department of Conservation’s website states: ‘New Zealand is a world hotspot for biodiversity … We have over 17,000 known species and more are being discovered all the time. Experts estimate up to 85% of New Zealand wildlife could be in the ocean … [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, states: ‘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 focused 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 a number of countries including New Zealand, China, North America, Australia, Japan, Europe. NZKS is listed on the New Zealand Stock Exchange.
As a result of rising water temperatures, NZKS is becoming an early victim of climate change. Recently, NZKS has changed its business model to address this and seek out cooler water to farm salmon. However water temperatures are rising even in 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.
Table 1 below lists submissions made by the Institute in response to applications made by NZKS. These insights have also led to working papers and letters to Ministers.
Table 2: McGuinness Institute NZKS-related research
Table 3: Copies of active NZKS resource consents by site
Table 1: McGuinness Institute submissions on NZKS applications
| Date of submission | Submission | Status/decision on application | Recipient of submission | Heard by (e.g. Court or Commissioners) | Full title of invitation to comment/submission | Their description | Reference number (e.g. application number/court number), if applicable |
|---|---|---|---|---|---|---|---|
| March 2024 | MPI: Notes in response to the Proposal by Government to extendthe duration of existing consents for marine farming [submission] | Submissions sent | Ministry for Primary Industries (MPI) | Ministry for Primary Industries (MPI) | Extending the duration of existing consents for marine farming [Proposal] [see slide pack on proposal to extend marine consent durations] | The Government is proposing to extend existing marine farm consent durations by an additional 25 years (added to existing consent terms). | N/A |
| December 2019 | The New Zealand King Salmon Co Limited (U190438) North of Cape Lambert, North Marlborough [Blue Endeavour] [submission] Particulars to Facilitate Mediation (1 March 2023) 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) | Granted* Decision* (10 Nov 2022) Consent Order* (19 Sep 2023) – Env Court: amended consent conditions post-mediation McGuinness Institute Press Release (21 September 2023) Appeal: * The Decision (dated 10 November 2022) was appealed: McGuinness Institute Notice of Appeal (2 Dec 2022) Department of Conservation Notice of Appeal (1 Dec 2022) Mediation arising from appeals: NZKS: Mediated settlement to NZKS Blue Endeavour consent (3 June 2023) See also: Fisheries New Zealand: Aquaculture Decision for coastal permit U190438 in the Cook Strait (19 December 2023) | Marlborough District Council (MDC) | Commissioners: Craig Welsh (Chairman); Rob Enright; Liz Burge | The 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 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 Lambert | U190438 U190438.1 Blue Endeavour |
| June 2021 | Party Notice [ENV-2021-CHC-074 ] (12 July 2021) Minute of The Environment Court [ENV-2021-CHC-74 & 105] (29 November 2021) | Granted (7 September 2022) [see decision] | Environment Court Christchurch | Judge: J J M Hassan | In the matter of the Resource Management Act 1991; and in the matter of an Application for a Declaration under s 311 of the Act between the New Zealand King Salmon Co. Limited [Applicant] and Marlborough District Council [Respondent] (Notice of Application For Declaration [NZKS]) (22 June 2021) | Application for a declaration under s 311 of the Act | ENV-2021-CHC -074 (Decision No. [2022] NZEnvC 169) |
| February 2021 | Marlborough 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) | Variation 1: Confirmed* (with amendments) MDC Decision (18 May 2023) MDC Media Statement (23 May 2023) Commissioner’s Decision and Report (28 April 2023) Variation 1A: Withdrawn* MDC Decision (18 May 2023) MDC Media Statement (23 May 2023) [See Commissioner’s Report and Recommendation (28 April 2023) [Variation 1] and [Variation 1A] *Subject to appeals | Marlborough 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 MDC files] | Variation 1: Marine Farming Variation 1A: Finfish Farming | N/A |
| September 2020 | NZKS’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] Party Notice [ENV-2021-CHC-105] (27 October 2021) Minute of The Environment Court [ENV-2021-CHC-74 & 105] (29 November 2021) | Refused* [see decision] * NZKS Notice of Appeal (1 October 2021) NZKS Notice of withdrawing appeal (5 December 2022) | Marlborough District Council (MDC) | Commissioner: Sharon McGarry | The 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) | U140294 U140296 ENV-2021-CHC-105 |
| March 2020 | Marlborough 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/A | NZKS Section 127 RMA application to vary U160675 [see 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 years | U160675 |
| July 2019 | Marlborough 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) | Declined [see decision] | Marlborough District Council (MDC) | Commissioner: John Mills | The 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 U140294 | U190357 U140294 |
| May 2017 | Statement 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] | Ministry for Primary Industries (MPI) | Advisory Panel: Peter Skelton (Chair); Ron Crosby; Alan Dormer | Potential relocation of salmon farms in the Marlborough Sounds [see MPI proposal] | 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 1991 | N/A |
| March 2016 | Submission on a new Marine Protected Areas Act [submission] | Policy under reform | Ministry for the Environment (MfE) | New Zealand Government | A New Marine Protected Areas Act [see consultation document] | 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 future | N/A |
| May 2012 | New 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] | 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] | 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 Limited | N/A |
Table 2: McGuinness Institute NZKS-related research
Table 3: Copies of active NZKS resource consents by site
Note: To be read in conjunction with our Discussion Paper 2023/04: Exploring the role of aquaculture in our marine space (particularly Table 4.1: NZKS salmon farms – By the numbers).
Note: These PDFs are re-uploaded from the Marlborough District Council Property Files Online website and combined where appropriate so that each resource consent has its own individual PDF. We have used the PDF page numbers rather than the page numbers at the bottom of the documents as in some cases the documents contain attachments or sub-documents.
Note: Ministry for Primary Industries also hosts an interactive web-based mapping tool, NABIS (National Aquatic Biodiversity Information System, see here), which displays information about New Zealand’s marine environment, species distributions and fisheries management (including data on marine farms). MPI relies on councils to provide information to update NABIS
.
| NZKS salmon farms with resource consents | Site number | Resource consent Note: Date granted refers to the original consent date | Related resource consents |
|---|---|---|---|
| Internal waters (in the Marlborough Sounds) | |||
| Queen Charlotte Sound/Tōtaranui | |||
| 1. Otanerau (active) (one farm) | 8396 (exp. 2024) | MFL446 (granted 11 July 1990, p. 17). Permitted species: a mix, p. 1 | No copy at MI office: 010127, 950653, 981011, 060822, 080726, 160039, 090002. Note: A MAF planner's report (letter dated 2 Nov 1989) implies the farm was originally established on this site under a 'temporary marine farming licence' granted to Regal Salmon Ltd. Importantly, MDC has no evidence of a vary/add/delete of a previous MFL446 consent, so the oldest date of an active resource consent for this site is 11 July 1990. |
| U040217 (granted 22 April 2005, p. 9). Permitted species: a mix, p. 1 | |||
| MPE763 (granted 9 January 2006, MOF [MDC PC, 15 June 2023]). Original resource consent not found, but relied upon for activity. |
|||
| 2. Ruakaka (active) (one farm) | 8274 (exp. 2024) | MFL001 (granted 29 September 1975, p. 23). Permitted species: a mix, p. 5 | No copy at MI office: 980543, 950656, 060822, 080726, 001268, 090002, 021247 (exp. 7 May 2021). |
| U200301 (granted 15 October 2020, p. 10). Replaces part of U021247 (enables subsurface anchoring structures, p. 1) |
|||
| Pelorus Sound/Te Hoiere | |||
| 3. Crail Bay (seaweed, NZKS FY23, p. 20) (one farm) | 8513 (exp. 2024) | U090660 (granted 9 July 2010, p. 8). Permitted species: king salmon, p. 4 (note this and U090634 below are in the same decision) | No related resource consents |
| MFL048 (granted 27 June 1978, p. 23). This consent does not allow salmon farming, but is required for U090660 to operate, see pp. 4, 39 of U090660) | No related resource consents | ||
| U130743 (granted 4 April 2014, p. 20) (enables a feed barge, p. 2) | No related resource consents | ||
| 4. Crail Bay (fallowed) (one farm) | 8515 (exp. 2024) | U090634 (NZKS) (granted 9 July 2010, p. 8). Permitted species: king salmon, p. 3. (note this and U090660 above are in the same decision) | No related resource consents |
| MFL032 (Crail Bay Trust) (granted 18 May 1977, p. 24). This consent does not allow salmon farming, but is required for U090634 to operate, see pp. 3, 30 of U090634. Permitted species: a mix, p. 11 | No related resource consents | ||
| 5. Forsyth Bay (fallowed) (one farm) | 8110 (exp. 2024) | U040412 (granted 4 May 2005, p. 3). Permitted species: a mix, p. 17 | No copy at MI office: 950523, 980454, 060822, 080726, 130789, 180278, 090002. |
| MFL239 (granted 30 June 1982, p. 14). Permitted species: a mix, p. 3 | |||
| 6. Kopāua/Richmond (fallowed) (new, one farm) | 8633 (exp. 2049) | U140295 (granted 14 March 2013, p. 68). Permitted species: king salmon, p. 73 | No copy at MI office: 170579. |
| 7. Waihinau Bay (fallowed) (one farm) | 8085 (exp. 2024) | MFL456 (granted 24 April 1991, p. 20). Permitted species: a mix, p. 3 | Hard copy at MI office: 000956 (exp. 31 Oct 2010). No copy at MI office: 990126, 060822, 080726, 180707, 090002. |
| 8. Waitata (active) (new, one farm) | 8632 (exp. 2049) | U140294 (granted 14 March 2013, p. 149). Permitted species: king salmon, p. 155 | No copy at MI office: 170579, 180735, 180778. |
| Tory Channel/Kura Te Au | |||
| 9. Clay Point (active) (one farm) | 8407 (exp. 2036) | U160675 (granted 9 November 2016, p. 20). Permitted species: king salmon, p. 17 | Hard copy at MI office: 060926. No copy at MI office: 001268, 950655, 060822, 080726, 090002, 080054. |
| 10. Ngāmāhau (active) (new, one farm) | 8634 (exp. 2049) | U140296 (granted 14 March 2013, p. 101). Permitted species: king salmon, p. 107 | Hard copy at MI office: 150355 (mentioned in Appendix 3). |
| 11. Te Pangu (active) (one farm) | 8408 (exp. 2036) | U150081 (granted 26 January 2016, p. 16). Permitted species: king salmon, p. 1 | No copy at MI office: 950654, 010142, 981072, 040813, 060822, 080726, 090841, 100656, 110410, 120226, 130472, 090002. |
| External waters (in Cook Strait) | |||
| 12. Blue Endeavour (two farms) | Not yet designated | U190438 (granted 10 November 2022, p. 120). Permitted species: king salmon, p. 1. Subject to resolution of consent appeal | No related resource consents |