Assessment of Environmental Effects White Horse Rock Resource Consent Application
THE NEW ZEALAND KING SALMON COMPANY LIMITED
PREPARED BY BOFFA MISKELL LIMITED | OCTOBER 2011
CONTENTS
1.0 Introduction ...... 1
2.0 Rationale for Proposal ...... 4
3.0 The Proposal ...... 5 3.1 Introduction ...... 5 3.2 Resource Consent ...... 5 3.3 Design and Layout ...... 7 3.3.1 Introduction ...... 7 3.3.2 Cages, Fences and Netting ...... 8 3.3.3 Mooring Systems ...... 8 3.3.4 The Main Barge ...... 9 3.3.5 Lighting ...... 9 3.4 Operation ...... 10 3.4.1 Getting Salmon to the Farms ...... 10 3.4.2 Growing the Salmon ...... 10 3.4.3 Harvesting ...... 13 3.4.4 Vessels ...... 13 3.4.5 Land Based Infrastructure ...... 14 3.5 Discharges to Coastal Water and to Air ...... 14 3.6 Taking and Use of Coastal Water ...... 15 3.7 Environmental Management ...... 15
4.0 Site Selection ...... 17
5.0 Description of the Existing Environment ...... 18 5.1 Introduction ...... 18 5.2 General Marlborough Sounds Environment ...... 18 5.3 Existing Environment of the Proposed White Horse Rock Farm ...... 19 5.3.1 Landscape Setting ...... 19 5.3.2 Marine Environment ...... 20 5.3.3 Summary of Existing Environment of the Proposed White Horse Rock Farm ...... 21
6.0 Assessment of Environmental Effects ...... 24 6.1 Introduction ...... 24 6.2 Environmental Effects ...... 24 6.2.1 Economic Effects ...... 24 6.2.2 Iwi Cultural Effects ...... 25 6.2.3 Effects on the Water Column ...... 25 6.2.4 Effects on the Seabed ...... 26 6.2.5 Effects on Pelagic Fish ...... 30 6.2.6 Effects on Marine Mammals ...... 30 6.2.7 Effects on Seabirds ...... 30
6.2.8 Biosecurity Effects ...... 31 6.2.9 Effects from Disease Risk ...... 31 6.2.10 Effects on Terrestrial Ecology ...... 31 6.2.11 Natural Character, Landscape and Visual Amenity Effects ...... 31 6.2.12 Noise Effects ...... 32 6.2.13 Effects on Historic Heritage ...... 34 6.2.14 Effects on Tourism and Recreation ...... 34 6.2.15 Structural Safety ...... 35 6.2.16 Effects on Navigation ...... 35 6.2.17 Discharges to Coastal Water and Air ...... 36
7.0 Mitigation and Monitoring ...... 37
8.0 Consultation ...... 45
1.0 INTRODUCTION
This resource consent application for a salmon farm at White Horse Rock in Waitata Reach, Outer Pelorus Sound, accompanies separate applications for a plan change and concurrent resource consents lodged with the Environmental Protection Authority (EPA) for eight new salmon farms in the Marlborough Sounds (the Sounds). It is intended that this additional application for a salmon farm at the White Horse Rock site be heard together with the applications for the plan change and the other eight resource consents.
The New Zealand King Salmon Co. Limited (NZ King Salmon) is New Zealand’s largest salmon producer. The company, and its predecessor companies, have been growing King Salmon in New Zealand since the mid-1980s. NZ King Salmon currently produces approximately 8,900 tonnes of salmon per annum. It proposes to significantly increase its production, in order to meet rapidly increasing export and domestic demand, by developing new salmon farms in the Sounds. This will have substantial direct and flow on effects for the economies of Marlborough, Nelson, Tasman, and nationally, thereby supporting the economic and social wellbeing of the community.
Although NZ King Salmon is a very small player on the international salmon scene (0.4% of total global salmon production), its represents more than half of the world’s production of King Salmon (sometimes referred to as Chinook Salmon). Currently, approximately 50% of the salmon produced by NZ King Salmon is exported. It has an annual turnover well in excess of $100 million and currently employs 468 staff.
NZ King Salmon has developed into a vertically integrated company, maintaining control of its production from hatchery to marketing and sales of processed product. It operates three hatcheries, eight salmon farms, four processing plants, and associated offices, depots and servicing facilities.
The existing salmon farms are all located in the Sounds (Ruakaka Bay, Forsyth Bay, Waihinau, Otanerau, Te Pangu, Clay Point, and two small farms recently purchased in Crail Bay). Two further potential salmon farms have been granted consent by the Council, but are currently under appeal. These are located at White Horse Rock, Waitata Reach1, and Melville Cove, Port Gore.
The hatcheries, which supply the salmon farms, are located in Takaka, Tentburn in mid-Canterbury, and Waiau in north-Canterbury. The four factories that process the harvested salmon are located at Tahunanui, Nelson. The company currently has sales and marketing staff based in Auckland, Sydney, San Francisco and Tokyo (with a depot and processing facility also located in Sydney).
NZ King Salmon has applied to the Environmental Protection Authority (EPA) for a private plan change to the Marlborough Sounds Resource Management Plan (MSRMP), and associated resource consents for eight more farms in the Sounds at the following locations:
Site No. Site Name Location 1 Waitata Waitata Reach, Pelorus Sound 2 Kaitira Waitata Reach, Pelorus Sound 3 Tapipi Waitata Reach, Pelorus Sound 4 Richmond Waitata Reach, Pelorus Sound 5 Papatua Pig Bay, Port Gore 6 Kaitapeha Entrance to Tory Channel from Queen Charlotte Sound 7 Ruaomoko Entrance to Tory Channel from Queen Charlotte Sound 8 Ngamahau Tory Channel
1 An application for a salmon farm at White Horse Rock was granted consent by the Marlborough District Council, but that consent is currently under appeal to the Environment Court. A salmon farm at this same site is also the subject of this resource consent application to the EPA (and addressed in this AEE). This application is intended to be considered together with the separate plan change and resource consent applications lodged with the EPA.
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NZ King Salmon is also applying for resource consent to establish a salmon farm and undertake salmon farming at a ninth farm located in the vicinity of White Horse Rock, in the Waitata Reach of Pelorus Sound. It would be inshore of, and immediately adjacent to, the proposed Waitata plan change and resource consent site. The location of the proposed White Horse Rock salmon farm is shown on the maps in Appendix 1.
This Assessment of Environmental Effects (AEE) has been prepared to specifically support the resource consent application for the White Horse Rock site.
The White Horse Rock site is located within the Coastal Marine Zone 2 (CMZ2) under the MSRMP (as shown on the plan in Appendix 1). Unlike the other eight proposed salmon farms, the site does not first require a plan change to enable the establishment of a salmon farm and salmon farming. Under the rules that apply to the CMZ2, a resource consent is required to operate the proposed farm (as a Discretionary Activity under Rule 35.4) provided that the farm is located no closer than 50m to, and no further than 200m from, mean low water mark. The site for the proposed White Horse Rock salmon farm meets the requirements of this Rule and, accordingly, this application is made as a Discretionary Activity.
The White Horse Rock proposal relates to a site over which there is an existing mussel farm consent. Prior to the recent changes to the aquaculture legislation, that site was a deemed aquaculture management area (AMA). NZ King Salmon applied in 2008 to the Marlborough District Council for resource consent to farm salmon at this site. The consent was granted, but appealed to the Environment Court where a jurisdictional point relating to the status of the deemed AMA meant the merits of the appeal were not decided. That Environment Court decision was subsequently appealed to the High Court. That appeal has not yet been heard. The Aquaculture Reform (Repeals and Transitional Provisions) Amendment Act 2011 (part of the recent aquaculture reforms) has changed the law regarding the status of deemed AMAs. This will mean that the issue will be referred back to the Environment Court for determination. However, the complexities in the history of the application and uncertainty as to how the new law will operate in practice has lead to NZ King Salmon deciding to make the White Horse Rock site part of its Sustainably Growing King Salmon proposal and, in doing so, apply to the EPA for a resource consent under the new legislation under which AMAs do not exist.
NZ King Salmon’s market is evenly split between New Zealand and overseas. It sells a premium product and the demand is steadily increasing both in New Zealand and in the overseas markets. The existing farms have reached their production capacity and so this application, along with the plan change and other resource consent applications, would meet this continuing increase in market demand.
One of the strengths of NZ King Salmon from a market perspective is its ability to produce fish year round that are consistent in quality and size. Recognition of the various attributes of each of the farm sites, and managing these sites in conjunction with one another is an important aspect that contributes to the company’s ability to achieve consistent production. The additional marine farming space, including this proposed salmon farm at White Horse Rock, would enable NZ King Salmon to better integrate its operation as a whole by spreading production across a larger number of the sites according to their water current flows and temperature/depth profiles.
The separate AEE prepared to support the plan change and resource consent applications for the other eight salmon farms (the main AEE) comprehensively describes and assesses the effects of each of those farms within the Sounds environment. Much of that assessment can also be applied to the proposed White Horse Rock salmon farm, where the type of effects assessed are generic to all salmon farms or where the effects would be the same as for the adjacent proposed Waitata site. Accordingly, rather than reiterate the assessment contained in the main AEE, this AEE for the White Horse Rock farm makes use of the main assessment and cross references to it extensively.
Similarly, there are a large number of very detailed reports that support the main AEE. These can also be applied to this White Horse Rock AEE. This includes a report from NZ King Salmon (Appendix 2 of the main AEE) which provides background information regarding the applicant company and an overview of its operations. There are 20 specialist assessment reports appended to the main AEE,
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ranging from assessments of effects on the physical and biological environment through to economic effects for the community.
Additional technical reports have also been commissioned to specifically support this White Horse Rock AEE. These reports address effects which are site specific or not otherwise covered by the reports supporting the other eight sites. These include the following reports, which are attached in full to this summary AEE document:
Appendix 1 Maps and Plans
Appendix 2 Site Deposition and Benthic Effects Report (prepared by Cawthron Institute)
Appendix 3 Landscape Report (prepared by Boffa Miskell Ltd)
Appendix 4 Noise Report (prepared by Marshall Day Acoustics)
Appendix 5 Structural Engineering Report (prepared by OCEL Consultants NZ Ltd)
The primary purpose of this White Horse Rock AEE is to provide a “road-map” to these various reports. It briefly summarises the findings found in those reports and points to areas of detailed assessment where considered necessary. This AEE, its supporting reports and the material in the main AEE, also address the relevant assessment criteria for marine farms in the CMZ2 as set out in Rule 35.4 of the MSRMP.
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2.0 RATIONALE FOR PROPOSAL
Chapter 2.0 of the main AEE for the other eight sites comprehensively discusses the rationale for NZ King Salmon’s proposed salmon farm expansion. That discussion also equally applies to the proposed White Horse Rock site and is therefore not repeated fully here. However in summary it identifies:
• There is an increasing global demand for quality fish protein, which is expected to be met by additional aquaculture production;
• The Food and Agriculture Organisation of the United Nations (FAO) anticipates that, by 2020, 18 million tonnes of extra seafood will be required to maintain current global consumption (40 million tonnes by 2030);
• In the global market, growth of salmon consumption has been rapid and is likely to continue;
• New Zealand is the largest supplier of farmed King Salmon, which currently commands a premium price well above the price for more common Atlantic salmon. NZ King Salmon itself produces well in excess of 50% of the total farmed King Salmon sold globally;
• A key focus for NZ King Salmon is to continue to strengthen and grow its existing four strong markets. King Salmon is also about to diversify some risk by operating in multiple markets;
• NZ King Salmon’s growth is largely being driven by global demand or ‘pull’, rather than product ‘push’. Demand for NZ King Salmon’s premium product is steadily increasing, and existing farms have reached their production capacity. As a result, supply constraints have become an issue;
• Additional farms will enable NZ King Salmon to remain market led and focused, with the ability to supply the fish and portion sizes all year round, on-demand. New water space would also enable NZ King Salmon to further minimise the environmental footprint of its salmon farming and manage biosecurity risks by spreading production across the sites;
• Aquaculture has been identified as a priority growth sector by successive governments, with a current goal of becoming a $1 billion industry by 20252;
• If NZ King Salmon is unable to take advantage of the current consumer demand, the opportunity will be lost to international competitors reducing not only revenue gains to NZ King Salmon, but also significantly impacting on national and regional economic benefit.
2 The New Zealand Aquaculture Strategy, 2006.
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3.0 THE PROPOSAL
3.1 Introduction
NZ King Salmon seeks resource consent to establish a salmon farm and undertake salmon farming, at the 2.2 ha White Horse Rock site, located within the Waitata Reach of Pelorus Sound.
The proposed White Horse Rock site is zoned as CMZ2 in the Marlborough Sounds Resource Management Plan (MSRMP) and shown on the plans contained in Appendix 1. It is to be located adjacent to the proposed Waitata site which is proposed to be zoned as CMZ3 zone through NZ King Salmon’s plan change application.
This application has been made concurrently with the eight separate applications for new salmon farms within a proposed CMZ3 zone as sought through NZ King Salmon’s concurrent plan change and resource consent applications. Accordingly it is expected that it will be considered concurrently with the plan change and resource consent applications for the other eight sites.
The proposed design, layout and operation of the proposed farm are described in Sections 3.3 – 3.6 of this Chapter. Many facets of the operation will be the same as those for the other farms although a degree of operational flexibility is needed so as to respond to any local conditions and to respond to demands from the wider operation. For example, some sites will be harvested or stocked at different times and rates depending on the local conditions and the conditions of the other sites. As noted in Chapter 1.0, the intention is to treat the operation as an integrated whole.
NZ King Salmon has operated its existing farms over many years and the proposed design, layout and operation of the proposed farm is a reflection of that experience. In saying that, it is expected that all farms will continue to evolve and be refined. Further discussion of the history and evolution of the existing operation that has lead to the current proposal is found in the NZ King Salmon Report attached as Appendix 2 to the main AEE.
3.2 Resource Consent
The resource consent application for the White Horse Rock site largely mirrors those for the other eight proposed sites, albeit with some differences taking into account the physical and environmental constraints of its location, and recognising its co-location with the adjacent proposed Waitata site.
The following activities are proposed to be undertaken at the 2.2 ha White Horse Rock site (as shown on the plans attached to this AEE in Appendix 1). Further details of the proposed design, layout and operation of the farm are described in Sections 3.3 – 3.6 below. a. The development of a salmon farm and the undertaking of all activities associated with salmon farming. In general terms, consent is sought for the following activities:
(i) All structures, activities in the coastal marine area, occupation of the common marine and coastal area, disturbance of or damage to the foreshore or seabed, deposition on the foreshore or seabed, and other ancillary activities and structures, associated with a salmon farm and salmon farming; (ii) All discharges to water or air associated with a salmon farm and salmon farming, but excluding the discharge of human sewage; (iii) The taking and use of coastal water associated with a salmon farm and salmon farming.
While all the above activities associated with the salmon farm and salmon farming will occur within the 2.2 ha site, some effects arising from the activities may be experienced beyond the
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boundary of the site. For example, the salmon farm will be able to be seen and heard from beyond the boundary of the site, and some waste material will travel beyond the boundary of the site. b. A range of other activities are currently permitted in the CMZ2, provided Standards are complied with, and these will also be undertaken at the proposed White Horse Rock salmon farm, including:
• Navigation aids and beacons; • Public information signs; • Monitoring; • Recreational activity; • Stormwater discharge; • Taking and discharge of coastal water; • Use of surface water by ships and other vessels; • Navigation and mooring by ships c. All salmon reared will be from roe sourced in New Zealand. d. A term of 35 years will be sought for the resource consent. e. A maximum of 0.5 ha of salmon cages on the site, other than temporary cages for transferring salmon to or from the site. f. A proposed farm layout plan for the site is contained in Appendix 1. This show the location and layout of the cages and the location of the building/barge relative to the cages. Engineering details for the anchoring systems securing the cages and barge to the seafloor are provided in the Structural Engineering Report (Appendix 5). g. There will be progressive development of the site over time. The first cages will be started from a nominated boundary within the consented area and some cages will always remain against that boundary (i.e. the number of cages at the site will expand and/or contract from the other end of the row of cages). h. Salmon cages will be steel framed cages (30m x 30m), similar to those currently located on NZ King Salmon’s Te Pangu and Clay Point farms. i. There will be one building (on a floating barge), with a maximum footprint of 280m2 and maximum height of 7.5m. If both the White Horse Rock and Waitata salmon farms are developed, it is intended that there will be one shared barge between these farms, located either at White Horse Rock or Waitata. j. The following colours are specified for the cages, netting, the building and other structures:
• Karaka green or similar dark colour for the building and all features (such as drain pipes) on the building; • Dark recessive colours for all exterior, above-water metal structures (other than the surface of walkways) associated with the fish cages structures; • Black or dark coloured above-water netting; • Curtains to be provided in the accommodation building windows and which are to be a dark coloured fabric. k. Staged incremental feed discharge levels (in tonnes per annum) are specified in Table 3.1 below. Subject to the outcomes of monitoring, the feed discharge and associated salmon production levels will be progressively increased up to the maximum feed discharge level specified. However, achievement of the maximum feed discharge level will be dependent on ongoing achievement of the environmental standards.
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Table 3.1: Initial and maximum annual feed discharges, and incremental feed discharge steps
Maximum Feed Discharge Initial Feed Discharge Incremental Feed Discharge (tonnes per annum) (tonnes per annum) Steps (tonnes per annum)
1200# 500 3000# # Except that for this White Horse Rock site and an adjoining salmon farm at the Waitata plan change site: • the combined initial annual feed discharge shall be 4000 tonnes; and • the combined maximum annual feed discharge shall be 8000 tonnes. l. Monitoring requirements and timeframes for assessing the performance of the farm against environmental standards relating to benthic deposition effects are set out in Chapter 7.0 of this AEE. The staged increases in the scale of feed discharges for the farm will be linked to the ongoing monitoring of the effects of each stage against the environmental standards. m. Navigational lights and other warning devices are specified in the Navigation Report (Appendix 19 of the main AEE). These are consistent with those currently provided on NZ King Salmon’s existing farms, but are subject to the separate approval of the Council’s Harbourmaster. n. Management measures for the management of seabirds, marine mammals, biosecurity, disease risks and other effects are set out in Chapter 7.0 of this AEE.
3.3 Design and Layout
3.3.1 Introduction
The site will accommodate the following: a. A series of rectangular steel cages to hold the salmon; b. Floating steel structures supporting the grower and predator nets, with associated walkways to allow access to each cage (around, and sometimes over, the cages); c. Netting and fencing – these include the grower nets in the cages, bird netting over the top of the cages, and predator exclusion nets and barriers around the perimeter and underneath each site; d. Moorings and screw anchors – these extend well beyond the extent of the surface facilities, but will be contained within 2.2 ha consent area; e. A 280m2 building on a barge that provides accommodation for shift staff as well as offices, feed storage and workshop facilities – the two-storey barge will not exceed 7.5m in height. (There will however only be one barge shared between the White Horse Rock and Waitata sites should both sites be developed); f. A small transportable mortalities container – a sealed container located on a small floating platform generally attached to the farm to contain dead fish collected on an ongoing basis; and g. Temporary service barges and other transient structures, such as floating platforms, that may be required from time to time. This includes a harvest barge –generally a dumb barge that sits alongside the farm for the duration of the harvests scheduled for that farm. It has a forklift and hydraulic crane and stores harvest bins.
The site will also have navigational lighting, barge lighting; and underwater lighting for controlling fish growth and maturation.
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Proposed farm layout plan is contained in Appendix 1. Photographs of NZ King Salmon’s existing farms are included NZ King Salmon’s Report in Appendix 2 of the main AEE. These show the cages and associated bird and predator nets, as well as the building on a floating barge.
Details of the feed discharge strategy for the site are contained in the Site Deposition and Benthic Effects Report attached as Appendix 2 to this AEE.
3.3.2 Cages, Fences and Netting
The proposed steel sea cages will comprise a floating structure which consists of a perimeter of spirally welded steel pipe that is divided into sections, or individual cages, using the same steel pipe. Typically the steel cages will have a walkway attached to the top of the cage structure, with associated handrails attached to the walkway. It is possible that suspended walkways across the centre of the cages could be installed. Nets are attached to each cage structure to enclose an area of sea for the salmon to live in. These are called grower nets. The grower nets are suspended down some 20m from the tubular pipes. The nets are made of nylon and the diamond shaped mesh varies from 12.5mm to 35mm across in size. In order to contain smolt when they are first introduced, a smaller mesh size is used and as fish grow they are transfer fish to a grower net with a larger mesh size. The variable mesh sizes are designed to be small enough to keep the salmon contained, but large enough to allow adequate water flow to replenish dissolved oxygen levels in the cage and flush waste from the cages. The grower nets are cleaned frequently and changed as required. As for the existing farms, a combination nylon/polyethylene netting is proposed to surround a whole farm structure to prevent, as far as possible, seals and sharks from preying on the salmon. This netting has a mesh size ranging from 100-120mm. The nets would extend up to approximately 2m above the water line around the perimeter of the cages as shown in the photographs in Appendix 2 of the main AEE. The nets are tensioned off the mooring anchors to prevent the seals pressing against the net containing the salmon. The underwater predator netting is proposed to be treated with copper-based antifouling paint that, together with cleaning, ensures fouling does not restrict the flow of water through the grower nets. Notwithstanding this however, NZ King Salmon is currently undertaking trials at several of its existing salmon farms, as part of its strategy of working towards reducing, and ultimately discontinuing, the use of copper based antifouling on its predator nets wherever possible. Predator nets are considered the most effective method of excluding seals and other predators, and they have the added advantage of distancing the fish from the predators, thereby reducing stress in the fish. Each salmon cage is also proposed to be covered by a bird net, which acts to prevent seabirds, particularly gannets, from diving for the farmed fish. The proposed nets are black polyethylene and while generally effective, birds are still observed over the farm. Previous investigation work has shown a 47.5mm mesh size is most effective. 3.3.3 Mooring Systems
The proposed farm layout plan in Appendix 1 shows a series of mooring ropes connecting to screw anchors that are hydraulically driven into the seabed. These anchors consist of an approximately 800mm diameter steel auger which has an anchor plate. Additional details of the anchoring systems are contained in the Structural Engineering Report in Appendix 5. The proposed mooring ropes are made of polypropylene. They will be typically 40mm in diameter and will connect the anchors to the chains, which in turn connect to shackles on the cages. The chain enables the line length to be adjusted to the appropriate tension depending on the strength of the current. The anchors need to be located a sufficient distance from the structures so the mooring ropes can provide adequate tension to hold the farm securely in place. This is the reason why salmon farm consents are typically for an area much greater than the area covered by the surface structures alone.
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3.3.4 The Main Barge
The main barge will provide an accommodation building for shift staff, offices, feed storage and workshop facilities. The main barge is proposed to be located on the off-shore side of the proposed salmon cages, as shown on the farm layout plan in Appendix 1. It will be secured with its own mooring lines and anchors on the off-shore side, but also attached directly to the cage structure so that staff can move readily between the barge and the cage structure.
A proposed typical barge holds a floating two-storey building that is approximately 280m2 in size: a photograph of an existing barge is included in the NZ King Salmon Report in Appendix 2 of the main AEE. The lower floor houses a large feed storage area, feeding equipment, workshop, freshwater holder tank, shower, diesel storage and a generator room. The upper level houses staff accommodation and offices. The staff accommodation includes a staff kitchen area, shift worker bedrooms, a shower and a toilet. The office includes an area to monitor the feeding of the salmon.
Rainwater from the roof of the building and from other structures runs directly off into the sea.
Freshwater will be delivered to the holding tanks on the barge via a tank, carried by a barge to the farm.
Grey water is proposed to be discharged directly into the sea and this will not exceed 500m3 per day. Grey water is the water that is discharged after the use of showers and basins, or from the kitchen and laundry areas. Further details regarding the proposed greywater discharge are contained in the Greywater Report in Appendix 22 to the main AEE.
Black water, or sewage, is contained in tanks on site, and will be regularly collected and removed from the site via a commercial barge.
As discussed previously, the White Horse Rock site is proposed to share a single barge with the adjacent proposed Waitata site, should salmon farms be developed at both sites.
3.3.5 Lighting
Three forms of lighting are proposed for the salmon farm, as follows: a. Navigation lights for safety purposes; b. Internal lights in the building barge for staff and floodlight on the barge exterior to enable staff to enter the cage area safely at night if required; and c. Underwater lighting in the cages to manage the maturation of the salmon.
These are discussed in turn.
The navigation lights are subject to the separate approval of the Council’s Harbourmaster under the Maritime Transport Act 1994. However, subject to his approval, the navigational lighting is proposed to be designed in the same way as for the existing farms. There will be six lights. Four of them will be located on the four corners of the cage structure and two in the centres of the longest side of the cage structure. The lights are to be higher than one metre above the surface of the water.
The lights are to be coloured yellow and will flash five times every 20 seconds with the interval between the flashes being no more than one second. The length of each flash is also to be no more than one second. It is proposed to synchronise the flashing of the navigation lights both within each farm and also between those nearby farms.
The lights are to be solar powered and are designed to have a visible range of at least one nautical mile.
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The floating building barge will contain standard internal lights, similar to a dwelling. The exterior floodlight would only be switched on when staff need to enter the cage area at night. When required by the Harbourmaster, the barge will have navigation lighting installed to the standard required by the Marine Transport Act 1994.
Underwater lighting is presently used in the salmon cages at the existing Clay Point and at Te Pangu salmon farms. The use of underwater lighting is common practice in salmon farming overseas because it increases production and also reduces the risk of maturation of the salmon prior to harvest. Salmon that mature prior to harvesting have no market value.
Research is also indicating that the placement of lights at depth, instead of at the surface, also assists in distributing the fish throughout the cage which therefore reduces the potential for crowding and associated stress on the salmon.
Currently at Clay Point an array of 1000 watt halogen bulbs are suspended either in a circular pattern or along two parallel lines in the 30m x 30m cages. On-going trialing is occurring as to the most effective depth and configuration of the lighting.
3.4 Operation
3.4.1 Getting Salmon to the Farms
The salmon farms receive young salmon from the hatcheries during spring and autumn. They arrive as ‘smolt’. This is the stage where the young salmon are physiologically able to adapt to seawater and would naturally first begin their migration from fresh water to the sea.
The smolt are transferred to a custom-made truck and trailer unit and transported to Picton or Havelock. The truck and trailer units are then loaded onto a barge and taken to the farms. During this journey salt water is added to the tanks to help the smolt acclimatise to the seawater. Once the truck and trailer units arrive at the farm the smolt are discharged directly into the seawater.
The breeding programme produces salmon that have different growth rates and different times when they reach maturity.3 To ensure a year round supply of salmon to the market, the final farm destination for the smolt will be dependent on its growth strategies along with the environmental characteristics of each farm site.
3.4.2 Growing the Salmon
The length of time the salmon stay in the cages is dependent on their breeding history (genetics) and sea temperature, however, on average a fish will remain in cage for about 1½ to two years before being harvested.
King Salmon are naturally shoaling fish and therefore being contained in a sea cage is not contrary to their natural instinct. The stocking rates used are up to approximately 2.5% of the cage by volume.
Feeding Salmon
The key activity carried out at each farm is the feeding of salmon. The objective is to maximise the growth rate of the salmon while minimising feed wastage. NZ King Salmon uses the principle of satiation feeding to ensure that fish are fed an amount that matches their appetite, which varies throughout the salmon life cycle.
3 Salmon have no market value once they mature: they are therefore harvested when they are still immature.
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There are two parts to the feeding system: the feed delivery equipment and the feed monitoring equipment which monitors pellet wastage.
Feed pellets are delivered to the farm in large bags and stored in the barge until required. During feeding the bags are emptied into a hopper or feed silo and the feed is either delivered to the cages via a mobile hopper, called the spinner system, or alternatively propelled from the feed silos in the barge through pipes by air to the individual cages, called the Akva system.
The spinner system is the older of the two systems used. It is used at the lower current sites and feed is delivered to the spinners via the transportable hoppers. Pellets are fed into the system from a hopper suspended above each cage; the pellets fall into a motorised spinning disc that spins them out via a restriction plate over a wide area of the cage. Feeding rate is monitored by one of the following methods: a. An underwater video-camera placed in the water under the feed drift zone,4 which is connected to a television monitor in the office and is watched constantly during feeding to enable the feed rate to be adjusted based on the number of pellets drifting past the camera; or b. The AkvaSmart AQ1 computer-based feeding system whereby a computer programme regulates the rate and quantity of feed delivered to the fish based on feedback from an underwater sensor that counts waste pellets.
The more modern Akva system, which is likely to be used for the proposed farm, transports the feed to the cage via a plastic HDPE pipe using airflow and is then spread around using a roto-spreader attached at the end of the feed pipe. The rate and quantity of feed delivered to the cages is controlled using the AkvaSmart computer programme.
The feed will be moved to the farm by vessel. A crane and forklift is to be used to transfer the feed from the vessel to the barge at the site. The barge is enclosed so that the feed is stored where spillage cannot directly enter the sea.
The minimisation of waste feed is both a commercial and environmental objective of NZ King Salmon. This includes continual evolution of feeding strategies with better understanding leading to reduced wastes. Recent initiatives includes greater monitoring cages during feeding, improved feed delivery, and regular checking of delivery systems. NZ King Salmon has recently carried out initial experiments to measure feed loss at two of its farms using exiting feeding equipment. These showed very low levels of feed loss. NIWA, an independent science provider, has recently been commissioned to carry out feed loss monitoring at these farm sites.
Feed Used
Salmon are obligatory carnivorous fish, and as such the primary requirements for a salmon diet are protein and fat. Salmon cannot properly metabolise carbohydrate.
The pellets used by NZ King Salmon contain a mix of fish meal, land animal proteins and vegetable proteins as well as carbohydrate.
Earlier, fish meal was the predominant protein fed to salmon but in more recent years this has been steadily decreased so it now only constitutes approximately 10% of its protein intake. Instead protein is derived from mainly poultry or from sheep and cattle.
The source of carbohydrate in fish feed is typically Australian wheat, lupin, faba bean, or a soy protein concentrate. Carbohydrate is primarily used to bind the pellet together and has little nutritive value for the fish.
4 Salmon feed to a depth of at least 7-10m, which means their feeding behaviour is difficult to monitor from the surface.
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Astaxanthin is also added to the diet. It is required for fish health and is an anti-oxidant which gives salmon its pink colour. The particular form of astaxanthin used in fish feed is synthesised chemically, rather than being derived from prey but is identical to that which exists in nature. Zinc, an essential micro-nutrient in salmon diets, is included in the feed. NZ King Salmon proposes to use organic zinc in the salmon feed at all its salmon farms.
A significant number of vitamins and minerals are required to keep the fish healthy. These additives are less than 1% of the total feed, by weight.
The feed used by NZ King Salmon does not contain genetically modified organisms. Antibiotics are also not currently included in feed supplied to the New Zealand salmon industry, due to the absence from New Zealand coastal waters of the most important diseases that can affect salmon. Similarly, there is no need for lice treatments to be supplied by feed and such treatments have never been used in New Zealand. This is an enviable situation for New Zealand at the moment, but may not always be the case. In the future, if the need arose as a result of problems with fish health, antibiotics, lice treatments or other animal remedies may need to be added to the feed. This would need to be under the instructions of a veterinarian and would be managed under the Agricultural Compounds and Veterinary Medicines Act 1997, and the Hazardous Substances and New Organisms (HSNO) Act 1996, as required. The addition of antibiotics, lice treatments or other animal remedies does not form part of these current applications and, if ever required, any necessary resource consents would be obtained at the time.
Research into the feed type and the method of feeding is on-going. Over the past 20 years the feed conversion ratio has decreased from approximately 2.5 in 1990 to 1.8 in 2011. This means less feed ends up as excreted faeces. Recent work estimated that, for the type of feed currently used by NZ King Salmon, approximately 20% of the dry matter consumed is excreted as faeces.
Salmon Mortality
Salmon that die in the sea cages are known as “morts”. The deaths occur for a number of reasons, such as maturation, lesions from poor handling, predator damage, congenital defects, disease, runting or natural attrition.
As for the existing farms, the morts will be retrieved from the bottom of the cages by divers at least twice a week or by running an air lift which creates air flow and sucks the fish to the top of the net where they can by collected. The collected morts are counted and classified according to cause of death.
Removing the morts regularly reduces predator attraction and reduces the spread of any disease from morts to the living salmon. The morts are placed in a sealed storage unit and are regularly collected by one of the service vessels and disposed of at the landfill in Blenheim.
Maintenance Work
There is on-going maintenance work required at the farms. The grower nets need to be cleaned approximately once a month. Otherwise algae, barnacles, tubeworms and mussels will begin to clog the nets and reduce water flow, which in turn reduces the dissolved oxygen in the water and increases waste levels in the cages.5
The grower nets at newer farms are cleaned in-situ by using high pressure coastal water directed through rotating discs. A ‘head’ which contains the discs slides up and down the sides of the net and blasts off the fouling organisms. The other alternative is to manually clean the nets. This is still done at some of the older farms but means no fish can be left in the cage. The nets are lifted above the
5 The fouling organisms also weigh the nets down, which makes them not only difficult to handle but also places additional strain on the mooring structures and cause wear and tear on the equipment, cage structures and the net mesh.
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water, spread-out, and walked over and water-blasted clean. Nets are then left to dry to ensure that all fouling organisms have died.
The predator nets are to be coated in a copper-based antifouling paint. This means less frequent cleaning is required for the nets because the copper discourages the settlement and attachment of many encrusting organisms.
The predator nets are normally brought to the surface. When brought to the surface they nets are subjected to a mussel crusher to remove many of the encrusting organisms, and then taken to the land-based facility to dry out and to remove the remaining organisms not earlier crushed. Occasionally, when an unexpected build-up of fouling organisms occurs, predator nets maybe cleaned in the water.
Discharges occur of marine fouling and antifouling paint used to protect the predator net during the cleaning and installation of fish production (grower) nets and predator nets.
3.4.3 Harvesting
A specialist harvesting team of nine staff commute daily on a dedicated vessel to the farm being harvested. The team harvests approximately 50-60 tonne per day, five days a week (Sunday to Thursday). The harvest lasts approximately three months at any given farm. Photographs of the harvesting operations are included in the NZ King Salmon Report in Appendix 2 of the main AEE.
As for the existing farms, a snatch net will be dropped into the cages and the captured salmon guided to a floating pontoon which will be placed in each cage by the harvest team.
Once guided into the pontoon, the fish pass through a number of compartments containing anaesthetic (Aqui-S) to sedate them and then into carbon dioxide saturated-water which kills them. The practice of using carbon dioxide ceased at the end of August 2011. This series of compartments ensures that the fish are anaesthetised prior to death and is designed to make the harvest process as stress-free and humane as possible for the fish.
Once dead, the salmon are lifted by a snatch net onto a table which passes them onto the dumb6 barge moored alongside the farm during harvest operations. The fish are then bled and then loaded into insulated bins filled with ice slurry. Small quantities of coastal water are taken during the harvesting process.
The harvested fish are then collected by a motorised barge and transported back to either Picton or Havelock and trucked to the NZ King Salmon factory for immediate processing.
The newly harvested fish are transported via truck to the main primary processing plant in Nelson. Following processing and packaging, the salmon products are distributed to both domestic and export markets via truck to Christchurch or destinations in the North Island. Some fresh gilled and gutted salmon are air freighted from Nelson direct to Auckland and on to the export markets.
3.4.4 Vessels
A range of vessels will be used to transport staff to and from the proposed farm. All staff operating the vessels undertake appropriate training and all vessels are required to keep logbooks. In addition, any damage, accident or incident that occurs to, or on, the vessels are reported in accordance with NZ King Salmon’s accident and incident reporting procedures.
As discussed earlier a number of other specialist vessels are used during salmon farming operations. These include:
6 A barge that has no propulsion and therefore needs to be towed.
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a. The large barges to transport the truck and trailer units carrying smolt for the farm, the bulk bags of feed, the harvested fish and other large freight; b. Harvesting vessels and the dumb barge used by the harvest team; c. The barges for special activities such as predator net changes; and d. A tugboat or barge used for towing the sea cages between sites. This can happen once or twice a year.
Vessel activity varies seasonally, with the main activity being: a. During harvest (which lasts approximately three months at any given farm), the harvest barge and harvest crew vessel commute daily from Sunday to Thursday, with the ‘dumb’ barge remaining alongside the farm for the duration of the harvest. b. Commuter vessels travel to and from the farms Monday to Friday. c. Barges transporting food, and carrying out other logistical work (e.g. net changing, moving equipment etc) usually travel to the farms twice a week. d. Tugs and barges are utilised to move sea pens/fish once or twice a year. e. Vessels carrying customers, television crews and other one-off visitors.
3.4.5 Land Based Infrastructure
NZ King Salmon has a wide range of land-based infrastructure requirements to support the farming operations. No changes to land-based infrastructure are proposed as part of this application.
NZ King Salmon only utilises the ports of Havelock and Picton to support its sea farming operations. The Havelock and Picton facilities are well placed to support marine farming operations, providing landing facilities, barge services, light engineering and utility services, vessel repair and maintenance services and dive industry services.
NZ King Salmon’s factories in Nelson currently take all of the company’s processing. However, if the proposed farms are developed and production increased markedly, it is likely that NZ King Salmon will develop a processing factory closer to its Sounds’ farms.
Currently all NZ King Salmon’s salmon feed is imported. However, the feed companies have indicated that the increase in production resulting from development of the proposed sites would provide the opportunity for the construction of a feed mill in New Zealand.
Air-freight of fresh fish currently occurs from Nelson airport. The development of a processing factory in Marlborough would support the use of Blenheim airport for air freight requirements.
3.5 Discharges to Coastal Water and to Air
The following discharges normally associated with salmon farms and salmon farming and are included in the resource consent proposal for the White Horse Rock salmon farm: a. Salmon farm feed discharged to coastal waters; b. Marine biofouling and antifouling paint discharged to coastal waters; c. Greywater from the accommodation barge discharged to coastal waters; d. Emissions to air from the diesel generator and other diesel- and petrol-powered marine farm equipment; e. Emissions to air generally associated with the salmon farm activity; f. Coastal water taken for cleaning and harvesting operations and discharged back to the sea. Details regarding the nature of these discharges are contained in Section 3.6.1 of the main AEE. Those details also apply to the above discharges proposed at the White Horse Rock site.
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3.6 Taking and Use of Coastal Water
All general cleaning required on the outside areas of the farm uses coastal water taken directly from the sea with high pressure pumps and water blasters. This water is discharged directly back into the sea. During harvesting operations small quantities of coastal water are also taken and used. It is considered that the take and use of coastal water for the proposed salmon farming activities is of such a minimal scale and inconsequential nature that no assessment of the effects of these activities is required. In addition, provided that the volume of coastal water taken and discharged is not more than 500m3 per day, it is provided for as a permitted activity in the CMZ2 under the MSRMP.
Effects from the discharge of marine biofouling associated with the discharge back to the sea of coastal water (as described in Section 3.5 above) are, however, assessed.
3.7 Environmental Management
The initial development of each of NZ King Salmon’s farms is staged, with each incremental stage of development not being permitted unless it can be shown that the farm is operating well within the requirements of its resource consent. The operation and ongoing development of each farm is subject to a rigorous environmental monitoring and reporting programme, which sets the basis for ongoing development and adaptive management of each farm over time.
NZ King Salmon contracts an independent science organisation to prepare an annual monitoring programme, which is approved by Marlborough District Council, prior to the monitoring and data analysis being undertaken. The results of that monitoring are reported annually to the Council through an annual environmental report prepared by the independent science organisation. This report recommends any staged increases in farm development that can be accommodated at any farm (in accordance with resource consent requirements), as well as any adaptive management measures necessary to ensure ongoing compliance.
The same approach to staged development, environmental monitoring, reporting and adaptive management is proposed for the White Horse Rock site. The monitoring, management and other mitigation actions proposed for this resource consent application are outlined in Chapter 7.0 of this AEE.
NZ King Salmon has recently developed an Environmental Policy for Aquaculture Operations. Details of this policy are contained in the report from NZ King Salmon attached as Appendix 2 of the main AEE.
NZ King Salmon has developed a specific Marine Mammal Policy in conjunction with the Department of Conservation (DoC) which includes management actions for minimising the risk of seal entry to the salmon farms, as well as guidelines for the handling of any seals, or other marine mammals, which interact with the salmon farms. NZ King Salmon holds a permit from DoC to take actions to deter seals from entering cages, and to catch and release any seals that do enter a sea cage. This does not include the killing of any seals. The company also records and reports seal and other marine mammal activity around its farms to DoC.
A Seabird Management Policy has also been developed by NZ King Salmon which details the management actions to be taken to minimise the attraction of seabirds to the farms.
NZ King Salmon is in the process of developing a Biosecurity Management Plan (BMP) to address disease risks associated with transfer pathways to their salmon farms and among them. While NZ King Salmon’s current BMP has a focus on the management of disease risk, its scope will be broadened to include marine pests, and consider on-farm as well as pathway-based management measures.
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All diesel and petrol on the farm will be stored and used in accordance with the relevant requirements of the Hazardous Substances and New Organisms (HSNO) Act.
NZ King Salmon has undertaken an assessment of likely risks to farming operations and is currently developing a tsunami and disaster preparedness plan. In addition, the company has emergency response plans in place relating to potential oil spills, toxic algae blooms and jellyfish strikes.
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4.0 SITE SELECTION
The selection of the White Horse Rock site by NZ King Salmon as a potential location for a salmon farm predates the company’s previous resource consent application for the site which remains subject to appeal.
NZ King Salmon was approached directly by the holders of an unimplemented coastal permit (U010272) to farm bivalve and algae species on the site to see if NZ King Salmon may wish to take over the site for salmon farming. This was an attractive proposition for NZ King Salmon who were looking for expansion opportunities. As a result, site investigations were initiated to determine the suitability of the site for salmon farming.
These investigations confirmed the suitability of the site owing to its current CMZ2 zoning, separation from existing houses, suitable water depth, moderate water current flows for dispersal of farm discharges, suitable substratum beneath the site, distance from ecologically sensitive habitats, and proximity to Cook Strait.
An agreement was reached with the consent holder resulting in the transfer of the existing costal permit to NZ King Salmon. This resulted in the subsequent application for resource consent for salmon farming at the site, and which remains subject to appeal.
NZ King Salmon remains convinced as to the suitability of this site for salmon farming and has made the current application on this basis.
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5.0 DESCRIPTION OF THE EXISTING ENVIRONMENT
5.1 Introduction
This Chapter provides a summary description of the existing environment in relation to the proposed White Horse Rock salmon farm. This summary draws heavily on the existing environment description contained in the main AEE, while introducing new information to describe the benthic environment, and natural and landscape character of the proposed site.
5.2 General Marlborough Sounds Environment
Section 5.1 of the main AEE for the other eight sites, extensively describes the physical, biological, community and economic environment of the wider Sounds, including the Waitata Reach of Pelorus Sound. This description is therefore also applicable to the environment of the proposed White Horse Rock site. Rather than repeat that discussion fully here, the following briefly outlines the information contained within that separate AEE and cross references to it.
• Section 5.1.1 of the main AEE describes the existing Sounds marine environment, including:
- Landscape attributes and terrestrial (land-based) flora and fauna;
- Climate, bathymetry, ocean currents and tides;
- Seabed substratum types and related benthic infaunal and epifaunal communities;
- Water column attributes including temperature, salinity, oxygenation, dissolved nutrients and nutrient loading, and related phytoplankton productivity;
- Pelagic fish species present including finfish, sharks, and rays;
- Marine mammals present including seals, killer whales, whales, and dolphins;
- Seabirds present (including the endangered NZ King Shag).
• Section 5.1.2 of the main AEE describes the history of human occupation in the Sounds, including:
- Maori settlement including areas of particular iwi interests;
- European settlement including exploration, whaling, and settlement patterns.
• Section 5.1.3 of the plan change describes the existing Sounds Community and Economy including:
- Key industry sectors, related employment, and relative economic contribution to the region;
- Residential activity and recreational pursuits;
- Tourism activities, numbers, and economic contribution to the region;
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- History of marine farming in the Sounds, current farm distribution, employment, and contribution to the regional economy.
• Section 5.1.4 of the main AEE describes the catchment setting of the Waitata reach in which the proposed White Horse Rock salmon farm is to be located, including:
- Broad description of the reach and its surrounding landscape, including land vegetation cover;
- Location of dwellings, jetties, and existing marine farms;
- Boating traffic;
- Ambient noise levels.
5.3 Existing Environment of the Proposed White Horse Rock Farm
5.3.1 Landscape Setting7
The proposed White Horse Rock farm is to be located on the western side of Waitata Reach, off the headland that separates Waitata Bay and Waihinau Bay. The outermost face of the headland, between Boat Rock Point and Burnt Point, is approximately 1.2 km long. It is an exposed, rocky coast and steep, south-east facing slopes. The headland is not identified as an outstanding natural feature or landscape (ONFL) in the MSRMP.
The proposed site occupies a shallow indentation in the headland adjacent to White Horse Rock. The closest edge of the cage area will be approximately 90m from the shoreline. It is to be located inshore from the proposed Waitata farm subject to the separate plan change and resource consent application.
The vegetation on the slopes adjacent to the site is dominated by manuka on the lower slopes with kanuka becoming more dominant from mid-slope. A range of other native coastal species including mahoe, five-finger, wineberry, rangiora, mamaku and occasional nikau are also emerging through the manuka-kanuka canopy across the site and a few wilding radiata pines are lightly scattered across the steep face.
The site is also close to Boat Rock Point which is a roost used by NZ King Shags8 and identified in the MSRMP.
There are currently no structures in the immediate vicinity of the site. However, consent has been obtained for a mussel farm at this site. This has not been implemented but, if implemented, it would enable 5 longlines, with associated buoys, to be established within a consent area of 2.2ha. The longlines would be placed centrally within the consented area, being longest along the seaward boundary (191 m) reducing to 44.1 m on the inshore boundary. The species intended to be farmed are green shell and blue mussels, scallops and flat oysters. A list of four specified types of algae may also be farmed at the site. The longlines would be spaced at 20 metre intervals and secured by screw anchors. Navigation lights are required by the conditions of consent to be located at each end of the most seaward and landward longlines.
7 For further detail, refer to Section 3 of the Landscape Report in Appendix 3 to this AEE, and Section 4 of the Terrestrial Ecology in Appendix 14 of the main AEE 8 For further detail refer to Section 3.2 of the Seabirds Report in Appendix 10 of the main AEE
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There are also several existing mussel farms in Waitata and Waihinau Bays with the nearest to the site being situated between Rat Point and Boat Rock Point. NZ King Salmon has consent to operate a salmon farm in Waihinau Bay, which it currently operates in conjunction with another consented site in Forsyth Bay. The salmon farm is currently located at the Forsyth Bay site.
The natural character9 of the land adjacent to the site is assessed as high while the natural character of the inshore seascape is considered to be medium due to the existing, but as yet to be implemented, mussel farm consent. Overall, the degree of natural character is considered to be medium-high. The site has been assessed as not fulfilling the criteria that would constitute it being an area of outstanding natural character.
There are numerous marine farms, tracks and dwellings in the bays on either side of the headland (Waihinau and Waitata Bays), but there are no buildings or structures on the headland adjacent the site.
The closest dwellings to the site are in Waihinau Bay and Waitata Bay. Of these dwellings, one property at the southern entrance to Waitata Reach may have elevated oblique views of the proposed White Horse Rock site at 3.2 km (W2)10 . The site is thought to be screened from view from the dwelling by the spur above Reef Point but this would need to be confirmed. The site will be visible from parts of this property, which is operated as a private nature reserve.
There are no formed public roads in the vicinity of the proposed salmon farm site with views to the site. It has been indicated in previous hearings relating to the White Horse Rock salmon farm that a walking track will be, or has been, constructed above the proposed site, extending to the highpoint of the White Horse Rock headland (247masl) above the proposed salmon farm site, and from there in a southerly direction, descending towards Boat Rock Point11. It cannot currently be determined whether this track has been, or will be, constructed.
Much of the boating traffic in Waitata Reach is related to servicing the mussel and salmon farms in outer Pelorus Sound and beyond. There are also recreational boats and resident’s boats accessing their properties, that pass through this area but it does not have the popularity or high level of use for recreational fishing and boating that Queen Charlotte Sound does12.
5.3.2 Marine Environment13
The proposed farm site is considered to be a moderate current-flow site. Average water velocities generally range between 10 to 12 cm s-1 with maximum water velocities ranging from 31 to 51 cm s-1. Current speeds decrease slightly with depth, with the fastest mean current speed near the surface (12 cms-1) and the slowest mean current speed near the seabed (10-11 cms-1). The predominant direction of tidal flow was to the east-northeast, running parallel to the coastline.
The proposed White Horse Rock salmon farm is to be sited in relatively deep water of between approximately 20 and 40m depth. Beyond the site, the seabed slopes relatively steeply down to 55m depth after which it begins to flatten out.
Beneath the proposed White Horse Rock site, the seabed is dominated by mud, mud/shell, and sand/shell habitats. Polychaete, nematode and amphipod species were the most abundant taxa within sediments (infauna). On the northern and inshore edge of the White Horse Rock site, where the seabed was dominated by soft sediments interspersed with shell material, turret shell gastropods,
9 For details on how natural character is defined and how natural character at the site is evaluated refer to Section 2 of the Landscape Report, set out in Appendix 3 10 The relevant dwelling number is shown on the house location maps in Appendix 21 of the main AEE 11 Submitted by the owners of the property adjacent to the White Horse Rock site, Pelorus Wildlife Sanctuary Limited, to the Council and Environment Court hearings (during 2009 and 2010) regarding the previously proposed salmon farm at White Horse Rock. 12 For further details refer to the Recreation Report in Appendix 16 to the main AEE. 13 For further details refer to the Site Deposition and Benthic Effects Report in Appendix 2 to this AEE
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sea cucumbers, snake tail stars, eleven-armed sea stars, sea urchins, cushion stars and ascidians were common. Hydroids, ascidians and sponges were also occasionally observed.
On the southern edge of the White Horse Rock site and further offshore, the substrate was muddy, with burrows present, but few epibiota were observed. Epibiota in this deeper region included sea cucumbers, sea stars, scallops, ascidians, sponges and bryozoans.
Shallow areas inshore of the proposed site were dominated by cobbles and small boulders, with tubeworm mounds and brown algae. A few rocky reef areas were present inshore of the proposed site providing structured habitat for grey vase sponges and ascidians. Communities inhabiting the hard substrate habitats inshore of the proposed Site (i.e. rocky reefs, boulders) are considered ecologically significant and highly valued in the Sounds region. While these habitats are far less common than muddy habitats in the Sounds region, diver transects undertaken by Cawthron in the wider Waitata Reach area showed that these communities were not unique to Waitata Reach, with similar communities observed along most of the transects14.
Table 5.1 below15 provides a semi-quantitative assessment of the inshore substratum types found at the White Horse Rock and Waitata sites.
Table 5.1 Estimated area (ha) of three substratum types out to the mud/silt boundary at the proposed White Horse Rock and Waitata Sites. Also included is the percentage of the total area of each substratum type inshore of the Sites.
Bedrock Reef Boulder/Cobble Pebble/Shell/Sand Total Measured ha (% total) ha (% total) ha (% total) Distance (km) 0.4 (0.3) 3.2 (1.5) 5.6 (0.7) 0.9
The above description of the benthic substrata and habitats is visually summarised in a series of maps located in Section 3 of the Seabed Report in Appendix 2 to the main AEE.
5.3.3 Summary of Existing Environment of the Proposed White Horse Rock Farm
A summary of the attributes for the proposed salmon farm site are provided below in Tables 5.2 to 5.6.
Table 5.1 below summarises the existing level of natural character and the landscape category applied to the site and the distance from the site to the nearest house likely to have a view of the proposed farm.
Table 5.2: Summary of Natural Character and Landscape Values16:
Visual Amenity Natural Character Landscape Nearest House with View of Site (Distance) Medium-high VAL* W2 3.2 km * Visual Amenity Landscape
14 For further details refer to the Site Deposition and Benthic Effects Report in Appendix 2 to this AEE 15 Adapted from Table 1 of the Seabed Report in Appendix 4 to the main AEE 16 Adapted from the Landscape Report in Appendix 3 to this AEE.
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In the main AEE, the eight proposed salmon farm sites are categorised into four catchments. In some cases, the proposed sites are also in the vicinity of existing salmon farms or other aquaculture activity such as mussel farming, and therefore are visually cumulative for potential observers. The proposed salmon farm at White Horse Rock comes within the Waitata Reach group of proposed salmon farms, as summarised in Table 5.3 below.
Table 5.3: Cumulative Grouping of Salmon Farm Sites in Waitata Reach on Potential Observers
Group Sites Area Existing Salmon Other Potential Observers Farms Aqua- Culture
1 Waitata Waitata Yes: Yes Observers include residents, Kaitira Reach Waihinau Bay recreational water users, tourism operators and aquaculture workers Tapipi Forsyth Bay nearby but and land managers. Richmond not in Waitata Reach White Horse Rock17
The physical and visual characteristics of the Waitata Reach catchment group have been examined for potential cumulative effects on coastal natural character, landscape and seascape character, outstanding natural features and landscapes and the visual amenity of observers. An overview of these cumulative effects is considered in the Landscape Report appended to the main AEE and summarised in the Landscape Report attached as Appendix 3 to this AEE.
Turning to the marine environment, the site depth and tidal currents are summarised in Table 5.4 below.18
Table 5.4: Summary of Marine Physical Characteristics
Site Depth Near-Bottom Currents Flow Type (m) Average (cm/s) Maximum (cm/s) 20-40 11.7 44.5 Moderate
Table 5.5 provides a summary of the grain-size and organic consent of the seabed at the White Horse Rock site as well as the infaunal abundance and diversity for the sites below.19
Table 5.5: Summary of infaunal abundance and diversity statistics, sediment grain size and organic matter, for the White Horse Rock Site (and the adjoining Waitata Site)
Taxa/core Total Abundance AFDW* Site (range) taxa (range) %w/w % Gravel % Sand % Silt/Clay White 28 (18-45) 147 99 (42-179) 12 31 57 5.2 Horse Rock Waitata 32 (15-53) 147 141 (33-473) 6 29 64 4.9 * AFDW = Ash Free Dry Weight (assessment of sediment organic content)
17 In main AEE for the eight proposed salmon farm sites, the White Horse Rock salmon farm is referred to as being “under appeal” (to the Environment Court) 18 Adapted from the Site Deposition and Benthic Effects Report in Appendix 2 19 Tables 5.4, 5.5 and 5.6 are adapted from the Site Deposition and Benthic Effects Report in Appendix 2.
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Finally, Table 5.6 below provides a summary of the dominant substrata and ecologically important habitats or values found within and adjacent to the proposed White Horse Rock site.
Table 5.6: Summary of the substrata and ecologically important habitats or values found within and adjacent to the proposed site
Dominant substrata Ecologically important habitats or values above trigger levels* Sand/shell, Mud, Mud/shell Small patches of Inshore reef habitat Tubeworm mounds and sponge communities * Source: Department of Conservation 1995: Guidelines for ecological investigations of proposed marine farm areas in the Marlborough Sounds. Nelson/Marlborough Conservancy, Occasional publication No. 25, 21 p.
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6.0 ASSESSMENT OF ENVIRONMENTAL EFFECTS
6.1 Introduction
This Chapter outlines the actual and potential environmental effects of the proposed salmon farm at the White Horse Rock site. The main AEE for the other eight sites is also relevant to the White Horse Rock site, where the effects are the same irrespective of the location within the Sounds, or would be the same as for the adjacent proposed Waitata site (which is the case with many of the effects considered in relation to the Waitata site). The following assessment therefore draws extensively on the main AEE and appended specialist assessment reports for the other eight sites. Rather than repeating that assessment, the following assessment instead cross references extensively to it.
Where the environmental effects of the White Horse Rock site are site specific or differ from those of the Waitata site, site-specific specialist assessment reports have been prepared and attached to this AEE. The following assessment summarises those site specific assessments.
Having had regard to the assessment of effects in this Chapter, Chapter 7.0 of this AEE then goes on to identify proposed means of monitoring and mitigation of any adverse effects by potential conditions on the resource consent.
6.2 Environmental Effects
6.2.1 Economic Effects
The assessment of economic effects contained in section 6.2.1 of the main AEE, and the related Economics Report20 is relevant to the assessment of economic effects from the White Horse Rock site. That assessment describes the economic benefits of NZ King Salmon’s proposed expansion of eight new farms, in the context of the regional (and top of the South Island) economy. It also considers the opportunity costs that may arise from the occupation and use of the Sounds by those salmon farms, through removing the ability of the occupied sea space to be used for alternative activities.
That assessment has been undertaken on the basis of production from NZ King Salmon’s existing operational farms, based on NZ King Salmon’s Biosecure future production levels (as described in the NZ King Salmon Report21). The Economics Report does not include an allowance for future production from the small White Horse Rock farm, which is subject to appeal. It notes that the assessment is conservative to the extent that another resource consent application has now been included for the White Horse Rock site. It is clear from the Economics Report that the additional salmon farming production from the eight additional farms (lodged with the Plan Change) represents a substantial increase in financial output from aquaculture in the region and for the top of the South Island. Overall, the Economics Report concludes that these proposed salmon farms will result in significant positive economic effects regionally and nationally, contributing to community economic and social wellbeing on a sustainable and on-going basis. If consented, the White Horse Rock site will, therefore, add to this overall contribution to the economic and associated social benefits derived from the increase in salmon farm production in the Sounds.
Furthermore, the Economics Report concludes that there is likely to be a very low opportunity cost as a consequence of the occupation of the marine resource by the proposed salmon farms, in terms of
20 Appendix 3 of the main AEE. 21 Appendix 2 to the main AEE
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other types of aquaculture, commercial fishing and tourism. Given its small size relative to the other eight proposed salmon farms, there is also anticipated to be a very low opportunity cost from the White Horse Rock site.
6.2.2 Iwi Cultural Effects
The assessment of iwi cultural effects contained in section 6.2.2 of the main AEE, and the related Iwi Interests Report22 can also be applied to the White Horse Rock site. That assessment considers the effects on iwi cultural values including in relation to the proposed adjacent Waitata site.
From that assessment, it is assumed that there may be some effects on iwi cultural values due to Maori historical associations and the location of historical Maori sites in and around the area of the Waitata and White Horse Rock sites. There do not appear, from publicly available information and from initial, more general consultation, to be direct impacts of significance.
Ngati Kuia is recognised as the Iwi with manawhenua/manamoana in this area. The iwi currently exercise a Kaitiaki role through resource management statutory processes (as they have through this application process), customary practices and commercial interests.
As part of its previous application for resource consent at White Horse Rock, NZ King Salmon held initial discussions with Rangitane, Te Atiawa and Ngati Apa, as well as Ngati Kuia and Ngati Koata. NZ King Salmon subsequently made personal contact with representatives of both Ngati Koata and Ngati Kuia. This engagement did not identify any concern with the proposal to place a salmon farm at White Horse Rock. Copies of the application were sent as part of the notification process as required.
Neither Iwi made a submission on the application at Council level. An expert historian engaged by NZ King Salmon to give evidence on that application before the Environment Court, David Armstrong, concluded that the area was in fact within the rohe of Ngati Kuia with some possible claim of influence with Ngati Toa. His conclusion is that this area is not within the rohe of Ngati Koata.
Ngati Kuia wrote a letter to the Council in August 2010 (when the matter was already before the Environment Court). That letter confirmed that the White Horse Rock site was within Ngati Kuia's rohe. The letter raised issues relating to toxic waste, environmental recovery, access and aesthetics. It did not raise any issues as to cultural effects.
Further details of the consultation undertaken with Ngati Koata and Ngati Kuia are set out in Chapter 8.0 of this AEE.
6.2.3 Effects on the Water Column
The assessment of effects on the water column contained in sections 6.2.3 and 6.3.1 of the main AEE, and the related Water Column report23 in respect of the Waitata site can also be applied to the White Horse Rock site. In particular the water column modelling undertaken already takes into account the White Horse Rock as being a potential consented site. That assessment has considered:
• Physical effects (on water currents, waves, stratification (mixing) and solar radiation) as a result of the 3-dimensional farm structures extending from the water surface down through the water column; • Effects of dissolved oxygen (DO) depletion associated with respiration (oxygen consumption) by large numbers of fish within a relatively small volume of water; and • Effects of additional nutrients introduced to the water column through the addition of feed and subsequent fish waste production.
22 Appendix 18 of the main AEE. 23 Appendix 5 of the main AEE.
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From that assessment, the following can be concluded in relation to the White Horse Rock site:
• Physical effects as a result of the farm structures may be difficult to detect due to the site’s dynamic environment. Mixing effects may be more likely to be detected around the structures due to frictional turbulence effects increasing with current speeds.
• The effects of submerged artificial lighting on the surrounding marine environment in terms of increased abundances of phototaxic zooplankton and phytoplankton are likely to be minor and unmeasurable.
• Slight to moderate localised depletion of dissolved oxygen is expected. The degree of reduction would not represent a significant risk to marine life and would not be expected to extend beyond farm boundaries.
• Production of fish waste will result in an increase dissolved nutrients within the water column around the farm and within the surrounding water column. This will be greatest near the farm and will decrease with distance with mixing and dilution.
• Levels of ammonium above thresholds for adverse effects on sea life are unlikely to occur, particularly beyond the close proximity of the farm.
• The assessment of net nitrogen inputs (from all proposed farms) has shown that they are below critical loading rates; so the new nutrient loading from the new farms is unlikely to compromise the integrity of planktonic ecosystems in the Sounds.
• There is no evidence to suggest that localised enrichment from existing farms in the Sounds has resulted in an increase in harmful algal blooms (HABs). The potential for discharges from the proposed salmon farms to result in changes in phytoplankton community structure, that could influence the incidence of HABs, is also considered unlikely.
• Modelling shows the potential for overlapping effects between the existing salmon farm at Waihinau Bay, the White Horse Rock site, and the proposed Waitata site. While the existing Waihinau Bay site is modelled to have a measurable influence on dissolved inorganic nitrogen (DIN) concentrations in the vicinity, the additional effect on DIN concentrations from the Waitata and White Horse Rock sites is small. There is also the potential for an associated small increase in phytoplankton biomass.
• The nature of copper and zinc discharges from antifouling agents and the known behaviour of such contaminants indicate that water column effects, if measurable, are unlikely to be ecologically significant and will be limited spatially to areas immediately adjacent to farm boundaries24.
6.2.4 Effects on the Seabed
The effects on the seabed for the other eight sites were considered in Sections 6.2.4 and 6.3.2 of the main AEE, and the related Seabed Report25.
Section 6.2.4 of the main AEE summarises the overall approach taken to the assessment of seabed depositional effects across all the proposed salmon farm sites. Typical seabed effects from the operation of salmon farms are described, including the results from 20 years of analysis of seabed effects at existing salmon farms in the Sounds. The approach to establishing sustainable feed capacities for the sites is described, based on their physical characteristics and associated effects on
24 Refer to Copper and Zinc Report in Appendix 6 to the main AEE 25 Appendix 4 of the main AEE.
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the seabed beneath and in the vicinity of the farms. This summary is based on the assessment contained in the Seabed Report appended to the main AEE.
That assessment, however, did not specifically consider the White Horse Rock site, except in relation to the potential cumulative effects of a White Horse Rock farm (should it be consented) and the Waitata site. Accordingly a site specific Depositional and Benthic Effects Report has been commissioned to specifically address the proposed White Horse Rock site. This White Horse Rock report is attached as Appendix 2 to this AEE26. This report uses the same approach to the assessment of seabed depositional effects and to establishing sustainable feed capacities as used in Seabed Report appended to the main AEE and cross-references to that Report.
Depositional modelling at the White Horse Rock site indicates reasonable dispersal of the depositional footprint due to the moderate water current velocities. The depositional footprint will be reasonably intense (but localised) towards the shallow (shoreward) side of the proposed cages, but relatively diffuse on the seaward side, where it fans out with the greater depth.
Modelling of the maximum likely feed loading at the White Horse Rock site of 3000 t/yr predicts an elliptical depositional footprint due to the effect of the prevailing current. Without resuspension in the model, the depositional footprint (deposition > 0.5 kg m-2 yr-1) affects an area of 6.3 to 9.7 ha at feed levels of 1300 to 3000 t yr-1, however, most of this area will be exposed to relatively low deposition rates. With resuspension in the model, deposition beneath the cages is considerably reduced, with depositional flux greater than 0.5 kg m-2 yr-1 predicted at feed levels of 1600 t yr-1 and greater. However, the total area affected is modelled to be negligible, with less than 2 ha affected at a feed loading of 3000 t/yr. In reality, the area affected by deposition is likely to be somewhere between these two ranges.
When the cumulative deposition effects of the neighbouring proposed Waitata Site are taken into account, relatively low rates of deposition are still evident, consistent with the high flows associated with the Waitata site and, therefore, the high dispersal potential (the particulates are spread further across the seabed). Without resuspension in the model, the overall area affected by deposition (> 0.5 kg m-2 yr-1), across combined feed loadings of 4000 to 8000 t yr-1, is estimated to be 25.2 to 32.3 ha for the two farms. With resuspension in the model, depositional flux greater than 0.5 kg m-2 yr-1 is not predicted, even at combined feed levels of 8000 t yr-127.
A summary map of the benthic habitats and the depositional footprints for the White Horse Rock site and for the combined White Horse Rock and proposed Waitata site, are shown in Figure 6.128 below.
26 Site Depositional and Benthic Effects Report attached to this AEE as Appendix 2 27 A combined maximum feed discharge of 8000 t yr-1 is proposed if both the White Horse Rock and Waitata farms are developed, although maximum feed discharges of 3000 t yr-1 for White Horse Rock and 6000 t yr-1 for Waitata are proposed if either site is developed without the other. 28 From Figure 15 in the Site Depositional and Benthic Effects Report in Appendix 2 to this AEE
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Figure 6.129: Predicted depositional footprint for the Maximum Conceivable Feed Level (MCFL) under a ‘no-resuspension’ scenario, overlaid onto the habitat map created for the White Horse Rock and Waitata Sites. The blue line indicates the 0.5 kg m-2 yr-1 deposition area and the orange line indicates the > 10 kg m-2 yr-1 deposition area. Top: Predicted depositional footprint for the White Horse Rock Site only (MCFL, 3000 t yr-1). Bottom: Predicted cumulative depositional footprint for the White Horse Rock and Waitata Sites (MCFL, 7000 t yr-1)
Depositional modelling of the maximum likely feed loading at the White Horse Rock Site predicts a primary depositional footprint (0.5 kg m-2 yr-1) of 10 ha, which extends up to 200 m beyond the Site boundary (as shown in Figure 6.1). The dominant habitats beneath the footprint are mud, mud/shell and sand/shell. Infaunal communities associated with these substrata are primarily polychaetes, nematodes, cumaceans, amphipods, ostracods and tanaids; taxa that are well represented and widespread in the Sounds region. Epibiota on these mud and shell habitats consist of snake tail
29 From Figure 15 in the Site Depositional and Benthic Effects Report in Appendix 2 to this AEE
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stars, sea stars, turret shells and sea cucumbers. Occasional horse mussels and scallops were observed within the footprint, but in densities well below trigger levels30.
High deposition levels of 10 kg m-2 (1-2 ha) are predicted to largely remain within the cage area boundary. In this area, directly beneath the farm cages (ca. 1-2 ha), infaunal communities will become highly enriched, infauna diversity will be significantly reduced and a high abundance of opportunistic taxa such as nematodes and Capitella capitata are expected. This is also likely to result in the displacement of most epibiota. It is anticipated that 10 ha of seabed will be moderately impacted, however, the level of enrichment will decrease rapidly with distance for the first 50 to 100 m, and then grade progressively to near-background conditions within 500 m.
The majority of notable ecological habitats in the study area are located inshore of the proposed cages. A small amount of benthic habitat inshore of the farm is likely to be affected by farm discharges. The reef and cobble/tubeworm mound areas inshore of the farm are expected to receive low levels of deposition. Comparison of the depositional footprints at maximum feed discharge rates shows the White Horse Rock site on its own is expected to affect a similar area of inshore habitat, but at a slightly higher level of deposition, than the cumulative effects from the White Horse Rock and Waitata farms. This is due to the reduced maximum feed discharge level at the inshore White Horse Rock site, if the Waitata farm is also developed.
Monitoring of rocky reefs at other NZ King Salmon farms indicates that the reef communities near the farms (90-200 m from cages) remained healthy and diverse after up to 18 years of operation. This data suggests that reef communities near White Horse Rock, which are located a minimum distance of 50 m from the proposed cages, may also remain healthy after farm operation commences. Monitoring of these habitats is proposed following initial operation of the proposed farm.
Overall, water current data and depositional modelling predicts that the majority of farm derived sediments will be transported away from inshore habitats and out into the main channel. While some highly localised changes in benthic community structure will occur directly beneath and adjacent to the farm, the majority of effects will be spread over a large area of more common soft-bottom mud habitat, in the main channel.
Effects outside of the depositional footprints of the proposed salmon farms have been assessed and described in the Seabed Report appended to the main AEE and in Section 6.3.2 of that AEE. Those findings are also relevant to the assessment of effects for this proposed salmon farm at White Horse Rock and should be referred to. In addition, that report and AEE describe and assess the following effects which are relevant to the proposed White Horse Rock farm:
• Seabed disturbance during initial farm establishment, particularly the installation of the screw anchors; • Potential increases in the abundance of epibiota, or surface dwelling animals, in response to increased food availability in the vicinity of the salmon farms; • Localised reduction in levels of light reaching the seafloor as a result of the salmon farm structures; • Fouling organisms depositing beneath the farms; • The release of copper and zinc in quantities that have the potential to result in accumulation within sediments beneath and adjacent to salmon farms over time31.
A summary of potential effects to the seabed environment is also provided at the end of Section 6.3.2 of the main AEE which will not be repeated here, but should also be referred to.
A comprehensive monitoring and adaptive management programme, with assessment of seabed effects against defined environmental standards, is recommended in the Site Depositional and
30 Department of Conservation 1995: Guidelines for ecological investigations of proposed marine farm areas in the Marlborough Sounds. Nelson/Marlborough Conservancy, Occasional publication No. 25, 21 p 31 Also refer to the Copper and Zinc Effects Report appended to the main AEE as Appendix 6
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Benthic Effects Report32. The proposed mitigation measures and monitoring proposed for the White Horse Rock site reflect these recommendations and are described in Chapter 7.0 of this AEE.
6.2.5 Effects on Pelagic Fish
The effects on pelagic fish from salmon farms are generic across the Sounds environment. The assessment of effects on pelagic fish contained in section 6.2.5 of the main AEE, and the related Pelagic Fish report33 can therefore also be applied to the White Horse Rock site.
That assessment considers the effects of salmon farms on the abundance, biomass, and species diversity of wild fish. It also considers the effects of underwater artificial lighting from farms on pelagic fish as per the Artificial Lighting report34. From that assessment it can be concluded that subject to recommended monitoring and management practices, that any adverse effects on pelagic fish will be minor. The mitigation measures for the White Horse Rock resource consent are described in Chapter 7.0.
6.2.6 Effects on Marine Mammals
The effects on marine mammals from salmon farms are generic across the Sounds environment. The assessment of effects on marine mammals contained in section 6.2.6 of the main AEE, and the related Marine Mammals report35 can therefore also be applied to the White Horse Rock site.
That assessment identifies the effects of salmon farms on marine mammals, particularly seals, dolphins, and whales which inhabit the marine environment of the Sounds. This includes the potential effects of entanglement, effects from noise and lighting, and impacts on the foraging habitat of marine mammal species. From that assessment it can be concluded that any adverse effects on marine mammals will be minor. While there is a high likelihood of farm-seal interactions in particular, no adverse effects on seals are anticipated, subject to the measures recommended being adopted by NZ King Salmon. The mitigation measures for the White Horse Rock resource consent are described in Chapter 7.0.
6.2.7 Effects on Seabirds
The effects on seabirds from salmon farms are largely generic across the Sounds environment. The assessment of effects on seabirds contained in section 6.2.7 of the main AEE, and the related Seabirds report36 can therefore also be applied to the White Horse Rock site. Discussion in that report relating to the Waitata site in particular is also relevant to the White Horse Rock site.
That assessment describes the effects of salmon farms generically on seabirds, and the effects of the specific sites in relation to known breeding and roosting sites, particularly those of the nationally endangered King Shag. These include the potential effects of entanglement, ingestion of litter, exclusion from feeding areas, and the disturbance of breeding and roosting birds. This includes the effects on the existing King Shag roosting site located at Boat Rock Point.
The report recommends that a 100m buffer is maintained around that roosting colony where activities associated with salmon farms are excluded. There is sufficient separation between the proposed farm and the Boat Rock Point roosting site for this buffer to be maintained. Consequently it is anticipated that the proposed White Horse Rock farm will have negligible effects on breeding, roosting, and foraging seabirds. The mitigation measures proposed for the White Horse Rock resource consent application are described in Chapter 7.0.
32 Refer to Appendix 2 of this AEE. 33 Appendix 8 of the main AEE 34 Appendix 12 of the main AEE. 35 Appendix 9 of the main AEE. 36 Appendix 10 of the main AEE.
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6.2.8 Biosecurity Effects
Aquaculture activities in general can exacerbate the establishment and spread of macroscopic unwanted marine organisms, and hence have the potential to adversely affect mussel aquaculture and natural ecosystems.
The potential biosecurity effects of salmon farms are generic across the Sounds environment. The assessment of effects contained in section 6.2.8 of the main AEE, and the related Biosecurity report37 can therefore also be applied to the White Horse Rock site. From that assessment, the effects on the spread of non-indigenous marine pests from the White Horse Rock site are considered minor. The biosecurity management measures proposed for the White Horse Rock resource consent application are described in Chapter 7.0.
6.2.9 Effects from Disease Risk
Farming of salmon has the potential to introduce and spread infectious diseases within the farmed salmon population, and also to wild fishes and other aquatic animals. The effects from disease risk apply generically across the Sounds environment. The assessment of disease risk contained in section 6.2.9 of the main AEE, and the related Disease Risk report38 can therefore also be applied to the White Horse Rock site.
On the basis of that assessment, no disease effects are anticipated as result of the proposed White Horse Rock site. The grouping of the White Horse Rock site and the other proposed Waitata sites separately from NZ King Salmon’s other existing and proposed farms will also enable it to manage disease risks within three separate farm management areas.
6.2.10 Effects on Terrestrial Ecology
The effects on terrestrial ecology of the adjacent land from the proposed Waitata site have been considered in section 6.2.10 of the main AEE, and the related Terrestrial Ecology report39. That assessment can therefore also be applied to the White Horse Rock site.
That assessment identifies that as none of the activities associated with salmon farming occur on the adjoining land, their construction and operation will not have any direct effects, either individually or cumulatively on the land and terrestrial ecology values. Furthermore, no adverse indirect effects were identified, provided that current farm waste management methods currently used by NZ King Salmon farm continued at this site. Accordingly on the basis of the Terrestrial Ecology Report, no direct or indirect adverse effects on terrestrial ecological values are anticipated from the White Horse Rock site.
6.2.11 Natural Character, Landscape and Visual Amenity Effects
The effects on natural character, landscape, and visual amenity assessment completed for the other eight sites were considered in sections 6.2.11 and 6.3.3 of the main AEE, and the related Landscape Report40.
That assessment considered the cumulative natural character and landscape effects of all the proposed sites in the Waitata Reach, plus a potential farm at the White Horse Rock site,. However it did not consider the White Horse Rock site being developed itself, including the scenario of it being developed in advance of, and without, the adjacent Waitata site. Accordingly an additional Landscape
37 Appendix 7 of the main AEE. 38 Appendix 11 of the main AEE. 39 Appendix 14 of the main AEE. 40 Appendix 13 of the main AEE.
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report has been commissioned to specifically address the White Horse Rock site. This report is attached as Appendix 3 to this AEE.
As outlined in section 5.3.1, the existing natural character of the site has been assessed as moderate – high, due in part to the existing, but as yet to be implemented, mussel farm consent at the site. The site is considered to have a medium level of sensitivity, with some capacity to accommodate change in the form of the proposed salmon farm which has been assessed as resulting in a medium-low magnitude of change to the natural characteristics of the site. The location and proximity of the site to the influence and pattern of existing and consented modification in the seascape, both locally and in neighbouring waters, assists in integrating the proposal into the coastal landscape. The area of high natural character on the land will remain, with the benthic environment able to accommodate change. Overall, the effects of the proposed salmon farm on natural character have been assessed as moderate, reflecting the balance between the high level of natural character on the adjacent headland and the influence of the wider pattern of existing and consented modification in the local and neighbouring waters.
Effects of the White Horse Rock proposal on natural features and landscapes at this site have also been assessed as moderate when considered in terms of the extent of modifications in the vicinity of the site. Adverse impacts of the White Horse Rock proposal on Outstanding Natural Features and Landscapes (ONFL’s) in the wider coastal environment have been assessed as low due largely to their distances from the site.
The effects of the proposed White Horse Rock site on the visual amenity of private viewpoints and on views from roads and tracks has also been assessed as low due to the limited viewpoints available and the distance of the site to the closest dwelling and public road. The potential effects of the proposed salmon farm on the visual amenity values of water-based views are also considered to be low, due largely to the existing and consented pattern of modification in the vicinity of the site and the temporary nature of most views.
As mentioned in the introduction to this section, a comprehensive assessment of cumulative effects for the proposed farms in the Waitata Reach has been undertaken and is contained within the Landscape Report, appended to the main AEE. Within that report, the cumulative effects also take into account existing and potential salmon farms, including the potential for a salmon farm at the White Horse Rock site should that appeal be granted. Accordingly, refer to that AEE for an assessment of the cumulative effects of all existing, proposed and potential salmon farms in Waitata Reach, including the White Horse Rock farm.
The Landscape Report attached to this AEE as Appendix 3, however, addresses cumulative effects of the White Horse Rock site in the context of the current existing environment, including the existing Waihinau Bay farm. It has concluded the cumulative coastal natural character, landscape, and visual amenity effects of the two sites would be low. The report considers the current and consented cumulative pattern and extent of mussel farming in Waitata and Waihinau Bays, and current land uses above the coastal edge, reduce the significance of any cumulative effects for these two salmon farms together.
6.2.12 Noise Effects
The noise effects of the proposed Waitata salmon farm site have been considered in section 6.2.12 of the main AEE, and in the related Noise report41. While it has not considered the White Horse Rock site specifically, much of that assessment can be applied to this proposed farm given the likely similar nature of the noise sources and the same surrounding environment.
The proposed White Horse Rock site would potentially represent an additional noise source in addition to noise generated by the Waitata site. However it is proposed in this application that the White Horse Rock and Waitata sites will share a single barge building and related facilities between
41 Appendix 15 of the main AEE.
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them. The barge is the principal source of noise relating to salmon farming, containing the main generator, feed dispenser compressor, and water blaster, etc. Accordingly, it is anticipated that noise levels associated with the combined operation of both farms will not be significantly greater with the addition of the White Horse Rock farm, given the sharing of many facilities.
The noise standard proposed for the other eight sites through the CMZ3 rules is based on the current MSRMP standard for the Coastal Marine Zones, albeit to be measured at a point 250m from farm structures. The same noise standard is proposed for the White Horse Rock site - to be implemented by way of conditions of consent.
In order to assess the noise effects from the combined operation of the White Horse Rock and Waitata salmon farms, a brief additional noise assessment report has been prepared for this White Horse Rock application. This report is attached as Appendix 4 to this AEE. For the purposes of this assessment, it has been assumed that all noise-generating equipment would be situated on the White Horse Rock site, with an additional generator and feed dispensing system on the Waitata site. This provides a conservative, “worst-case” assessment of the noise emissions from the White Horse Rock and Waitata salmon farms.
The calculated noise levels, based on the above assumptions, are shown in Table 6.142 below. The noise levels calculated include the mitigation measures recommended for all salmon farms in the Noise Report appended to the main AEE43.
44 Table 6.1 : Predicted Noise Levels (LA10) with Mitigation – White Horse Rock and Waitata Sites
Assessment Location Daytime Nighttime Sat-pm/Sunday All equipment Generator All equipment operating only operating except waterblaster
Proposed Noise Limits 55 dB 45 dB 45 dB Assessment location 250m 47 dB 30 dB 45 dB Most affected house (3.2km) 14 dB 2 dB 14 dB
Closest Shoreline (85m) 56 dB 37 dB 54 dB Closest location to proposed trail 43 dB 26 dB 41 dB (approx. 380m)
These noise level predictions show that, if the White Horse Rock and the Waitata sites are both developed for salmon farming, the noise emitted from the farm will comply with the proposed noise limits at 250m from any marine farm surface structure, at the possible walking trail on the adjoining land, and at the nearest house (by a considerable margin).
The nearest shoreline is closer to the farm than 250m, so it is not proposed that the noise limits apply at this nearer location. However, were the noise levels to be measured at the nearest shoreline, they are predicted to effectively comply with the daytime and night limits (within prediction tolerances), but would exceed the stringent Saturday/Sunday limit by up to 9dB. However, the gradient of the adjacent land is very steep, structures and walking tracks are unlikely to be built there and the area is
42 From Table 1 in the Noise Report attached to this AEE as Appendix 3 43 Refer to Appendix 15 Noise Report to the main AEE 44 From Table 1 in the Noise Report attached to this AEE as Appendix 3
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likely to remain largely uninhabited, so it is not considered necessary to apply the noise limits to this near location.
The closest recreational users are likely to be on a possible trail leading down the ridge, if the trail is constructed, or on the water. The noise limits would be complied with at the closest part of the possible trail, which is approximately 380m from the salmon farm. If recreational users do come close to the farms on the water, the noise levels would be similar to a working rural environment close to the machinery.
As per the assessment of the other eight farm sites, recreational vessels may be present within 250 metres of the proposed farm. However they are unlikely to spend significant time in that close location. The potential for underwater noise from the White Horse Rock farm is also expected to be similar to that predicted for the Waitata farm as the noise sources will be the same. Consequently, as per the previous assessment, underwater noise will be similar or less than the noise from other marine activities in the Sounds.
The mitigation measures proposed for the White Horse Rock resource consent application are described in Chapter 7.0. These mirror those for the other sites and include compliance with the same noise levels, and the preparation of a noise management plan confirming those levels can be complied with and detailing any noise mitigation attenuation.
6.2.13 Effects on Historic Heritage
The effects of the proposed Waitata site on historic heritage including archaeological sites, European heritage sites, and shipwrecks has been considered in section 6.3.4 of the main AEE, and the related Heritage report45. That assessment can therefore also be applied to the White Horse Rock site.
On the basis of that assessment, the effects on heritage and archaeological sites are anticipated to be minimal or negligible in the case of the White Horse Rock site.
6.2.14 Effects on Tourism and Recreation
The effects of the proposed Waitata site on tourism and recreation has been considered in sections 6.2.14 and 6.3.5 of the main AEE, and the related Recreation report46. That assessment can therefore also be applied to the White Horse Rock site.
That assessment considers the potential effects from salmon farms displacing recreational activities and impacts on the amenity values of the recreation and tourism experience. The Waitata site was considered to be in an area which is of lower recreational and tourism use, being removed from existing water based activity, land routes, and infrastructure, and already having a consented mussel farm at the same location. In addition, it was assessed as not having recreational activities that were not directly substitutable nearby. The adverse effects were, therefore, assessed to be less than minor. On this basis, no significant adverse effects on tourism and recreation are anticipated from the development of the proposed White Horse Rock farm.
As noted for the Waitata site, the existing use of water space for recreational fishing is unknown. Accordingly it has been recommended that further consultation with the recreational fishing community is undertaken. This is also considered appropriate for the White Horse Rock site following lodgement of the resource consent in order to determine the pattern of fishing at and near the site.
45 Appendix 17 of the main AEE. 46 Appendix 16 of the main AEE.
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6.2.15 Structural Safety
The proposed White Horse Rock farm is located in an area with strong tidal currents and exposed to ocean swells as well as the short-fetch waves, characteristic of the Sounds. In order to ensure the safety and security of the structures required for the proposed salmon farm, a site specific Structural Engineering report for the White Horse Rock farm has been prepared. This encompasses a preliminary structural design and mooring analysis. A copy of the Structural Engineering Report is contained in Appendix 5 to this AEE.
The proposed design for the floating farm structures has been assessed as fully feasible from a mooring and structural safety perspective. It will use proven technology with known, high factors of safety. This is based on existing experience with NZ King Salmon’s farms at Te Pangu and Clay Point, which are located in high flow locations in Tory Channel. The proposed design has been able to benefit from the company’s ongoing development and refinement of its moorings and structures at these existing farms to ensure safety and security.
In order to ensure the screw anchor installation is undertaken in compliance with the design capacity, it is recommended that monitoring of the installation forces occur, as well as undertaking a pull-out test on a representative anchor. In addition, a hydrodynamic force monitoring programme is recommended to be implemented to continually monitor the wave and tidal current forces on the mooring system and structures, in order to check that the loading remains with the specified and tested design loads.
Subject to these recommendations, it is considered that the safety and security of the salmon farm structures at White Horse Rock can be assured with a high safety factor. The mitigation measures proposed for the resource consent application are described in Chapter 7.0.
6.2.16 Effects on Navigation
The effects of the proposed Waitata site on navigation has been considered in sections 6.2.15 and 6.3.6 of the main AEE, and the related Navigation report47. This has also recognised the existing unimplemented mussel farm consent that exists for the White Horse Rock site, and has had regard to the potential for a salmon farm to be established on that site under the consent that is currently under appeal48.
The Navigation Report notes that with both the White Horse Rock and Waitata salmon farms developed, there would be approximately 70m of sea room on the inside of the White Horse Rock Farm. This is a greater amount of clearance than if the consented mussel farm on the White Horse Rock site was present, given that surface structures on mussel farms generally occupy the area of the permit with the exception of the space needed for the anchor warps which run parallel to the shore. Large vessels, or vessels which wish to travel at speed, would choose to travel in the main part of the Reach. Vessels which are prepared to reduce their speed will be able to navigate inshore of the farms. Provided vessels keep 4-5m away from the salmon farm structures, the anchor ropes will be at a depth that will not interfere with navigation of small vessels. Farms will also be well lit at night and conspicuous by radar. On the basis of Navigation report, the proposed White Horse Rock farm therefore poses little risk of collision for a competent navigator maintaining a look out and travelling at a safe speed.
A comprehensive set of conditions is recommended in the Navigation Report to ensure no adverse effects on navigational safety. The mitigation measures proposed for the resource consent
47 Appendix 19 of the main AEE. 48 Although a consent has been granted by the Council for a salmon farm on the White Horse Rock site, this is currently under appeal to the Environment Court. This current application is a new application for a salmon farm on the same site, lodged with the EPA and intended to be considered in conjunction with the plan change and resource consents for eight other salmon farms in the Sounds, including the Waitata site adjoining the White Horse Rock site.
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applications are described in Chapter 7.0. However, it should be noted that the requirements for navigational lighting are the responsibility of the Council’s Harbourmaster under separate legislation.
6.2.17 Discharges to Coastal Water and Air
The nature of the discharges to coastal water and air included in the resource consent application for the White Horse Rock salmon farm is described in Section 3.5 of this AEE. This description cross- refers to the details regarding the nature of these discharges contained in Section 3.6.1 of the main AEE. Those details are stated as also applying to the discharges proposed at the White Horse Rock site.
Section 6.4 of the main AEE summarises, and where necessary adds to, the assessments of environmental effects from these discharges already described in Chapter 6.0 of this AEE. In addition, an evaluation of the relevant discharges in terms of sections 105 and 105 of the RMA is provided. The assessment of the effects of proposed discharges contained in Section 6.4 of main AEE equally applies to the proposed discharges from a salmon farm at the White Horse Rock site and should therefore be referred to.
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7.0 MITIGATION AND MONITORING
Chapter 6.0 of this AEE has summarised the assessments of effects on the environment. These are described in more detail in the specialist reports attached as Appendices to this AEE or to the main AEE for the other eight sites. Where some adverse effects are identified, the specialist environmental assessment reports include recommendations or suggestions for mitigation management and monitoring.
Table 7.1 includes NZ King Salmon’s proposed mitigation and monitoring actions, based on the recommendations of the specialist reports. It is anticipated that the mitigation and monitoring set out in Table 7.1 will be reflected in the conditions of consent granted for the White Horse Rock salmon farm.
Table 7.1: Proposed Mitigation and Monitoring (based on recommendations from the specialist environmental assessment reports)
Topic Mitigation Monitoring
Seabed Feed Discharge Levels: Baseline Monitoring Prior to Site Development: Effects49 • Maximum Initial Feed Discharge (per annum) - 1200 tonnes Baseline survey monitoring of seabed within, and adjacent to, the site, prior to site development (in accordance with EM- (±15%) 53 • Incremental Feed Discharge increases (per annum) - 500 tonnes AMP ) – one survey required. (±15%) This should include: • Minimum time period between incremental feed discharge a. Quantitative (replicate) data for environmental variables increases of 3 years from each of the likely on-ongoing monitoring stations; • Maximum Feed Discharge (per annum) - 3000 tonnes (±15%) b. Spatial information on the distribution of soft-sediment • Maximum combined Initial and Maximum Feed Discharges if habitats and communities across the site Waitata farm is also developed: • Initial 4000 tonnes per annum (±15%) Should also include pre-development monitoring of: • Maximum 8000 tonnes per annum (±15%) c. habitats that support notable biological features within and adjacent to the site, once prior to farm installation. Process for Increasing Feed Discharge Levels: Incremental Feed Discharge increases subject to: Monitoring Programme Following Site Development: Monitoring of seabed following site development – the primary
49 Refer to Site Depositional and Benthic Effects Report in Appendix 2 to this AEE 53 Environmental Monitoring and Adaptive Management Programme (EM-AMP)
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• Site operating at or near its current maximum annual feed depositional footprint and associated ecological effects - as capacity (±15%) for at least 3 years specified in Annual EM-AMP. • Impacts have stabilised (at least 2 successive years of monitoring Sampling intensity dependent upon the age development at the results comparable) site, how stable the feed levels have been over the last 12 • Site is compliant with Environmental Quality Standards (EQS) months, and whether or not the site has been compliant with the ES over the last 2 years (and if not what the breaches related to (in accordance with Figure 19 of the Seabed Report appended Location of First Cages: to the main AEE) Start first cages at a specified location and some cages to always remain against that Boundary (i.e. the number of cages at the site Refer to Table 15 of Seabed Report (appended to the main AEE) for basic sampling methods associated with the different would expand and/or contract from the other end of the row of cages) types of monitoring intensities
EQS50 Compliance Zones: Monitoring results and adaptive management measures for the Establish Site-specific Zones for EQS compliance (Zones 1, 2 & 3). following year to be specified in an Annual Report The recommended maximum dimensions for the initial Zone Boundaries to be in accordance with Table 11 of the Site Depositional and Benthic Effects Report Monitoring of Habitats that Support Notable Biological Features: The size and shape of the Zones for the site will be reviewed (to compare with the predicted zones), after 3 years of operation at the Monitoring of habitats that support notable biological features within and adjacent to the site; as well as comparable habitats Initial Feed Discharge level. and appropriate control / reference sites to determine if salmon farm sediments have an effect on viability and recruitment of Environmental Quality Standards (EQS): key species and communities in these habitats EQS established against which the monitoring results will be This would be an expansion of NZ King Salmon’s existing reef assessed. monitoring programme to include identified areas close to the In accordance with Table 6 and Figure 8 of the Seabed Report51 proposed site and additional reference locations. (appended to the main AEE) Sampling would entail collecting quantitative measurements of abundance and cover of key species from photographic samples and analysing for spatial and temporal patterns. EQS Compliance:
Zone 1 & 2 (measured beneath edge of cages – ‘Cage’ Stations): • ES52 ≤ 5
50 EQS = Environmental Quality Standard 51 Seabed Report attached as Appendix 4 to the main AEE 52 ES = Enrichment Stage
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• No more than one replicate core with no taxa (azoic), • No obvious, spontaneous H2S out-gassing, • Bacteria mat coverage not greater than localized/patchy.
Zone 3 (measured at the Z2/3 Boundary Stations) • Infauna abundance cannot be significantly higher than at corresponding ‘Cage’ Station.
Zone 4 (measured at Zone 3/4 Boundary Stations): • ES < 3 • Conditions must remain comparable with appropriate reference Station(s).
Disturbance to the Seabed during Initial Farm Development Use of experienced and qualified personnel to install anchors and structures to minimise the amount of seabed disturbance during installation
Effects of Trigger Levels: Monitoring of Copper and Zinc: Copper and 54 ISQG-Low criteria for copper and zinc to be used as first tier trigger Monitoring of copper and zinc using an adaptive, decision-tree Zinc values within an adaptive monitoring program approach, whereby monitoring effort increases in focus and intensity as trigger levels (representing the increased likelihood of ecological effects) are reached. Hierarchy of Management Actions if Trigger Levels Exceeded: A suggested structure for an Adaptive Management Plan for Hierarchical schedule of management actions for exceedance of copper in sediments beneath farms is presented in Figure 9 of defined trigger levels55 the Copper and Zinc Effects Report (appended to the main Where it becomes clear that sediment trigger levels are exceeded for AEE) copper in its potentially bioavailable forms, management action to A similar framework to be followed for zinc, but simplified, as curb inputs to the system and/or research instigated to examine the zinc is not expected to be associated with paint flake material. actual bioavailability and toxicity of the copper contamination and to potentially replace the trigger levels with site-specific criteria.
54 Refer to Copper and Zinc Effects Report in Appendix 6 to the main AEE 55 Refer to Figure 9 of the Copper and Zinc Effects Report to the main AEE
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A similar framework for management action and/or research for zinc. 56 Biosecurity Biosecurity Management Plan (BMP): Biosecurity Monitoring Practices: Mitigation measures for marine pests to form part of a Biosecurity Passive surveillance regime (as currently practised at NZ King Management Plan (BMP) that NZ King Salmon is already developing Salmon’s existing farms), in which farm workers watch out for for disease management; to include on-farm as well as pathway- target pest species, or any unusual fouling on farm structures, based management measures during their daily activities Direct pathway management to reduce the risk of pest spread, such as the implementation of a regular regime of vessel hull coating with antifouling paint General on-farm management measures, and targeted measures to control or contain specific pest species; Routine practices to manage fouling of nets and structures (as currently practised on NZ King Salmon’s existing farms)
Submerged Lighting Levels: Artificial 57 Only the amount of lighting required for beneficial outcomes for Lighting salmon production should be used (i.e. unnecessary over-powering of lights should be avoided)
Pelagic Best Practice: Fish58 Implement best practices for: • minimisation of feed loss from salmon farm cages • management of shark interactions as identified by industry members at 2003 South Australian workshop (as set out in the Pelagic Fish Report), including: o Good farm husbandry, which minimises the number of fish dying in the cages; o Prompt removal of dead fish from cages in accordance with NZ King Salmon’s current practices;
56 Refer to Biosecurity Report in Appendix 7 to the main AEE 57 Refer to Artificial Lighting Report in Appendix 12 to the main AEE 58 Refer to Pelagic Fish Report in Appendix 8 to the main AEE
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Shark Exclusion: Utilisation of predator exclusion nets or shark-resistant materials in cage construction
Marine Seal Management: Monitoring of Nets: Mammals59 Continue to use the methods currently practised at NZ King Salmon’s • Rigorous regime of net inspections existing farms to mitigate seal attacks, these include: • Checking tension is maintained on predator nets and • Provision of, and continual improvements to, protection netting anchor warps around all salmon cages (both predator netting encompassing all • Monitoring for loose lines and debris the salmon cages, and bird netting over each cage). • Predator exclusion netting should extend sufficiently high above the water around the farm to exclude seals, but no higher. • Rigorous net inspection and maintenance regime • Maintenance of existing operating procedures in relation to seal management
Cetacean Interaction Management: • Well tensioned protection nets surrounding the entire farm, with net tension constantly maintained • Well tensioned grower nets • Rigorous net inspection and maintenance regime • Maintain anchor warps that are sufficiently taut to prevent entanglement of cetaceans • Farm maintenance practice requiring the monitoring and securing of all lines and the collection of loose lines and debris • Farm management practices, such as retention of all net and cordage debris, plastic strapping and other domestic rubbish for disposal ashore
59 Refer to Marine Mammals Report in Appendix 9 to the main AEE
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Marine Mammal Policy: • Continue to develop and implement NZ King Salmon’s Marine Mammal Policy, incorporating training and a regular reporting system for managers and staff at all farms • Continue existing liaison and information sharing with DoC regarding farm interactions with seals and cetaceans, and the continued development of improved management measures • Farm staff to be instructed in the identification and safe handling of both live seals and cetaceans
Best Practice: Implement best practices for: • minimisation of feed loss from salmon farm cages good farm husbandry, which minimises the number of fish dying in the cages, and prompt removal of dead fish from cages in accordance with NZ King Salmon’s current practices
60 Disease Harvesting Methods: Disease Surveillance: Use of harvesting methods consistent with world’s best practice Effective disease surveillance management for this activity for minimisation of disease risk. NZ King Salmon’s current harvesting practices are considered to meet this standard
61 Seabirds Buffer Zones to King Shag Roosting Site: Establish buffer zone of 100m around the existing King Shag roosting site at Burnt Rock Point, within which no activities associated with the salmon farm occur
Terrestrial Litter Management: Ecology62 Litter management practices in accordance with NZ King Salmon’s
60 Refer to Disease Risk Report in Appendix 11 to the main AEE 61 Refer to Seabirds Report in Appendix 10 to the main AEE 62 Refer to Terrestrial Ecology Report in Appendix 14 to the main AEE
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standard operating procedures
Visual Colour of Structures, Building and Facilities: Amenity63 • Black or dark colour to be used for netting that is normally above- water • Building to be painted in a dark colour, such as the karaka green used on the buildings at the existing Clay Point and Te Pangu salmon farms • All the features (drain pipes, etc) on the building to be painted in the same colour as the building • All exterior, above-water pipe work and other metal structures (other than the surface of walkways) to be painted in dark recessive colours Curtains to be provided for accommodation building windows and curtain fabric to be a dark colour
64 Engineering Engineering Design and Installation: Monitoring of Hydrodynamic Forces: • Farm layout, mooring and anchoring arrangements and Monitoring of actual hydrodynamic forces on farm by tidal installation, as per Engineering Report and associated layout currents and waves to be undertaken on an ongoing basis, to plans. confirm that loading is within specified design loads • Design loading for mooring and anchoring system in accordance with recommendations of suitably qualified and experienced engineer • Test pullout loading to be undertaken of a representative anchor, to confirm anchor pullout capacity, in accordance with Engineering Report
Mooring Loading Exceedances: Where monitoring shows exceedance of design loading on moorings, causes of any loading exceedances to be investigated and rectified
63 Refer to Landscape Report in Appendix 3 to this AEE 64 Refer to Structural Engineering Report in Appendix 5 to this AEE
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65 Noise Noise Limits Noise Limits not to be exceeded at or beyond 250m from the salmon farm surface structures:
0700 – 2200 hours Mon-Fri & 0700 – 1200 hours Sat – 55dBA L10
On any day between 0700 and 2200 hours - No Lmax Limit
All other times including any public holiday – 45dBA L10 and 75 dBA Lmax Noise ordinarily generated by the arrival and departures of vessels servicing the salmon farm to be exempted
Noise Management Plan: Before commencement of on-site establishment, Noise Management Plan to be prepared by suitably qualified acoustic engineer to confirm that the Noise Limits can be complied with and provide details of noise mitigation treatment required to achieve this.
65 Refer to Noise Report in Appendix 15 to the main AEE and the Noise Report appended as Appendix 4 to this AEE
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8.0 CONSULTATION
Consultation relating to the White Horse Rock site was undertaken as part of the previous resource consent application by NZ King Salmon, which remains subject to appeal. No further consultation has been undertaken specifically as part of the current application on the basis that the applications are very similar.
Pre-application consultation as part of the previous application was by way of personal contact with potentially adversely affected parties and submitters to seek any immediate comment. This included discussions with the manager of the land adjacent to the site, both relevant Iwi, and a public meeting called by the Marlborough Sounds Advisory Group held at Waitaria in November 2008. No consultation with commercial fishing interests was undertaken as there were no known commercial fishing activities adjacent to the proposed farm.
The subsequent public notification of the application by the Marlborough District Council invited submissions, of which a number were made. At that time an oversight was identified where by the owners of the Tui Nature Reserve (on the Reef Point headland to the south) had not been consulted or directly notified of the application. As a result NZ King Salmon engaged in discussion with the owners the reserve, resulting in an agreement being reached and their submission being withdrawn. The agreement reached enabled NZ King Salmon to become a Full Green Partner in the Tui Nature Reserve.
Other post submission consultation was held with other submitters with a view to finding mutually acceptable solutions to the concerns raised. However no agreement was reached prior to the Council hearing of the application. These included discussions with the appellant to the current resource consent application for the site, Pelorus Wildlife Sanctuaries, which continued following the lodging of the appeal by the appellant.
As stated in Section 6.2.2 of this AEE, NZ King Salmon has previously engaged with both Ngati Kuia and Ngati Koata. Initially, NZ King Salmon was advised by representatives of Ngati Koata that there were no areas of concern to that iwi in respect of the application. Subsequent correspondence from Ngati Koata, however, raised some potential concerns. Following that, NZ King Salmon once again sought to meet with iwi representatives to discuss those concerns. That invitation was not accepted.
In respect of Ngati Kuia, initial discussions also revealed that there were no elements of particular concern to that iwi regarding the White Horse Rock application. Further consultation was undertaken following the lodgement of the original consent application with the Council, when NZ King Salmon met with the chairperson of Te Runanga o Ngati Kuia, Waihaere Mason. Mr Mason advised that Ngati Kuia would not make a submission on the application, but rather provide comments in writing. A letter was sent to the Council dated 12 August 2010 (described in Section 6.2.2.) which contained those comments.
King Salmon has good relationships with iwi generally. For example, at the Clay Point farm in Tory Channel, it has a type of joint venture arrangement with Te Atiawa. This involves leasing the water space from Te Atiawa. NZ King Salmon also has a memorandum of understanding with Te Atiawa as to future cooperation. NZ King Salmon is of the view that it has appropriately consulted with iwi in respect of this application and takes the interests of iwi into account, endeavouring to work with iwi wherever possible.
It should be noted that the Māori Commercial Aquaculture Claims Settlement Act 2004 gives full and final settlement to Maori for any claims in relation to the allocation of marine farming space. Existing marine farms will not be affected except to be included in the calculation to determine how much space has been allocated to the industry since 1992 and thus enable a determination as to how much space or other compensation is required to satisfy the 20% allocation. A cash settlement has been agreed between Te Tau Ihu Iwi and the government as settlement for the space over which the White Horse Rock site lies.
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