Proposed Coromandel Finfish Marine Farming Zone - Ministry of ...

PROPOSED COROMANDEL FINFISH MARINE FARMING ZONE 

REPORT OF THE MINISTERIAL ADVISORY PANEL 

 

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The Aquaculture Unit is a business unit of the Ministry of Fisheries



Site visit observation: On location at the proposed zone, 20 January 2011, looking in an 

easterly direction. Excellent visibility. Fine, wind from the south, approximately 15 knots. Small 

southerly chop. Radar confirmed the presence of four boats within a four nautical mile radius 

of the boat. A yacht is visible directly astern. 

Cover photo: A kingfish farm sea-cage near Port Lincoln, South Australia. Courtesy Environment Waikato. 

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Contents 

Foreword 4 

Acknowledgements 5 

Recommendations 6 

Map of area 9 

Introduction 10 

Proposed Coromandel Marine Farming Zone 11 

Species information 13 

Ministerial Advisory Panel’s Terms of Reference 14 

Process 15 

Outline of process 15 

Issues raised/commentary 16 

Relevant statutory documents 18 

Cultural wellbeing 21 

Summary of issues raised 21 

Findings 21 

Matters arising (uncertainties, planning provisions) 21 

Panel’s views 22 

Commentary on key issues 22 

Economic wellbeing 25 


Findings 25 




Environmental wellbeing 34 


Findings 34 




Social wellbeing 41 


Findings 41 




Conclusion 49 

Afterword 49 

References 50 

Appendices 51 

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Foreword 

The Hon Phil Heatley, Minister of Fisheries and Aquaculture, has requested our Panel to 

advise him on the suitability of a 300-ha site in the Hauraki Gulf west of Coromandel township 

for the farming of finfish. If such a project proceeds, it will provide the first opportunity to test 

the commercial viability of finfish farming (other than salmon) in New Zealand. 

Until now the only finfish species farmed in New Zealand is King or Chinook salmon acclimatised 

in New Zealand from the Pacific coast of North America since the late 19 th century. It is only 

farmed in the South Island – summer water temperatures in otherwise suitable waters in 

the North Island are too warm for salmon to thrive. One indigenous species, the Greenshell 

Mussel TM , is the mainstay of aquaculture in New Zealand. The other species farmed is the 

ubiquitous Pacific oyster. 

Aquaculture is a rapidly expanding activity around the world. As world population rushes 

towards 7 billion – expected to be by late this year according to the United Nations Population 

Division, and estimated to reach 9 billion by around 2045 – it is interesting to look at trends 

in fish production. According to the United Nations Food & Agriculture Organization (FAO) 

world-wild capture fisheries production peaked in 1996 at 95.1 million tonnes. By 2008 it had 

declined to 90.8 million tonnes. On the other hand, world aquaculture production increased 

from 33.8 million tonnes in 1996 to 68.3 million tonnes in 2008 – in other words, it more than 

doubled. If those extra 2 billion people are to eat seafood, in a world where wild catches 

may well continue to decline, then aquaculture production might need to double in the next 

35 years. Can New Zealand contribute to achieving this increased level of production? 

New Zealand aquaculture production has increased from 28,855 tonnes in the year 2000 to 

41,014 tonnes in 2009. Aquaculture export earnings have increased from $212.7million to 

$279.4 over the same period. While both the industry and successive governments share and 

have shared the goal of achieving export earnings from an economically and environmentally 

sustainable aquaculture industry of $1 billion per annum by 2025, the industry does not believe 

this can be achieved without diversifying into farming other finfish species. 

At present the farming of finfish species in New Zealand appears to be trapped in a circular 

debate. On the one side there is the demand that no development proceed until it can be 

proved that no harm can result. On the other side are would be proponents who are not able 

to prove their case because they cannot establish a commercial-sized operation to reveal the 

impacts of such an operation and demonstrate that those effects can be avoided or mitigated 

as required by the RMA. While the question referred to us for inquiry and report is expressed 

in plainer terms it amounts to this: should the Minister, like Alexander, cut the Gordian knot. 

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Acknowledgements 

We would like to thank and acknowledge officials at the Aquaculture Unit – Ministry of 

Fisheries, Ministry for the Environment, Department of Conservation, Ministry of Economic 

Development, and Te Puni Kōkiri, for their assistance in providing advice that helped shape 

the development of this report. 

We also thank and acknowledge all those persons from various groups and organisations who 

gave up their time to speak to us during our familiarisation visits and Panel hearings. 

Any errors or omissions remain ours. 

The Hon Sir Douglas Kidd 

Chairman 

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Recommendations 

Recommendation 1 

The issue: The site is appropriate 

The site appears to be appropriate for finfish farming and should be made available, as soon 

as possible, for consent applications. 

The recommendation 

The farming of finfish species (other than salmon) needs to be validated in New Zealand 

conditions. Space needs to be made available now, so that commercial finfish farming can be 

demonstrated in a strategic and planned manner. This includes using adaptive management 

to ensure any finfish farming activities are done within environmental limits. 

We use the features of adaptive management that were considered in the Environment Court 

in the case of Crest Energy Kaipara Limited v Northland Regional Council (Decision A.130/09). 

In this context, features of adaptive management are: 

(i) that stages of development are set out; 

(ii) the existing environment is established by robust baseline monitoring; 

(iii) there are clear and strong monitoring, reporting and checking mechanisms so that steps 

can be taken before significant adverse effects eventuate; 

(iv) these mechanisms must be supported by enforceable resource consent conditions 

which require certain criteria to be met before the next stage can proceed; and 

(v) there is a real ability to remove all or some of the development that has occurred at the 

time if the monitoring result warrant it. 


The issue: Proactive measures to ensure the space is used 

Even if the zone is created, the Panel recognises that proactive measures may be required to 

ensure that the space is actually used. 


The government, through the Aquaculture Unit, will need to work with industry, Māori, 

Environment Waikato and local government to ensure that the space is used. Finfish 

farming in this zone will be a high-risk venture, which will require a large amount of capital 

investment upfront. 

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The issue: Boat safety issues can be addressed 

Potential boat safety issues resulting from the creation of the zone can be mitigated. 


Once the zone is put in place there will be a lag time (the consent application period) when an 

education programme/communication strategy should be put in place to inform Hauraki Gulf/ 

Coromandel users about the new zone. Maritime New Zealand will be asked to provide the 

necessary chart and GPS updates during that period. 

The Panel does not accept the reason that having poor navigation equipment on board 

vessels is a valid reason to stop development. Vessel owners/skippers have particular 

responsibilities for the safety of their craft at all times and must demonstrate duty of care to 

exercise those responsibilities in an appropriate manner. 


The issue: Māori involvement 

The Panel recognises the significance of Tikapa Moana to Hauraki iwi and the particular 

relationship Ngāti Tamaterā and Ngāti Maru have to the proposed zone. 

Well-managed, environmentally sustainable aquaculture has the potential to make a significant 

contribution to the wellbeing of Hauraki iwi, hapū and marae. 

The Panel accepts both the need for, and the right of, Māori, to be fully involved with finfish 

farming development. 


To meet the concerns of local tāngata whenua over consultation matters the Aquaculture Unit 

should engage local Māori in face-to-face meetings on the issue of finfish farming. 

The creation of the zone represents a significant opportunity for Hauraki iwi to become involved 

in finfish farming. This opportunity should be actively explored. 


The issue: Next steps 

If the proposal is to be progressed, changes will need to be made to Environment Waikato’s 

Regional Coastal Plan. As the consultation document noted, there are several options available 

to the Minister for pursuing such changes. 

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The Panel is of the view that a plan change that simply lifts the current prohibited status of 

aquaculture in the proposed zone would not go far enough. Rather, detailed plan objectives, 

rules and policies are required in respect of matters such as ensuring an adaptive management 

approach is taken to the development of aquaculture in the zone. Given the need to ensure 

that the space is used it is not unreasonable to expect that the plan change would include clear 

directions on: 

• the allocation method to be employed, including in respect of implementation of the Māori 

Commercial Aquaculture Claims Settlement Act 2004 

• the levels of site occupation 

• the types of structures permitted (including ancillary buildings) associated with finfish farming 

• the farming of other species (such as, mussels, seaweed). 

The drafting of such planning measures will be a challenging task, and one that would benefit 

from appropriate levels of input and scrutiny by key stakeholders. At the same time, this 

proposal will need to be advanced relatively quickly if it is to contribute to achieve the goal of 

a thriving and sustainable aquaculture industry with an annual turnover of $1 billion by 2025. 


If the Minister accepts the recommendation that this proposal should be advanced, he will need 

to carefully weigh the options for changing the Waikato Regional Coastal Plan. In determining 

which route might be taken to implement such a plan change, we believe the Minister must 

weigh the dual objectives of expediting the proposal and providing an appropriate level of input 

and scrutiny by key stakeholders. In our view, such input and scrutiny will play an important 

role in avoiding time-consuming, unintended consequences. 

The Panel holds the view that the intent of recommendations 14 and 15 of the Aquaculture 

TAG 1 should be revisited with a view to enabling the parallel processing of plan changes and 

resource consents and allow the applicant some priority for space but not so as to impact on 

rights under the Māori Commercial Aquaculture Claims Settlement Act 2004. 

1 Re-Starting Aquaculture – Report of the Aquaculture Technical Advisory Group, 15 October 2009 

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Map of SE Hauraki Gulf showing proposed Coromandel Marine Farm Zone 

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Introduction 

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To develop our aquaculture industry in New Zealand we need to take steps to culture species 

that will, in the long term, be of high value on the international market. Two species that are of 

particular interest at this time are hapuku and kingfish. Research has been undertaken on the 

potential to sea-cage farm both species in New Zealand and suitable zones are now needed 

to validate the commercialisation of these species. 

The Aquaculture Unit has recently engaged with tāngata whenua and the public to amend 

the Waikato Regional Coastal Plan to remove the prohibition on new aquaculture within a 

defined 300-ha zone in the Hauraki Gulf/Tikapa Moana (known as the proposed Coromandel 

Marine Farming Zone). Under the proposal, resource consent applications for fish farming 

(principally hapuku and/or kingfish) could be lodged in the proposed zone. Such resource 

consent applications would then be considered under the Resource Management Act 1991 

(RMA) and the Fisheries Act 1996. 

A three-member Ministerial Advisory Panel (‘the Panel’) was established to provide government 

with independent recommendations on the proposal. The role of the Panel is to (i) oversee the 

consultation process and (ii) provide the Minister of Fisheries and Aquaculture with independent 

advice on the costs and benefits to establish the proposed Coromandel Marine Farm Zone. 

The Panel is chaired by Hon Sir Douglas Kidd. The other members of the Panel are 

Mark Farnsworth and Justine Inns. The Panel’s Terms of Reference are set out on page 14. 

This report provides the Panel’s findings and recommendations on the proposal to establish 

the proposed Coromandel Marine Farm Zone. This advice is prepared in light of submissions 

received; oral presentations from submitters during the public hearing process; discussions 

with tāngata whenua, relevant groups and organisations, and government officials; and all 

relevant reports and documents. 

This report is structured as follows: 

• description of the proposal – includes site description and species information 

• the Panel’s Terms of Reference 

• the consultation process – includes a description of the public consultation process, and 

identifies and responds to concerns raised in submissions in respect to this process 

• consideration of the proposal in accordance with the concepts of cultural wellbeing, 

economic wellbeing, environmental wellbeing, and social wellbeing 

• conclusion 

• afterword 

• appendices. 




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In writing this report the Panel is aware of the Government’s commitment to facilitate the 

development of aquaculture in New Zealand, the need to ensure sustainability, and to maintain 

a healthy aquatic environment. The Panel also recognises that the Government supports 

the aquaculture industry’s goal to establish a $1 billion aquaculture industry by 2025 that is 

managed within environmental limits. 

Proposed Coromandel Marine Farming Zone 

The proposed Coromandel Marine Farming Zone is shown in the map on page 9. The Panel 

notes that the locality and dimensions of both the proposed zone and the Wilsons Bay marine 

farm site are illustrated using the same scale. 

The zone covers an area of 300 ha and is rectangular in shape with its eastern and western 

boundaries being 1 km in length, and its northern and southern boundaries being 3 km in 

length. The zone has a water depth of 30 to 40 m. 

The proposed zone is 13.5 km from the Coromandel Township and 4.9 km from Waimate 

Island. The zone is not visible from shore. The zone is situated away from major constraints 

on aquaculture, such as commercial shipping and ferry routes, aesthetic values, recreational 

boating anchorages, and recreational fishing hotspots. Shifting the zone further eastwards, as 

urged by one submitter, towards the coast would likely increase interference with recreational 

boating activity moving in a north-south direction along the Coromandel coastline. 

Since the panel hearings, NIWA has completed a qualitative site investigation 2 of the proposed 

zone using side-scan sonar, towed underwater video, and epibenthic sled. The survey 

indicates the sea floor is comprised of soft mud with various quantities of broken shell and 

shell fragments. The most conspicuous fauna within the zone is heart urchins, olive shells, 

and the invasive clubbed sea squirt Styela clava. The survey recorded “two live scallops and 

6 empty scallop shells” within the proposed zone. NIWA reports that the “proposed zone does 

not support populations of species with high conservation or fisheries value”, and that there are 

“no obvious ecological reasons why the site would be unsuitable for finfish farming”. NIWA’s 

report has been posted on the Ministry of Fisheries website. 

In the absence of the new NIWA report, submitters speculated as to the benthic conditions and 

species present. The Panel notes that NIWA’s findings give no cause to not proceed further 

with our consideration of other issues. We are aware that a site specific benthic and species 

assessment will be required in connection with any RMA consent application. 

The zone is well flushed and is influenced by wind and tidal patterns. Currents are dominated 

by tidal cycles with median speeds ranging between 2 cm and 20 cm per second. The direction 

of water flow (particularly surface water) typically reflects wind direction. 

2 Grange, et.al., 2011 




As such, water flow tends to move north during strong southwest winds and south during strong 

northeast winds. Wind direction in the proposed zone is typically southwest and northeast to 

southeast. Model simulations suggest that tidal currents flow southwards into the Firth of Thames 

below 10 m water depth and northward out of the Firth of Thames at the surface. 3 

Environment Waikato advises that it is currently developing a hydrodynamic model for the Firth of 

Thames and southeast Hauraki Gulf (and will include the proposed zone). This model will better 

inform the effects of the proposed fish farming activities on the region’s coastal environment, and 

will assist the Aquaculture Unit, Environment Waikato, and the aquaculture industry to develop an 

appropriate management programme to mitigate marine farming effects (including the proposed 

finfish farming activities). 

The long axis of the zone is located across these currents, and is largely sheltered from oceanic 

swells by Coromandel Peninsula and benefits from some shelter from Waiheke and Ponui islands 

to the west. Waves within this region are generally limited to around 0.5 to 0.6 m high (with wave 

periods between 3 and 5 seconds); however, larger waves are experienced during storm events. 

Several submitters stated that the proposed zone experiences 3 to 4 m high swells particularly 

when northeast conditions have set in. NIWA advises that the nature of wave action within the 

region means that any finfish farm would typically use 20 to 50 m diameter plastic circle cages 

that are best suited for the local oceanographic conditions. 

To ascertain the nature of potential environmental effects associated with the proposed Coromandel 

Marine Farming Zone, the Aquaculture Unit commissioned NIWA (prior to constitution of the 

Panel) to conduct an assessment of relevant production and ecological considerations of the 

proposal, 4 as well as the potential cumulative effects associated with Coromandel and Wilsons 

Bay fish farming. 5 

The NIWA reports have been independently peer reviewed by the Cawthron Institute and the 

Ministry’s Aquatic Environment Working Group. The Aquaculture Unit also commissioned the 

New Zealand Institute of Economic Research (NZIER) to provide information on the potential 

economic impacts of the proposal. 

A number of submissions confirmed the proposed zone provides a good site for sea-cage finfish 

farming, as it is situated in a deep, well-flushed area with tidal flow, and sufficiently away from 

shore to prevent any visual impacts. The Panel considers the proposed zone is a suitable site for 

the scale of farming of hapuku and/or kingfish as outlined in the proposal. 

3 Giles, 2011 

4 Zeldis et.al., 2010 

5 Broekhuizen, 2011 

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Species information 

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The industry has signalled a desire to commercially trial the farming of hapuku and/or kingfish 

within the proposed Coromandel Marine Farm Zone. 

Aquaculture New Zealand states that these two finfish species are within the top five 

aquaculture species that industry wishes to develop in New Zealand. It adds that New Zealand 

is well placed to develop premium-value, niche overseas markets for both species given their 

favourable texture and taste, and that they will be sustainably grown in the clean, healthy 

waters of the Hauraki Gulf. 

Hapuku is native and found only in the waters of New Zealand. The Panel notes that NIWA 6 has 

established a proof of concept for a hapuku production system at its Bream Bay Aquaculture 

Park and is presently assessing the performance of this species to provide product for market 

assessment. NIWA reports that it has developed F1 broodstock, further refined hatchery 

production techniques, evaluated nutrimental requirements, and fish health diagnostic and 

management techniques. 

Kingfish is a common fish species found throughout northern and central New Zealand, as 

well as Australia and the Pacific. Results from tagging programmes demonstrate that kingfish 

occasionally travel between the two countries. The Panel notes that NIWA 6 has developed a 

juvenile kingfish production system at its Bream Bay Aquaculture Park and has produced 350,000 

sea-cage ready juveniles. NIWA has also developed F1 broodstock, further refined hatchery 

production techniques and conducted comparative rearing trials in research pens at its Mahanga 

Bay research facilities. NIWA has commissioned a feasibility study on various marketing aspects 

of kingfish. 

The culture of kingfish is an expanding international aquaculture industry supplying the 

demand for high-quality fish products. A large yellowtail kingfish farming industry is developing 

in South Australia to fulfil domestic and overseas markets. A recent setback of this industry 

is believed to have been due to marketing issues. Hatcheries also supply large quantities of 

juvenile kingfish to marine farms growing southern bluefin tuna taken from the wild. Much of 

this industry focuses around Port Lincoln where there are many sea-cages dedicated to the 

production of this species. A closely related kingfish species is the basis of a major aquaculture 

industry in Japan, where wild caught juveniles are grown out in sea-cages. 

The Panel notes that domestication of hapuku and kingfish is now complete in New Zealand, 

and production arrangements are in place to produce sufficient numbers of juveniles to assess 

the commercial viability of finfish farming of these species. 

6 Zeldis et.al., 2010 




Ministerial Advisory Panel’s 

Terms of Reference 

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The Panel is appointed to oversee a public consultation process to consider a proposal to 

amend the Waikato Regional Coastal Plan. 

The broad functions of the Panel are to: 

• oversee the consultation process (including leading public hearings of submissions) to 

consider a proposal to amend the regional coastal plan for the Waikato region 

• consider other material made available on the scientific, ecological, economic, social and 

cultural aspects of the proposal 

• to report back to the Minister of Fisheries and Aquaculture on the outcome of this process 

and provide recommendations. 

The Panel shall also take into account any material provided by the Minister and the Ministry 

of Fisheries. This material may include: 

• the Government’s existing decisions on the proposed aquaculture legislative reforms 

• the Minister’s goal for aquaculture reform 

• previous aquaculture policy advice to the Minister 

• any relevant independent reports. 

Panel members are not appointed as advocates or representatives of a particular interest or 

sector group. Members are appointed because of their personal expertise and knowledge, and 

to provide independent advice. 

The Panel is to provide findings and recommendations in a written report to the Ministry’s Chief 

Executive by 25 February 2011 on proposals to amend the Waikato Regional Coastal Plan. 

The report is advisory, and the Minister and the Ministry will not be bound by the findings and 

recommendations of the Panel. 




Process 

Outline of process 

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The Aquaculture Unit released a public consultation document 7 on 17 December 2010. Closing 

date for submissions was 9 February 2011. 

This document was posted and emailed to a large number of relevant local, regional, and 

national stakeholder groups, as well as tāngata whenua. This document and supporting 

information was also posted on the Ministry of Fisheries website, and was accompanied with 

supporting media releases to inform the general public about the proposal and the availability 

of relevant information. 

Public notices were also placed in the New Zealand Herald, Waikato Times, Coromandel 

Peninsula Post, and Hauraki Herald on four separate occasions throughout the consultation 

period. In addition, a two-page feature on the proposal was placed in the Hauraki Herald on 

28 January 2011 to increase public awareness of the proposal and consultation process within 

the Auckland and Coromandel regions. 

A total of 77 submissions were received. The range of submitters was extensive ranging from 

individual members of the public and tāngata whenua, to regional and national stakeholder 

groups and organisations. A list of submitters is provided in Appendix 1. A summary of 

submissions is available on the Ministry of Fisheries website. 

Panel hearings were convened to provide an opportunity for submitters to directly discuss the 

proposal with the Panel. These hearings were convened as follows: 

• Auckland – 9 February 2011 

• Thames – 10 February 2011 

• Coromandel Township – 11 and 12 February 2011. 

All submitters who requested to meet with the Panel were accommodated during the four days 

of panel hearings. A list of speakers at each hearing is provided in Appendix 2. 

In addition, the Panel made two other visits to the Coromandel region. First, from 19 to 21 

January 2011 the Panel visited the area to become familiar with the region and its adjoining 

waters. As part of the first visit, the Panel visited the proposed Coromandel Marine Farm Zone 

and Wilsons Bay marine farm zone on 20 January 2011. 

The second visit on 8 February 2011 enabled the Panel to meet with Environmental Waikato 

councillors to discuss the Waikato Regional Coastal Plan. 

7 Consultation Document-Proposed Coromandel Marine Farming Zone (17 December 2010) is available from www.fish.govt.nz 




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During both visits the Panel also met with representatives from a number of groups and 

organisations to discuss the proposal and obtain relevant information. These included 

the following: 

• Mayor and senior representatives, Hauraki District Council 

• Mayor and senior representatives, Thames-Coromandel District Council 

• Environment Waikato 

• Hauraki Māori Trust Board 

• Coromandel Community Board 

• Coromandel Marine Farmers Association 

• Yachting New Zealand 

• Waikato Conservation Board. 

Issues raised/commentary 

A number of submissions raised concerns as to the inappropriateness of using the 

consultation document and associated planning considerations report 8 as a substitute to 

a plan change process. 

Royal Forest and Bird Protection Society of New Zealand Inc. stated: 

“The expected process of Plan Change through Schedule 1 to the RMA, which enables 

submissions and proper consideration of amended plan provisions is appropriate given 

the significance of the new proposal – not just the size and location of the zone, but the 

intention to facilitate sea cage finfish farming of native species.” 

The Panel notes that it is not the intention of this process to act as a substitute to a plan change 

process. The purpose of the Panel, as noted in the Terms of Reference, is to oversee the 

public consultation process and to recommend whether or not the provision of the proposed 

Coromandel Marine Farming Zone in the Waikato Regional Coastal Plan is appropriate. Based 

in part on these recommendations it is then up to the Minister of Fisheries and Aquaculture to 

determine if and how this will occur. 

Submissions also raised concerns about the consultation period, notably that it was too short 

and that it was inappropriate to consult over the Christmas period. 

Leigh Commercial Fishermen’s Association Inc. stated: 

“...many of the public that may be affected by this proposal would be enjoying a holiday 

break and unaware of this consultation.” 

8 Environment Waikato – Regional Coastal Plan. Proposed Coromandel Marine Farming Zone Planning Considerations, 

Aquaculture Unit , December 2010 




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The Panel holds the view that the consultation timeframe, an eight-week period which included 

Christmas and New Year, was more than adequate. This position is supported by the Hauraki 

Coromandel Development Group who stated: 

“...in the Coromandel, the best time to consult with the community is over the Christmas 

period. Consultation at other times might attract feedback from locals, but a significant 

portion of Coromandel ratepayers are absentee owners. Furthermore the Peninsula 

fills with holidaymakers, many of whom are fishermen or yachties from other parts of 

New Zealand. Hence undertaking consultation over this period has provided these 

stakeholders with the optimum awareness of the proposed 300 ha zone.” 

While the overlap between the close of submissions and the start of the Panel hearings due 

to time constraints was not ideal, the process was managed successfully and did not present 

any obvious issues. The Panel was informed that the resident population in the Coromandel is 

about 26,000, and this typically rises to 150,000 for about six weeks over the summer period. 

The Panel highlights that timing of the consultation process, and in particular local publicity 

relating to it, coincided with the peak in visitors into the region. 

Many of the submissions in opposition to the proposal noted that no zone should be created 

until further research is undertaken. 

Karen Doddrell, for example, stated: 

“Not enough research has been done to establish finfish farming in the Firth of Thames.” 

While Stewart Robinson stated: 

“…at this time there is insufficient evidence available to be confident that no harm to the 

marine environment and ecology of the zone and the Firth of Thames would eventuate 

from the proposal to establish a finfish farm at this location in the long term (decades).” 

The Panel is of the opinion that the use of an adaptive management regime (including staged 

development) will ensure that commercial finfish farming can be established in the proposed 

zone in a sustainable manner. We use the term ‘adaptive management’ in the sense approved 

of in the Environment Court in the case of Crest Energy Kaipara Limited v Northland Regional 

Council (Decision A.130/09). In this context, adaptive management means: 

Adaptive Management: an experimental approach to management or ‘structural learning by 

doing’. It is based on developing dynamic models that attempt to make predictions or hypotheses 

about the impact of alternative management policies. Management learning then proceeds by 

systematic testing of these models, rather than trial and error. Adaptive management is most 

useful where large ecological systems are being managed and management decisions cannot 

wait for final research results. 




Features of adaptive management are: 

(vi) that stages of development are set out; 

(vii) the existing environment is established by robust baseline monitoring; 

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(viii) there are clear and strong monitoring, reporting and checking mechanisms so that steps 

can be taken before significant adverse effects eventuate; 

(ix) these mechanisms must be supported by enforceable resource consent conditions 

which require certain criteria to be met before the next stage can proceed; and 

(x) there is a real ability to remove all or some of the development that has occurred at the 

time if the monitoring result warrant it. 

Crest Energy Kaipara Limited v Northland Regional Council (Decision A.130/09). 

Relevant statutory documents 

The relevant national and regional statutory documents with regard to the proposed Coromandel 

Marine Farming Zone are as follows: 

• Resource Management Act 1991 (RMA) 

• Hauraki Gulf Marine Park Act 2000 (HGMPA) 

• New Zealand Coastal Policy Statement 2010 (NZCPS) 

• Proposed Waikato Regional Policy Statement (RPS) 

• Waikato Regional Coastal Plan (RCP) 

This section provides a concise assessment of the consistency of the proposed zone with the 

relevant provisions of these documents. 

The purpose of the RMA is to promote the sustainable management of natural and physical 

resources. Part Two of the RMA underpins the manner in which the management of the use, 

development and protection of natural and physical resources is to be undertaken. It details 

those matters which are of national importance, which include the preservation of the natural 

character of the coastal environment, the maintenance and enhancement of public access to 

the coastal marine area, and the relationship of Māori and their culture and traditions with their 

ancestral lands, water, sites, waahi tapu, and other taonga. It is considered that the proposed 

Coromandel Marine Farming Zone is consistent with the purpose and principles of the RMA, 

as it will allow people and communities to provide for their economic wellbeing while sustaining 

the natural and physical resources and safeguarding the life-supporting capacity of the coastal 

marine environment. 

The HGMPA established the Hauraki Gulf Marine Park, with a purpose of integrating the 

management of the natural, historic, and physical resources of the Hauraki Gulf, its islands, 

and catchments. 




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Section 8 sets out the objectives of the management of the Hauraki Gulf. These objectives 

focus on the protection of the natural, historic, and physical resources and the life-supporting 

capacity of the Hauraki Gulf. They allow for the cultural and historic associations with the 

Hauraki Gulf, and the social, economic and recreational wellbeing of people and communities, 

to be maintained. The objectives of the HGMPA must be treated as a New Zealand coastal 

policy statement, except where there is a conflict with the provisions of the NZCPS. 

The proposed Coromandel Marine Farming Zone is located in an area which will ensure that any 

adverse effects of aquaculture activities on the cultural, historic and recreational associations 

with the Hauraki Gulf environment will be avoided or mitigated as much as possible, while 

providing for the establishment of finfish farming which will have a positive economic impact 

on the region. The actual establishment of the marine farms will be the subject of a full RMA 

process, which will require matters to be addressed in order to protect the life-supporting 

capacity of the marine ecosystem. As such, it is considered that the proposed Coromandel 

Marine Farming Zone is consistent with the objectives of the HGMPA. 

The NZCPS is a national policy statement under the RMA. The purpose of the NZCPS is to 

state policies in order to achieve the purpose of the RMA in relation to the coastal environment 

of New Zealand. Regional policy statements and plans must give effect to the NZCPS, and 

consent authorities must have regard to the relevant provisions of the NZCPS when assessing 

resource consent applications. 

The relevant objectives and policies of the NZCPS with regard to the proposed Coromandel 

Marine Farming Zone surround the safeguarding of the coastal marine environment, including 

the biological and physical resources, the ecosystem, coastal water quality, natural character, 

tāngata whenua values, recreation opportunities, and the opportunities for people and 

communities to provide for their social, economic and cultural wellbeing. 

As has been shown in the analysis of the provisions of the HGMPA, the establishment of the 

Coromandel Marine Farming Zone will provide for economic development in the region in 

a manner which safeguards the ecosystem, natural character, and cultural and recreational 

qualities of the surrounding coastal marine environment. As such, it is considered that the 

proposed Coromandel Marine Farming Zone is consistent with the objectives and policies of 

the NZCPS. 

The proposed Waikato Regional Policy Statement and the Waikato Regional Coastal Plan 

provide for the integrated management of natural and physical resources at a regional level in 

Waikato. The RPS provides a general policy framework intent, while the RCP deals with specific 

objectives, policies and rules to manage the allocation and use of coastal resources. The 

objectives and policies of these documents focus on the protection of the coastal environment, 

including the mauri and health of marine waters, indigenous biodiversity, amenity, tāngata 

whenua relationship with the coast, and natural character. 




›› 20 

Objective 6 of the RCP provides for marine farming which is developed in an efficient and 

sustainable manner and which avoids adverse effects on the coastal environment as far as 

practicable. As has been discussed in the preceding paragraphs, it is considered that the 

proposed Coromandel Marine Farming Zone is consistent with the objectives and policies 

contained in the RPS and RCP. 




Cultural wellbeing 

Summary of issues raised 

›› 21 

• Any activity in Tikapa Moana (Hauraki Gulf) should be undertaken in a manner that 

recognises and upholds the kaitiakitanga of Hauraki iwi. 

• The Crown’s obligations under the Māori Commercial Aquaculture Claims Settlement Act 

2004 must be delivered in a manner that is effective and appropriate. 

• The proposal has the potential to impact on customary fisheries. 

• Issues in respect of ownership of foreshore and seabed create uncertainty. 

• The natural character of the Hauraki Gulf is integral to the culture and identity of all 

New Zealanders. 

Findings 

• The Panel recognises the significance of Tikapa Moana to Hauraki iwi and the particular 

relationship Ngāti Tamaterā and Ngāti Maru have to the site in question. 

• It is understood that work is currently underway on how the Crown’s obligations under 

the Māori Commercial Aquaculture Settlement Act 2004 should be given effect. Those 

obligations will certainly apply to the proposed zone. 

• The Panel did not receive any particular evidence of potential effects of the proposal 

on customary fisheries, other than general concerns of the risk that farmed indigenous 

species might present to wild fisheries (these issues are addressed in the Environmental 

wellbeing section). 

• The position of Hauraki iwi regarding ownership of the foreshore and seabed of Tikapa 

Moana was made very clear. It is unfortunate that legislation on the foreshore and seabed 

is being considered by Parliament at the same time as this proposal is being considered, 

but the Panel does not believe that any resulting uncertainties present a major barrier to 

the proposal. 

• The Panel acknowledges that many New Zealanders, particularly those living in 

communities on the shores of the Hauraki Gulf, have a cultural and spiritual affinity with 

the Gulf and believe that both its natural character and the recreational opportunities it 

provides to those people and the boating population of the surrounding areas should be 

maintained as far as possible (these issues are addressed in the Social wellbeing section). 

Matters arising (uncertainties, planning provisions) 

• Planning objectives in respect of the zone should include the aim of recognising and 

upholding the kaitiakitanga of Hauraki iwi, particularly Ngāti Tamaterā and Ngāti Maru. 




›› 22 

• To the extent that planning provisions for the zone will include a mechanism for allocation 

of the right to apply, they should provide a means of allocating space to Hauraki iwi that is 

consistent with the Māori Commercial Aquaculture Claims Settlement Act 2004. 

Panel’s views 

The Panel holds the view that the full inclusion of Hauraki iwi – particularly those holding 

mana moana over the proposed zone – is not only appropriate but crucial to the success of 

this proposal. 

Commentary on key issues 

Kaitiakitanga 

The Panel was left in no doubt as to the significance of Tikapa Moana to Hauraki iwi, and were 

advised that Ngāti Tamaterā and Ngāti Maru strongly assert their mana moana over the site 

of the proposed zone. 

In evidence to the Waitangi Tribunal hearing the claims of Hauraki iwi in relation to the Hauraki 

Gulf Marine Park Act 2000, Toko Renata Te Taniwha described the application of the concept 

of kaitiakitanga to Tikapa Moana: 

“The key is that our relationship with Tikapa Moana is about a balance between rights 

and obligations. 

“We consider that our obligations as kaitiaki extend, perhaps most importantly, to future 

generations. This is about passing down our traditions and tikanga with regard to Tikapa, 

in particular how Tikapa Moana should be treated, and how we can ensure that the 

generous gifts of Tikapa Moana will continue to be available for those future generations.” 

Hauraki iwi, hapū and marae have long recognised the potential that well-managed, 

environmentally sustainable aquaculture has to contribute to the wellbeing of their communities. 

For that reason, all have been involved in the development of the industry in Tikapa Moana 

since its earliest days. It is acknowledged that finfish farming will bring new challenges in the 

application of the principles of kaitiakitanga, but Hauraki iwi submitters expressed a cautious 

optimism about its potential. 

As it was explained to the Panel during the site visit, the dearth of land available to the iwi 

forces them to look to Tikapa Moana as the foundation of their tribal asset base, just as their 

tūpuna relied on its rich resources for their sustenance and survival. 

Objective 2.4 of the Waikato Regional Coastal Plan requires that those administering the 

plan “recognise and provide for the special relationship which tāngata whenua have with the 

coastal environment”. The Panel believes that the proposal is so significant to Hauraki iwi and 

to Tikapa Moana that specific measures should be put in place to ensure that the kaitiakitanga 

of Hauraki iwi is recognised and upheld. 




Māori Commercial Aquaculture Settlement 

›› 23 

The Māori Commercial Aquaculture Claims Settlement Act 2004 guaranteed iwi a representative 

20% of all new aquaculture space created in the future. 

The Hauraki Māori Trust Board told us: 

“The protection of the aquaculture settlement to Māori in the creation of any new marine 

farming zone is paramount.” 

Te Ohu Kaimoana Trustee Limited went further and challenged the Panel to: 

“...provide helpful advice to the government and all participants on the best means of 

implementing the Settlement assets associated with this zone that can both assist iwi 

and the development of aquaculture in the region.” 

There is no question that the settlement must be provided for and the Panel understands 

Te Ohu Kaimoana Trustee Limited’s concern. We recognise, however, any provision for the 

settlement within the proposed zone will need to allow for proposed new settlement delivery 

mechanisms (at the time of this report those delivery mechanisms are still being consulted on). 

We also recognise that the settlement will be delivered on a regional basis. Because of this, 

any provision for delivery for the settlement will need to take into account the interests of all iwi 

within the settlement region (and note that this will be broader than the proposed zone itself). 

Customary fisheries 

The Panel is not aware of any specific impacts on customary fisheries from the proposal, 

though Mr Tewi Nichols of Te Rūnanga a Iwi o Ngāti Tamaterā advised us of a particularly 

important red flounder and other taniwha that inhabit the area. 

The Panel was advised of applications affecting the area of the proposed zone under the 

Fisheries (Kaimoana Customary Fishing) Regulations 1998 which are under dispute. It does 

not appear that the creation of the proposed zone will materially affect those applications. 

The Hauraki Māori Trust Board advised that a Pātaka system operates in respect of iwi, hapū 

and marae-owned mussel farms, to provide kaimoana to iwi members and the wider community, 

while easing pressure on depleted wild stocks. The Hauraki Māori Trust Board confirmed that 

iwi involvement in any finfish farming proposal could include a similar component. 




Foreshore and seabed 

›› 24 

Te Rūnanga a Iwi o Ngāti Tamaterā reminded the Panel of the famous Petition of Tanumeha 

Te Moananui and others to Parliament in 1860: 

You the Government have asked for the gold of Hauraki; we consented. 

You asked for a site for a town; you asked also that the flats of the sea of Kauwaeranga 

should be let; and these requests were acceded to. 

And now you have said that the places of the sea, which remain to us, will be taken. 

O friends, it is wrong, it is evil. 

Our voice, the voice of Hauraki, has agreed that we shall retain the parts of the sea from 

high-water mark outwards. 

Hauraki iwi stand by these words in 2011 as staunchly as they did 150 years ago. 

The Panel believes that the proposal can proceed without prejudice to this position. 




Economic wellbeing 


Site attributes 

Positive attributes 

›› 25 

• Output from the finfish farm has the potential to contribute significantly to New Zealand’s 

economic wellbeing – regionally and nationally (for example, through increased 

employment, tax revenue). 

• Significant potential to contribute to Māori economic wellbeing. 

• The multiplier effect associated with finfish farming will provide opportunities for a wide 

range of related activities, such as trucking and servicing industries. 

• A new industry will provide the opportunity for innovation. 

Negative attributes 

• Disease outbreak from the farm could have an adverse impact on wild fisheries. 

• The creation of the zone will impact on existing commercial fishing by effectively removing 

300 ha of fishing area (for example, snapper, flatfish, and scallops). 

Other matters 

• New and improved infrastructure may be required to support a new industry. 

• There is potential for both positive and negative implications for tourism. Fish farms could 

become a visitor attraction in their own right. A significant increase in truck movements on 

the coast road could be a negative. 

• There are non-market effects to be considered such as the possible loss of fisher/boating 

numbers due to a reduced wild-fish fishing area. 

Findings 

• Finfish farming has the potential to make a major contribution to New Zealand’s 

economic wellbeing. 

• It needs to be recognised, however, that there is a potential for benefits to move away 

from the Coromandel Peninsula, specifically to the Auckland area (port and airport) or that 

the economic benefits could be shared between regions. The maximisation of benefits 

to the local district/region will require a commitment from both the regional council and 

district councils. 

• The farming of hapuku and kingfish has the potential to play a major role in the aquaculture 

industry achieving its $1 billion target by 2025. If this target is to be reached then new 

space will have to be allocated to finfish farming. 




›› 26 

• Adaptive (including staged) development will be an important part of any new commercial 

development. The steady progress of achievement of set environmental monitoring way- 

points and the consequent adjustment of operational criteria to deal with issues that arise 

will help to generate and underpin public confidence. 

• Impacts on fishing are controlled by the Undue Adverse Effects test in the Fisheries 

Act 1996. 

• There are a range of issues and potential solutions regarding infrastructure that need to 

considered. Councils are aware of infrastructure constraints and are moving to address 

them. This may require some central government support. It seems, however, highly 

probable that the expansion of mussel farming in the Wilsons Bay zone (both A & B) will 

drive increased landing/shore handling capacity before any finfish operation commences. 


• There is a need for central, regional, and local government, as well as communities to 

work together to make this work. 

• There is a need for industry to work together, for example, a consortium approach that 

includes Māori/iwi participation. 

• Māori/iwi must be given opportunity to be involved at initial stages of industry’s development/ 

involvement. The right to develop is assured to Māori by the principles of the Treaty of 

Waitangi and entitles Māori to determine the extent of their participation unconstrained 

by the settlement. The Māori Commercial Aquaculture Claims Settlement requirements 

should not to be seen as the limit of Māori involvement. 

• Clear guidance is necessary in allocation methods to ensure the best players are involved. 


The Panel holds the view that the commercial viability of finfish farming needs to move from the 

extrapolation of overseas data and desk exercises to a commercial operation in a New Zealand 

situation to validate the commercial viability of finfish farming (other than salmon) and assess 

all of the positive and negative impacts. 

Clear plan rules should be developed for the zone which specify a strict ‘use or lose’ approach. 

Applicants must be prevented from banking ‘sea-space’. If the project fails for any reason the 

zone will cease to exist and the coastal permits will be cancelled without compensation. 

The matter of foreign ‘ownership’ needs to be addressed. There are strict controls on foreign 

ownership of commercial finfish quota. Starting to farm Quota Management System (QMS) 

finfish species should not undermine those controls. Commercial finfish farming should adopt 

a similar approach as the QMS. 




›› 27 

Foreign ownership of marine farms has not, to date, been a public issue. It is clear that Hauraki 

Gulf/Tikapa Moana is culturally significant to iwi and, indeed, nearly half of New Zealand’s 

population. The willingness of all these New Zealanders to, at best, tolerate fish farms in such 

a special place could be sorely tested if they felt their enjoyment of it was being reduced so 

that foreigners could benefit. 

Government should, at the appropriate time, require some payment in recognition of the fact 

that a business is being conducted in public space. Free use of this space once businesses 

are established and have positive cash flow could not be justified. 

Government working through the Aquaculture Unit, in conjunction with Environment Waikato, 

needs to address the issues of space allocation to ensure that space is uplifted and that 

Māori are active participants. In this instance a weighted attribute method of allocation may 

be appropriate. The Panel is clear that a highest bid tender/auction is not the best option. 

The Panel believes that consideration should be given to the South Australian Department 

of Primary Industries approach to space allocation and tenure, having regard to the need to 

implement the Māori Commercial Aquaculture Claims Settlement Act 2004. 


Economic considerations of the proposed zone 

A common theme in the submissions on the topic of economic benefits is that finfish farming 

has the potential to contribute significantly to New Zealand’s economic wellbeing. 

The Thames-Coromandel District Council’s submission noted: 

“The development of a $100+ million finfish industry will create jobs and economic 

development, and assist with diversification of the economic base on the Peninsula.” 

A E Ward in his submission suggested: 

“…the nation generally must embrace any new ventures to boost the economy and 

exports.” 

NZIER 9 in their June 2010 analysis of the Net Economic Benefit of aquaculture growth (mainly 

oyster, salmon and mussels) in New Zealand concluded: 

9 NZIER, 2010 

“We have confirmed using comprehensive and robust economic modelling framework that 

there are significant NEBs to industry and New Zealand economy as a whole from an 

expansion of aquaculture between now and 2025.” 




Mike Burrell of Aquaculture New Zealand noted the following: 

›› 28 

“In order to guide the implementation of the New Zealand Aquaculture Strategy – 

which is to sustainably grow the sector to a Billion Dollars per annum by 2025 – AQNZ 

commissioned a study by Ernst and Young 10 to estimate; 

whether the goal was feasible in the timeframe; and 

where the focus should be placed to achieve this goal. 

The conclusion of the study was: 

- That the $1 billion goal by 2025 cannot be achieved without new space being made 

available for high value species (particularly finfish); and 

- The best species for achieving this in the short to medium term were Kingfish and 

Hapuka.” 

NIWA’s December 2010 11 report concluded that: 

“Financial analysis indicates the production of between 4000 and 8000 tonnes of Kingfish 

and/or 2000 or more tonnes of hapuku is required to achieve economic sustainability with 

these species. Production at these levels would generate Net Present Value of at least 20%. 

Production of 8000 tonnes of live weight (6900 tonnes HOGG [head off, gutted and 

gilled] equivalent) of kingfish per annum will generate an estimated NZ$78 million p.a. 

in gross farm-gate revenue and a total economic benefit of NZ $135 million p.a., while 

4000 tonnes of live weight (3450 tonnes HOGG equivalent) of hapuku production per 

annum will generate an estimated NZ$80 million p.a. in gross farm-gate revenue and a 

total economic benefit of NZ$138 million p.a. 

Production of 4000 tonnes live weight can be anticipated to generate 210 direct full-time 

equivalent positions and 242 indirect full-time equivalent positions for a total of 452 full- 

time equivalents positions, while 8000 tonnes live weight can be anticipated to generate 

420 direct full-time equivalent positions and 484 indirect full-time equivalent positions 

for a total of 904 full-time equivalents positions.” 

A November 2009 report 12 commissioned by the Waikato Governance Group of New Zealand 

Trade and Enterprise focused its attention on the aquaculture potential in the Waikato region. 

The report concluded that: 

“One of the greatest potentials for the development of aquaculture both regionally and 

nationally lies in finfish farming. 

10 Ernst & Young: New Zealand Aquaculture: Industry Growth Scenarios, 10 September 2009 

11 Zeldis, et.al., 2010 

12 Aquaculture Potentials in the Waikato Region A report prepared for New Zealand Trade and Enterprise Waikato 

Governance Group by StellarCom Consultants November 2009 




›› 29 

“Aquaculture offers the Waikato region a significant slice of the $1 billion target in 

shellfish and finfish aquaculture predicted by 2025.” 

Nita McNeil in her submission in support of the zone voiced her opinion: 

“I would like to make a submission in favour of the proposed Coromandel Marine 

Farming Zone primarily on the basis of the positive economic and employment benefits 

it could bring to the region.” 

The Hauraki Coromandel Development Group in addressing potential economic impacts in its 

submission pointed out: 

“The development of a finfish industry has the potential to bring jobs and long-term 

export growth to a rural area which needs employment opportunities for current and 

future generations.” 

By way of contrast, a common thread of those submitting in opposition of the proposed 

zone was the uncertainty of the economic analysis, for example, Mike Fabish for Fisheries 

Consultancy Services Limited offered this view: 

“The proposal should not be approved unless it can be established beyond reasonable 

doubt that the activity can operate profitably.” 

Stewart Robinson pointed out that: 

“The uncertainty of the economic analysis is recognised by the Aquaculture Unit…” 

Leigh Commercial Fishermen’s Association were blunt in their assessment noting that 

economic potential stated in the NIWA report on commercialisation of hapuku and kingfish 

farming is unrealistic and overly optimistic. 

Observations were made and questions posed, in the submissions, about the negative 

economic impacts of the zone on commercial fishers. There were two principal issues raised: 

(1) the exclusion of commercial fishers from the zone and (2) the potential impacts of disease 

and parasites associated with finfish farming on wild fish populations. 

In terms of excluding commercial fishers the Coromandel Scallop Fisherman’s Association 

pointed out that: 

“…the proposal seeks to remove 300 hectares of scallop grounds from the QMS which 

is currently fished by our members.” 

Pat Baskett in her submission stated: 

“I believe that the economic benefits of farming finfish are likely to be short-lived. In the 

long term, aquaculture in its present forms can only contribute to the tragic depletion of 

marine resources which many experts consider is set to occur within 40 years.” 




›› 30 

David Taipari, in his verbal submission, stressed that Māori had an upfront right to be 

economically involved in finfish farming in this zone. 

Panel observations 

Aquaculture development – particularly finfish farming – has the potential to contribute 

significantly to New Zealand’s economic wellbeing. 

Finfish farming of selected species (such as, kingfish and hapuku 13 ) has the potential to make 

a considerable contribution to any future aquaculture development. 

The economic assessments have been based on potential rather than hard data for species 

indicated. As a result there is uncertainty as to the validity of any conclusion either positive or 

negative. A true economic assessment can only be made through a project that validates the 

commercial viability of finfish farming in a New Zealand situation. 

The economic potential of the zone will only be realised if it is used. Given the large sunk setup 

capital required, the way space is allocated will need to be carefully managed. Clear guidance 

will be required on the allocation method that is adopted. Government, through the Aquaculture 

Unit, may need to accept that they have a role to act as a facilitator to bring parties together to 

form a consortium (including iwi) to undertake development. 

The Commercial Scallop Commercial Fisherman’s Association did not provide any information 

to the Panel as to their catches in the vicinity of the proposed zone. The New Zealand Inshore 

Fishing Industry Council stated that it did “not consider it is the obligation of the inshore 

fishing industry to produce information on the effects of the proposed marine farming zone 

and activities of commercial fishing and fisheries resources in response to this consultation 

document.” We find NIWA’s latest advice that they saw two live scallops during their video tows 

as indicating that the proposed zone is most unlikely to support scallop fishing. 

The proposed zone is situated within the Coromandel (SCA) commercial fishery. A map 

showing the boundaries of this fishery and relevant fisheries statistical areas is on page 31. 

13 NZIER: Value of kingfish and hapuku farming – Preliminary analysis, Report to Ministry of Fisheries, 17 December 2010 




›› 31 

Map showing Coromandel (SCA CS) Quota Management Area. Fisheries statistical areas 

and proposed Coromandel Marine Farming Zone (red) are also shown. 

The fishery has a total allowable commercial catch (TACC) of 22 tonnes. The Panel notes 

that SCA CS commercial fishers reported a total estimated catch of 200 kg of scallops from 

fisheries statistical area 2X (which incorporates the proposed zone) during the last five fishing 

years. In comparison, most estimated catches are reported from fisheries statistical areas 2L, 




›› 32 

2R, and 2W (refer to map – shown in grey). There are no estimated catches of scallops from 

statistical area 2X for the current (2010-11) fishing year. Accordingly, the Panel considers the 

proposed zone will not have a significant impact on the SCA CS fishery. 

We note that the impact on commercial fishing will be handled by the Undue Adverse Effects 

on Fishing process. 

Allocations by weighted attribute tendering 

Councils have considerable experience is using tender processes for the purchase of goods 

and services. These typically use a weighted attribute system to balance the consideration 

of cost, technical expertise, track record and factors. A similar system could be established 

to assess tender applications for fish farming. Some work has been carried out by Northland 

Regional Council when preparing a system for considering invited private plan changes. 

The South Australian Department of Primary Industries sets up a tenure allocation board 

to judge applications. The criteria considered by the board: 

• nature of the proposal 

• relevance of the proposal to government policy and planning documents 

• economic benefit to the region 

• technical capacity 

• business capacity 

• environmental management capacity 

• regional and social benefits. 

Environment Waikato staff hold the view that the South Australian system could be 

adapted into a weighted attribute tender and this would be more appropriate than a simple 

cash tender. 

Infrastructure requirements 

It was very evident that the provision of infrastructure is a key issue being faced at both the 

district and regional levels. The Stellar Consultant’s November 2009 report noted infrastructure 

was one of the key challenges facing Waikato aquaculture. 

Ben Dunbar-Smith in his report 14 for the Hauraki-Coromandel Development Group 15 addressed 

the issues and option for wharfing infrastructure to support the Coromandel aquaculture industry. 

14 Ben Dunbar-Smith: Wharfing Infrastructure Discussion Document, Hauraki-Coromandel Development Group, November 2010 

15 Hauraki-Coromandel Development Group is a joint of committee of the Hauraki and Thames Coromandel District Councils 




›› 33 

Local government is actively addressing the infrastructural issue. The Thames-Coromandel 

District Council noted to the Panel that they are developing a Coromandel Blueprint Growth 

Strategy Project, which will be reflected in their 2012-2022 Ten Year Plan. This plan will also 

ensure the development of infrastructure needs to support industrial land activity growth. 

There are clearly funding issues that have to be resolved. 

A number of the submissions addressed the need for land-based and shore-based infrastructure. 

Megan Mackie submitted that: 

“Any consent for expansion of the Wilsons Bay aquaculture management area is 

reliant on sustainable landing and safe transportation options. These options should 

be part of the conditions for expansion either from the Ministry or the relevant local and 

transport bodies.” 

The Waipapa Bay Protection Society in their submission offered the view that the society 

neither supports nor opposes the proposed Coromandel Marine Farming Zone. They noted: 

“…the Zone approval process includes the identification and approval of appropriate 

infrastructure and access...” 

One of the options they suggested was: 

“...that the Zone is approved but that subsequent licenses or resource consents to utilise 

the Zone are not issued without having approved access to the land/water interface 

infrastructure and transportation network.” 

Hamish Mackie went further: 

“...greater consideration needs to be given to the location and development of shore- 

based facilities…” 


The economic success of increased aquaculture will be heavily dependent on the timely 

provision of supporting infrastructure. Many infrastructure requirements will require upfront 

funding. An equitable funding approach may require a partnership approach between local 

government, central government, industry and the community. 

There are a range of infrastructural choices/scenarios that will be dependent on the operational 

procedures adopted. For example, more mussels will lead to more empty trucks running into 

the area which could provide very competitive transport for fish feed to be taken out to the 

site. Harvesting at sea by purpose-built vessel direct to Auckland and on to international 

airfreight would obviate need for infrastructure onshore but that would not be inconsistent with 

farm personnel commuting to the farm from their homes on the Coromandel Peninsula by 

boat. There are many such scenarios. The provision of infrastructure is very much a chicken 

and egg situation. 




Environmental wellbeing 


Site attributes 

Positive attributes 

• Deep, well-flushed site with healthy waters, good current flow. 

• Low visual impact. 

• May improve local fish abundance. 

Negative attributes 

• Impact on natural character. 

• Adds nutrients to surrounding marine environment, increases water degradation. 

›› 34 

• Impact on wild fishstocks (scallops, flatfish, snapper) through loss of natural feed, and 

disease, parasites, antibiotics, pathogens, therapeutics. 

• Environmentally unsustainable. 

• Impacts on baitfish and birds. 

• Benthic impacts – accumulation of wastes under farm. 

• Effect on marine mammals. 

• Relatively exposed site. 

Other matters 

• Harvest of baitfish for feed. 

• Importation of fish feed. 

• Loss of nutrients on mussel farms. 

Findings 

• ‘Don’t know extent of impacts until we try it’. 

• All development must be staged over time (adaptive management approach with an 

integrated research and monitoring programme). 

• NIWA has collected information on benthic/habitat type within the zone. 

• Disease/parasites/pathogens/antibiotics issues will be addressed using an approved 

biosecurity plan for the zone – this will control the use of ‘discharges’ into the sea. 

• Much misinformation on use of fish feeds within the public arena – many submitters used 

outdated information. 





›› 35 

• Need for ongoing baseline monitoring programme to assess benthic impacts – condition 

of consent. 

• Adaptive management (including staged development) at consent stage. 

• Need for biosecurity plan at consent stage. 


The Panel is satisfied that good feeding and appropriate farm management practices (such 

as, limit on nitrogen input and a biosecurity plan) will, in an adaptive management regime of 

independent monitoring (with public disclosure), largely meet the concerns of the submitters 

who made comment on this issue. 


Effects of proposed finfish farming activity on the marine environment 

Considerable comment was made to the Panel on both the positive and negative environmental 

impacts that could arise from finfish farming. Concerns raised typically include the impacts 

(deposition) of uneaten food and faecal material on the seabed immediately underneath the 

farm and increased nutrient enrichment levels within the immediate and surrounding marine 

environment. The Panel drew on the considerable experience gained by New Zealand’s 

salmon industry to better understand good practice operational requirements and their 

environmental impacts. 

The Panel had to consider bold statements of impact that were in reality speculative and 

served to highlight the lack of specific information as demonstrated by: 

Pakihi Marine Farms Ltd: 

“The adverse ecological effects will be negligible and be far outweighed by the benefits 

that will result from finfish farming.” 

Environment Waikato in their submission noted: 

“Environment Waikato will be preparing a regional aquaculture strategy in partnership 

with key stakeholders such as the territorial authorities, the industry, iwi, and the local 

community. This strategy will include a constraints mapping process to identify areas from 

which aquaculture should be excluded and areas where aquaculture can be encouraged.” 

In actually preparing their plan change (to lift the prohibition) Environment Waikato had 

identified this area as a potential site. Environment Waikato commissioned a number of reports 

to underpin their reasoning. 




›› 36 

The Cawthron Institute’s 16 report of June 2007 provides a useful review of the ecological 

effects of finfish aquaculture, but it stressed: 

“This review is not intended to be an assessment of environmental effects that could 

be used directly in relation to resource consent applications; any assessment for such 

purposes would need to consider a range of site-specific issues.” 

The report notes: 

“At the farm scale, mitigation of poorly understood risks may rely on industry ‘best 

management practice’ or adherence to internationally accepted guidelines, at a level of 

effort that is reasonable within the context of sources of risk from other activities.” 

Many of the submitters in opposition noted that no zone should be created until further research 

is undertaken. For example, Richard Brabant noted in his verbal submission: 

“Rather than establish this large zone to enable commercial fin-fish farming to proceed 

further experimental work should be carried out. Surely trialling of sea cage farming of 

the two species in question in the Firth of Thames is essential before any decision is 

made about the appropriateness of the zone. 

“Research and trialling is an essential precondition to enabling full-scale marine farming 

in our coastal waters, if we are not to face potentially significant or even disastrous 

adverse effects on our existing natural coastal resources.” 

Bill Brownell in his recommendation 4 suggested that: 

“Any initial cage fish farming needs to be clearly defined as ‘experimental’, with a 

minimum review period of 3 years before the go-ahead can be given for full commercial 

operation at a particular scale.” 

Karen Doddrell stated that: 

“Not enough research has been done to establish finfish farming in the Firth of Thames.” 

The Panel acknowledges that the impartiality of NIWA recommendations was questioned given 

its commercial focus, but its report did provide the Panel with guidance based of scientific 

extrapolation. However, the reality faced by the Panel is that there is almost a complete lack 

of New Zealand research data for finfish species other than salmon which would underpin the 

setting up of a commercial operation. 

The Thames-Coromandel District Council submission agreed with NIWA’s recommendations 

and noted: 

“TCDC supports the use of an ‘adaptive management regime’ which could allow for 

continuous monitoring of any fin fish farming that gains consent.” 

16 Cawthron Institute 




›› 37 

The Panel accepts that the proposed sea-cage farming activities have the potential to cause 

significant amounts of nutrients and nitrogen to be added to the local marine environment. 

The very nature of finfish farming will cause uneaten food and faecal material to deposit on 

the seabed immediately under the sea-cages and this could substantially modify substrate 

conditions and impact on faunal assemblages. How these impacts are managed is key to the 

bio-economic and environmental performance of commercial fish farms. 

The Panel considers that these effects are generally restricted to the localised area of the 

farms, and these impacts can be mitigated and reduced by appropriate controls of the amount 

of feed added (thereby controlling nitrogen level), good feeding and farming practices, and 

appropriate and ongoing monitoring and remedial programmes. We note that the proposed 

zone is well flushed and situated in deep water, and is well suited for finfish farming. 

We note that the main sources of nutrient loading in the Firth of Thames and immediate waters 

are derived from local rivers and land run off, and that proposed production levels are expected 

to contribute between 5 and 11% of total nitrogen (inorganic plus organic) levels (based on 

4000 t and 8000 t annual fish production levels). 

The two NIWA reports provide some guidance on the likely environmental impacts of the 

proposed finfish farm activities on the surrounding marine environment. These reports indicate 

the proposed site was evaluated in regards to pelagic and benthic aspects and appears 

to be an acceptable site with reasonable depth and current speeds on the seabed and 

water column. 

These reports include various uncertainties and assumptions in modelling the effects of 

various nitrogen loads on the local and surrounding marine environment, and must therefore 

be treated with some caution. We highlight that there will never be any certainty with the 

modelling approach used in both reports, but note that the model outputs provide us with 

guidance as to acceptable levels of nitrogen inputs based on set fish production levels. We 

also accept that the actual effects of proposed finfish farming cannot be fully determined until 

such time as fish farming actually proceeds and the effects are monitored in real time. 

We note that NIWA is of the view that the proposed site provides a realistic opportunity to 

establish a sustainable finfish farming industry at the site and should be developed with adaptive 

(including staged) management with ongoing monitoring to establish that development is 

within “limits of acceptable change”. 

The Panel is of the view that an adaptive development approach to validate commercial finfish 

farming within the proposed zone allows central and local government, and the industry to 

implement appropriate measures to mitigate and address the environmental impacts of the 

proposed activities. 




›› 38 

The Panel recommends that consenting conditions are applied to progressively increase total 

nitrogen inputs within the proposed zone (based on fish feed levels) as the extent of the farm/ 

farms increase. This approach is applied within the Marlborough salmon industry and allows 

a precautionary stage approach to be applied to mitigate any large-scale impacts by allowing 

good monitoring and remedial programmes to be developed. 


The Panel is satisfied that good feeding and appropriate farm management practices (such 

as, limit on nitrogen input) will largely meet the concerns of the submitters who made comment 

on this issue. 

Use of imported fish feeds 

One of the most commonly expressed concerns by submitters about the proposed marine farm 

zone centred on the use of imported fish feeds. Concerns focused mainly on the unsustainable 

harvest of foreign fishstocks to provide fish protein and oils to grow hapuku and kingfish, and 

the transfer of fish protein away from local communities to produce a high-value fish product. 

We believe many of these concerns are based on out-of-date information and, in some cases, 

misinformation on the use of fish feeds in the public arena. 

The ethics on the proposed use of imported fish feeds is illustrated by the concerns expressed 

by the Thames Coast Protection Society: 

“We do not believe that it is ethically acceptable or environmentally sustainable 

to import fishmeal from overseas to support caged carnivorous finfish farming for a 

luxury overseas market.” 

The Panel is aware that the farming of finfish requires use of fish feeds, and that presently 

these are sourced overseas. If the proposal proceeds, the industry will continue to require 

the use of imported fish feeds, until such time as these can be sourced domestically. This will 

depend upon sufficient demand and favourable economics. This will not occur until demand 

for fish feed reaches a level where a plant to meet the demand will become profitable. If it is 

established, it will undoubtedly use some of New Zealand’s fishmeal and create new jobs. 

The Panel understands that imported fish feed into New Zealand is presently based largely on 

the Peruvian anchovy fishery (the world’s largest fishery). We note this fishery is extensive and 

was subject to overfishing in the 1970s-80s. As a result of this overfishing, the fishery is now 

managed using strict fishing restrictions (annual quotas) and annual biomass surveys to better 

manage the harvest and ensure sustainability. Despite frequent El Niño events in the 1990s, 

the fishery has recovered from low population size and remains stable. The Association of 

Peruvian Anchovy Producers is pursuing Marine Stewardship Council sustainability certification 

for this fishery. 




›› 39 

The Panel is also aware that advancements in the development of fish feeds now mean a 

reduced reliance of wild-fish protein and oils to produce artificial fish pellets. We understand 

that the ratio of wild fish protein to farmed fish protein is approximating 1:1, and this is likely to 

reduce as industry increases the amount on non-fish protein in its feed. 

The Panel notes that an increasing demand of fish feed in New Zealand may lead to a local 

fish feed producer using domestic fishstocks, all of which are conserved and managed under 

the QMS. The Panel would support an industry-led agreement to require industry to source its 

fish feed requirements from sustainability certified sources. 


The Panel is satisfied that the use of imported fish feeds is presently derived from sustainable 

fisheries. The establishment of a fish feed plant in New Zealand is a commercial matter. The 

Panel is certain of one thing, such a plant will not be established before demand for fish 

feed reaches the level that will make such a plant profitable. 

New Zealand produces and exports fishmeal from wastes arising from the operation of our 

commercial fisheries, all of which are conserved and managed under the QMS. In 2009 

New Zealand exported 22,017 tonnes of fishmeal for earnings of $47.2 million. This was 

produced both on vessels operating in the New Zealand Exclusive Economic Zone (EEZ) and 

at plants onshore. 

The Panel is aware of several submitters’ concerns about a possible reduction in baitfish 

abundance on local seabird populations if local baitfish resources are used to make fish feed. 

We note that the Hauraki Gulf/Tikapa Moana is home for many New Zealand seabird species, 

as well as several migratory species. However, if local fishstocks are harvested to produce 

fish feed, then the Fisheries Act 1996 requires catches of baitfish to be constrained within 

total allowable catches (TACs), and these would be set after taking into account any “effects 

of fishing on any stock and the aquatic environment”, as well as maintaining the long-term 

viability of any “associated and dependent species”. These considerations allow the Minister 

to take into account implications on the wider food chain (which includes seabirds) when 

considering commercial access to baitfish. 

Farm epidemiological and biosecurity 

Many submitters raise concerns about the potential for sea-caged fish to transfer infectious 

agents such as disease, viruses and parasites onto the wild fish population. 

The Panel is aware of the implications of outbreaks of infections in cultured fish and shellfish 

populations and the need for good farm management practices (such as, preventative and 

remedial planning). While the risk of transferring infectious agents between separate production 

units within the proposed zone and with wild fishstock cannot be removed completely, steps 

can be taken to minimise this risk. This includes maintaining appropriate distances between 




sea-cages within and between production units, and constant monitoring. 

›› 40 

The Panel notes that preventative planning is part of any good farming practices and that it 

is in the industry’s best interests that it develops an appropriate biosecurity plan before any 

sea-cages are placed into the sea. The Panel accepts this aspect of fish farming is a critical 

part of the verification process and is an integral component of the recommended adaptive 

(including staged) development approach. Submitters put considerable amounts of material 

before us sourced from overseas experience, much of it relating to salmon farming in Scotland, 

Chile and elsewhere. Many websites had been researched. Emphasis was placed on the use 

of hormones and antibiotics and other substances in medicating and managing fish farms. 

No one, it seems, looked to the New Zealand experience with the finfish species (King or 

Chinook salmon acclimatised in New Zealand since the late 19th century) with which there is 

now considerable farming experience, including about 15 years operation under the RMA. The 

New Zealand King Salmon Company Limited website records: 

“No antibiotics, growth stimulants, drugs or toxic substances are added (to feed)... 

Because of its isolation New Zealand is uniquely free of all serious pathogenic diseases 

that can affect salmon, therefore no antibiotics or vaccines are needed or used. 

Pathogens are regularly screened for by the Ministry of Agriculture and Forestry and 

our own fish health monitoring programme – none have been detected. The application 

of chemicals eg for control of sea lice, is not an issue in New Zealand, as no such 

chemicals are used.” (www.kingsalmon.co.nz/the fullstory) 


The Panel is satisfied that the risk of infectious agents can be mitigated using good management 

practices and an appropriate biosecurity plan. 




Social wellbeing 


• There are a number of different planning options to select from to create the zone. 

›› 41 

• Potential to piggyback existing trucking and vessel facilities of the expanding Greenshell 

Mussel TM industry ( cross-referenced with Economic wellbeing). 

• Potential positive and negative effects on commercial and recreational fishing (cross- 

referenced with Economic wellbeing). 

• Potential issues with boating through interference/exclusion and safety – orientation of 

zone (cross-referenced with Economic wellbeing). 

• Impacts on natural character/lifestyle. 

• Discharges from boats (recreational and industry). 

• Potential increased employment – new jobs/training (skilled and unskilled), retaining 

young people in the region, retaining school numbers (cross-referenced with Economic 

wellbeing). 

• Impacts on tourism. 

• Ethics of finfish farming. 

• Impacts on infrastructure – costs on ratepayers (improved/maintenance of roading and 

wharves, cross-referenced with Economic wellbeing). 

Findings 

• The need for space has been established. The Minister has a range of options that can be 

exercised to create that space. 

• Use of recreational fish buoys to improve recreational fishing and prevent interference 

with farm gear. 

• Safety concerns can be addressed by Maritime NZ and Environment Waikato’s 

Harbourmaster. 

• Finfish farming will impact on the natural character of the Firth, (cross-referenced with 

Cultural wellbeing). 

• Ethics of finfish farming managed under Animal Welfare Act (cross-referenced with 

Environmental wellbeing). 

• Need for integrated management with local government to address issues concerning 

infrastructure (cross-referenced with Economic wellbeing). 





›› 42 

• If direct Ministerial action is required to set up the zone then mechanisms should 

developed which will allow for meaningful input into the objectives, policies, rules and 

other methods which will regulate this zone. 

• Look at measures to maximise the benefits to the local district and region. 

• Ensure that direct action is taken over ‘advertising’ the zone. For example: 

– marine charts/GPS maps to be updated before operations commence 

– Environment Waikato’s Harbourmaster to review cardinal marks 

– consenting conditions to require adequate signage and marine marks. 


The Panel holds the view that finfish farming in the proposed zone will contribute significant 

social benefit to New Zealand. One of the many challenges which is faced by the local 

community is how these benefits can be uplifted. 

The Panel accepts that there will be impacts on the seascape values and natural character. 

These have been largely minimised by the remote location of the zone. 

Policy 8 in the New Zealand Coastal Statement 2010 17 has been put in place to recognise the 

significant contribution, both existing and potential, of aquaculture to the social and economic 

wellbeing of people and communities. 


Creation of the zone 

The Panel were informed that two planning initiatives are underway: 

• The Aquaculture Legislation Amendment Bill (No 3) (the Bill) proposes amending the 

Environment Waikato Regional Coastal Plan to enable applications to be made for marine 

farming activities other than shellfish farming in the Wilsons Bay Marine Farming Zone and 

on other existing farm sites and for small extensions to current marine farms. 

• Environment Waikato has prepared a proposed plan change 18 to allow for the development 

of new marine farms. 

The Panel is also aware that the Minister could use the Bill to deem the new zone. 

17 New Zealand Government: New Zealand Coastal Policy Statement 2010, Department of Conservation 

18 Environment Waikato: proposed Waikato Plan Change _version 5, 20 October 2010 




›› 43 

Environment Waikato in presenting their submission advised that there were three options for 

creating the new zone. These options are: 

1. Deeming it into the plan by adding it to the Bill using a Supplemental Order Paper (SOP). 

2. Deeming it into the plan using the Minister’s new regulation-making powers (according to 

the Bill as it currently stands). 

3. Inserting it into the plan through a normal plan change process. 

Option 1. Using an SOP to add it to the Bill will result in the quickest creation of the zone. It 

will come into existence at 1 July 2011 (or other date on which the Bill becomes law), at which 

time Environment Waikato will be able to tender out the right to apply for consents. 

Officials would be required to work closely with Environment Waikato staff to draft the policies 

and rules for the zone. This process would be unlikely to allow for any public participation in 

development of policies and rules for the new zone. 

It would be expected that the policies and rules for the new zone would be very similar to those 

proposed for the Wilsons Bay Zone by the Bill. These have been subject to public scrutiny 

through the select committee process. 

Option 2. Using the Minister’s new regulation powers would delay the establishment of 

the zone for the period required to carry out the consultation required by the Bill (approximately 

4 to 6 months). 

Using this process would provide another round of discussion with whatever stakeholders the 

Minister considers appropriate (according to the Bill as it currently stands). 

Option 3. If the zone was established by a normal plan-change process there would be 

considerably more scope for public participation, and consequently significant delays. 

If Environment Waikato carried out the plan change and was subject to appeals, it is likely 

to take 4 to 5 years for the zone to become operative, and no consent applications could 

be accepted until it was. If the plan change was called in by the Minister and processed 

by the Environmental Protection Authority (EPA), there is potential for the timeframes to be 

substantially reduced. 

The potential approach to create the zone has led a number of submitters to express serious 

concern over the “process” and “approach” to setting up the zone which appears to them is 

contrary to RMA requirements. 

Betty Williams in her submission pointed out to the panel that: 

“...the greatest impact will be on intruding into the traditional and spiritual space of 

tāngata whenua without prior robust consultation...We feel left out...” 




One of Bill Brownell’s recommendations stressed that: 

›› 44 

“The Ministry of Fisheries (or any other central government entity responsible for national 

aquaculture development) not be granted the power to override the statutory regional 

planning, policy making and environmental protection responsibilities of regional 

councils and the Department of Conservation under the RMA (1991).” 

New Zealand Inshore Fishing Industry Council: 

“Believes that the consultation documents provides an insufficient basis for a plan 

change under the Resource Management Act 1991 and sets an unhelpful precedent.” 

Reihana and Geoffrey Robinson were very blunt in their submission: 

“We oppose the proposal and due process has been avoided.” 

The Coromandel Marine Farmer’s Association submitted in support of a plan change 

noting that: 

“...the planning provisions of the Coastal Plan that are to be amended to allow for the 

site, also be amended to allow for other sites…” 

Mike Burrell of Aquaculture New Zealand noted: 

“...the 2000s were a ‘lost decade’ for aquaculture…” 

The Panel notes that complete blanket prohibition around the coast is a very blunt instrument 

and is contrary to the enabling ethic which was meant to underpin the RMA. 

One of the consultation documents made available on the Ministry of Fisheries website 

provided a planning analysis 19 for the establishment of the proposed zone, and broadly 

described potential changes to Environment Waikato’s Regional Coastal Plan that would be 

required. In Section 5.2 it noted that: 

“The exact content of any proposed plan change has not yet been developed. However, 

an outline of the possible content of such a plan change has been developed.” 

Section 5.2 then outlined the general approaches, or provisions of the proposed plan: 

“Three new policies to provide for: 

– a requirement that developments avoid significant ecological areas 

– a preference that the proposed zone is principally utilised for fed aquaculture, 

although other marine farming activities will be accommodated 

– the proposed adaptive management regime outlined in Section 3.3.5.” 

19 Environment Waikato – Regional Coastal Plan. Proposed Coromandel Marine Farming Zone Planning Considerations, 

Aquaculture Unit of the Ministry of Fisheries, December 2010 




›› 45 

It was pointed out to the Panel that the planning requirements can be both time and money 

consuming. On review of the planning options the Panel has come to the view that New Zealand 

Inc. cannot afford lengthy time delays, or major costs, to establish a finfish farming zone aimed 

at validating farming of finfish other than salmon in New Zealand. 

The Panel offers the following advice to the Minister: if he chooses to accept the recommendation 

of the Panel that the site is appropriate for finfish farming then he needs to carefully consider 

which option he will adopt to exercise his prerogative to amend the Waikato Regional Coastal 

Plan and set the area up so that it is open to consent applications. Direct intervention by 

the Minister to deem the area could have major flow-on consequences with other industries 

wanting a similar approach. 

The area over which the prohibition is lifted will require its own set of objectives, policies, 

and rules. Ideally these should be put in place at the same time as lifting the prohibition. The 

usual RMA plan change process puts the proposed objectives, policies, and rules through a 

rigorous public process. The public have come to accept that they have a right, in law, to be 

involved, and, it has been submitted to us, that they want to be involved. 

The Panel strongly recommends that a mechanism is developed which allows Environment 

Waikato and others input into the drafting of objectives, policies, rules and other methods. 

Without local input central derived objectives, policies, rules and other methods could result in 

unintended consequences. A little bit of time here may save considerable time later on. 


The Panel has expressed the opinion that the zone should be set in place as soon as possible. 

The Minister needs to carefully consider the implications of which option he will exercise to 

create the zone. 

The Panel holds the view that the intent of recommendations 14 and 15 of the Aquaculture 

TAG 20 should be revisited to enable the parallel processing of plan changes and resource 

consents and allow the applicant some priority for space but not so as to impact on rights 

under the Māori Commercial Aquaculture Claims Settlement Act 2004. 

A ‘call-in’ process through the EPA which processes both the plan change and consents 

concurrently would, potentially, be the shortest RMA route. This route would allow for the 

scrutiny of planning measures, however, there is still uncertainty about this route and there are 

time and cost elements to consider. 

20 Re-Starting Aquaculture – Report of the Aquaculture Technical Advisory Group, 15 October 2009 




›› 46 

The challenging task for the Aquaculture Unit is to find a mechanism that allows for meaningful 

input in the drafting of objectives, policies, and rules. Objectives policies and rules for the 

zone would benefit from appropriate levels of input and scrutiny by key stakeholders. At 

the same time, this proposal will need to be advanced relatively quickly if it is to contribute 

to achieving the goal of a thriving and sustainable aquaculture industry with a turnover of 

$1 billion per annum by 2025 within appropriate environmental limits. 

Boating issues 

Many of the submissions in opposition to the creation of the zone pointed out that the location 

of the zone would have an adverse impact on those using the Firth especially recreational 

mariners. It was pointed out to the Panel that the operational structures in the zone would 

present major safety issues to recreational users especially at night and in adverse weather 

conditions. The Panel was reminded that the zone was right in the ‘track’ of a classic yacht 

race (the Balokovic Cup). 

Richard Brown was typical of many submitters when he expressed his concern about boat 

safety issues pointing out to the Panel that many people go boating with poor navigation 

equipment. This statement was reinforced by the Thames Sailing Club: 

“There is a high traffic of commercial and recreational boats through the proposed area. 

Most of these boats do not carry radar and the farms represent a significant navigational 

hazard.” 

Carne Clissold: 

“…the location of the proposed fish farm lies on the normal routes for vessels proceeding 

between Coromandel Harbour and Kawau Bay or further up the coast and between 

Coromandel Harbour and north around Waiheke Island.” 

The Auckland Yacht & Boating Club suggested that boat safety issues could be mitigated by 

moving the zone to existing space within Wilsons Bay marine farming zone. 

Neil Macdonald (who states he has 20 years harbourmaster duties in the Coromandel) 

said the: 

“zone run NW-SE. This may help to negate any opposition by recreational boaties 

in transit from Te Kouma and Coromandel harbours to Gt. Barrier isle...It may also 

minimise sea and wind (wave movement) of the cage during inclement weather when 

structure in line with ebb and flood tide action.” 

Keith Ingram, Recreational Fishing Council, offered a different perspective noting that 

mariners will be able to cope with a well-marked aquaculture zone and that the public should 

have freedom of access to the area. He also suggested a partnership approach and that the 




›› 47 

commercial users of the space could make mooring buoys available for recreational fishers so 

that recreational anchors would not foul lines associated with the farm. 

Maritime New Zealand did not make a formal submission to the Panel but Jim Lott, their 

manager of Recreational and Small Craft, made a number of relevant observations in 

correspondence to the Aquaculture Unit: 

• Statements that the cages represent a navigation hazard are hard to justify provided the 

marking complies with MNZ/IALA requirements. 

• The area is on the rhumbline (the most direct course) from Auckland to Coromandel and 

from Coromandel to Kawau. It intersects the Balokovic Cup Course and other courses 

used for many years by Auckland and local yachts. Just about anywhere could conflict 

with a yacht race. Although it is on the rhumbline, a structure in clear water such as this 

would be at worst an inconvenience. 


If the zone is created the Panel accepts that potential boat safety issues may be created, 

however, the Panel also accepts measures can be taken to mitigate these. For example: 

• Once the zone is designated there will be a time lag when the site is not occupied – the 

consent application period. This time can be used to advertise the zone with appropriate 

communications to inform Firth users of the new zone. 

• Maritime New Zealand would be asked to provide the necessary chart and GPS updates 

during that period. 

The Panel does not accept that the reason that having poor navigation equipment on board is a 

valid reason to stop development. Boat owners/skippers have particular responsibilities for their 

craft, and they have a duty of care to exercise those responsibilities in an appropriate manner. 

The Panel notes the concerns about possible interference with the annual Balokovic Cup 

course. The Royal Akarana Yacht Club website (www.rayc.org.nz) states that this year’s race 

involved 12 yachts. 

Landscape and natural character 

Most submitters acknowledge that the Firth of Thames and the wider Hauraki Gulf are a special 

and unique area. Submitters were passionate in their concern that the Firth of Thames and 

the Hauraki Gulf should be protected from development; it is public space that should not be 

allocated to private concerns. 

Keith Purnell was unequivocal in his concluding statement to the Panel: 

“The Firth of Thames and Hauraki Gulf are to many New Zealanders in this area as sacred 

and deserving of protection from modification as is Eden Park to an avid footballer.” 




Ian James in a written submission pointed out: 

›› 48 

“The Hauraki Gulf Marine Park is a highly treasured recreational resource that is within 

a few hours drive of the majority of New Zealanders.” 

The Waharau Trust stated: 

“The water space in the firth of Thames and the land which surrounds the Firth are of 

high natural character and landscape value... 

“Any marine farming development in the southern or western parts of the Firth would 

significantly detract from these landscape and natural character values.” 

Capt Kathleen Walsh strongly pointed out: 

“I object to this ‘experimental hazardous proposal of such a massive scale’, in the 

Hauraki Gulf Marine Park, an area of national significance.” 

Richard Stone noted his concern: 

“The granting of private rights over public space is, I believe, a grave matter indeed.” 

By way of contrast Nita McNeil thought the proposed zone was well located in terms of 

ecological, commercial and recreational fishing and customary considerations. 

Environment Waikato’s submission in addressing the impact on landscape values and natural 

character noted: 

The natural character of any place is a combination of natural sights, sounds and 

smells, and is degraded by the presence of artificial structures. Its landscape values are 

a reflection of the aesthetics of the view perceived by an observer. 

The creation of a marine farming zone will impact on the natural character of the location 

and this cannot be mitigated by changing the position of the zone. Some controls can be 

applied at the consenting stage to minimise the obtrusiveness of farm structures. 

Visual impact on land-based observers at sea level is avoided by locating the zone 

more than 5 kilometres offshore. We note that the zone will be visible to observers from 

elevated parts of the coastline. 

Jim Lott noted in correspondence to the Aquaculture Unit that: 

“It is well out to sea and while any development may be unsightly, this particular 

development will be very minor.” 


The Panel accepts that there will be impacts on landscape values and the natural character 

of this area of the Gulf, however, given the offshore location of the zone these impacts have 

been minimised. 




Conclusion 

Within the context of the Terms of Reference, the Panel has undertaken: 

• a comprehensive site visit (which included informal consultation) 

• called for, and received, submissions 

• conducted hearings at various locations. 

›› 49 

The Panel has provided the Minister with this written report, which sets out the process that 

was followed, the issues which were identified, and a number of key recommendations for the 

Minister to consider. 

The Panel has come to the firm view that: 

• the proposed zone should be established 

• the commercial viability of finfish farming (other than salmon) needs to be proved in a 

New Zealand situation. A strategically, adaptively managed (including staged) commercial 

operation is the only way to validate all of the impacts (both positive and negative) of hapuku 

and kingfish. 

Afterword 

Even with the best process, applying the best legislation and coastal plans and with the benefit 

of all the expert evidence that can be obtained, no project undertaken at sea can be without 

risk, including the risk of destruction. The only way to avoid such risk is to do nothing. In the 

event of such destruction it is not improbable to suggest that the escape of the fishstock would 

most likely trigger a goldrush-like increase in recreational fishing effort amongst the owners of 

the huge number of recreational boats who use the waters of the Hauraki Gulf/Tikapa Moana. 

The fish, soon becoming hungry and being dependent might easily be caught. Experience 

with occasional modest escapes of salmon in the Marlborough Sounds gives credence to 

this assertion. 

Appropriate bonding in the consenting process would see what was left of the structures 

quickly removed. 

Submitters told us of the stirring-up effect on bottom sediments during the not uncommon 

strong winds in the area. This would soon cause the benthic environment to be rehabilitated. 

In short, if the worst comes to the worst, no permanent harm would result except perhaps to the 

bank accounts of the participants. The benefit of real data from the New Zealand experience 

with New Zealand species would remain. 




References 

›› 50 

Broekhuizen, N. (2011). Waikato Marine Finfish Farming: cumulative effects associated with 

Coromandel and Wilsons Bay fish-farming. NIWA Client Report HAM2011-008, prepared for 

Ministry of Fisheries Aquaculture Unit. 

Cawthron Institute. 2007 Review of the Ecological Effects of Marine Finfish Aquaculture: Final 

Report. Report No 1285. 

Department of Conservation. 2010. New Zealand Government: New Zealand Coastal Policy 

Statement 2010. 

Dunbar-Smith, B. (2010). Wharfing Infrastructure Discussion Document. Prepared for the 

Hauraki-Coromandel Development Group. 

Environment Waikato. 2010. Proposed Waikato Plan Change V 5. 

Ernst & Young. New Zealand Aquaculture: Industry Growth Scenarios. 10 September 2009. 

Giles, H (Environment Waikato). Water flow information for the Firth of Thames. Information 

provided to Aquaculture Unit on 17 February 2011. 

Grange, K., Cairney, D., and Carter, M. (2011). Waikato Marine Finfish Farming: site 

investigation. NIWA Client Report NEL2011-004, prepared for Ministry of Fisheries Aquaculture 

Unit. 17 p. 

Ministry of Fisheries. 2009. Re-Starting Aquaculture. Report of the Aquaculture Technical 

Advisory Group. 

Ministry of Fisheries. Consultation Document-Proposed Coromandel Marine Farming Zone. 

17 December 2010. 

Ministry of Fisheries. 2010. Environment Waikato – Regional Coastal Plan. Proposed 

Coromandel Marne Farming Zone Planning Considerations. Aquaculture Unit, Ministry of 

Fisheries. 

NZIER. The Net Economic Benefit of aquaculture growth in New Zealand. Scenarios to 2010. 

Final report to Aquaculture New Zealand, June 2010. 

NZIER. Value of kingfish and hapuku farming – Preliminary analysis. Report to Ministry of 

Fisheries. December 2010. 

StellarCom Consultants. (2009). Aquaculture Potentials in the Waikato Region. A report 

prepared for New Zealand Trade and Enterprise Waikato Governance Group. 

Zeldis, J., Broekhuizen, N., Forsythe, A., Morrisey, D., and Stenton-Dozey, J. (2010). Waikato 

Marine Finfish farming: Production and Ecological Guidance. NIWA Client Report CHC2010- 

147, prepared for Ministry of Fisheries Aquaculture Unit. 113 p. 




Appendices 

Appendix 1 – List of submitters 

Appendix 2 – Schedule of speakers 

›› 51 




Appendix 1 – List of submitters 

Number Submitter 

1 Karen Doddrell 

2 Nita McNeil 

3 Pat Baskett 

4 Max Purnell 

5 Natalie Jessup 

6 Wally Sander 

7 Michael Donoghue 

8 Richard Brown 

9 Commodore John Maxwell (Kaiaua Boating Club) 

10 Carl Jensen (Thames Sailing Club Inc) 

11 Hamish Mackie 

12 Adele Smaill 

13 Barry Taylor 

14 Patricia Duncan Taylor 

15 Reihana and Geoffrey Robinson 

16a & b Reihana Robinson 

17 Theodora Ward 

18 Loes Beaver (Coromandel Business Association) 

19 O M Nicholls 

20 Keith Purnell 

21 Megan Mackie 

22 Kate James 

23 Thames-Coromandel District Council 

24 Richard Williams 

25 Fisheries Consultancy Services Limited 

26 Advisory Committee for the Waikato Regional Environment 

27 Stewart Robinson 

28 Ian James 

29 Thames Coast Protection Society 

30 Catherine Delahunty 

›› 52 




31 Richard Stone 

32 Renee Annan 

33 Waharau Trust 

34 Waipapa Bay Protection Society Inc 

35 Clevedon Game Fishing Club 

36 Kaiaua Citizens and Ratepayers Association 

37 Kathleen Walsh 

38 Anthea Ward 

39 Ross Gardner 

40 Alexander Ward 

41 Sealord Group 

42 Coromandel Scallop Fisherman’s Association 

43 Coromandel-Colville Community Board 

44 Sanford Limited 

45 Gary Blake 

46 Bill Brownell 

47 Carne Clissold 

48 Mark Aislabie 

49 Hauraki Coromandel Development Group 

50 New Zealand Inshore Fishing Industry Council 

51 Richard Brabant 

52 Auckland Yacht and Boating Association Inc 

53 Leith McIntosh 

54 Environment Waikato 

55 Coromandel Marine Farmers’ Association 

56 Tasman Buildings Limited 

57 Royal Forest and Bird Protection Society of New Zealand Inc 

58 Hauraki Māori Trust Board 

59 Te Ohu Kaimoana Trustee Limited 

60 Aquaculture New Zealand 

61 Yachting New Zealand 

›› 53 




62 Jeanette McIntosh 

63 Karen Ismay 

64 Neil Macdonald 

65 Gulf Mussel Farms Limited 

66 G Walters 

67 Leigh Commercial Fishermen’s Association Inc 

68 A E Ward 

69 Unnamed 

70 John Ward 

71 Te Rūnanga a Iwi o Ngāti Tamaterā 

72 Pakihi Marine Farms Ltd 

73 Leigh Commercial Fishermen’s Association Inc 

74 Betty Williams 

75 Unnamed 

76 Keith Ingram 

77 Waikato Conservation Board 

›› 54 




Appendix 2 – Panel Hearings 

9 February 2011 – 3 Solent Drive, Marine Rescue Centre, Mechanics Bay, Auckland 

Panel: Hon Sir Doug Kidd (Chair), Mark Farnsworth, Justine Inns 

Ministry of Fisheries: Paul Creswell, Andrew Hill, Michael Nielsen 

Te Puni Kōkiri: Tony Seymour 

Department of Conservation: Sarah McRae 

Speakers: 

Richard Brabant 

Richard Brown (Auckland Yacht and Boating Association) 

Keith Ingram 

Public: 

Stephen Wagstaff, Keir Volkerling, Robyn Marsden 

10 February 2011 – 200 Mary Street, Civic Centre, Thames 

Panel: Hon Sir Doug Kidd (Chair), Mark Farnsworth, Justine Inns 



Speakers: 

Joyce Birdsall (Advisory Committee for the Waikato Regional Environment) 

Bill Brownell 

Keith Purnell 

Max Purnell 

Peter French (Deputy Mayor) and Ben Dunbar-Smith (Thames-Coromandel District 

Council) 

Rawinia Brownlee & Tewi Nichols (Te Rūnanga a Iwi o Ngāti Tamaterā) 

Clive Monds (Thames Coast Protection Society) 

Stephanie Todd 

Donna Neil (Kaiaua Boating Club) 

Patricia Taylor 

Public: 

Graeme Silver, Marilyn Brownell, Keir Volkerling, Robyn Marsden, Anthony Round (Rear 

Commodore Thames Sailing Club), AE Stevens (Ngāti Maru Runanga), Brett Rhind (BNZ), 

John Lloyd (BNZ), Scott McKenzie (BNZ), Kathy & Wali Ngamae (Ngāti Maru Runanga), 

Amy Cooper(Ngāti Maru Runanga), Clive Majurey (Ngāti Maru Runanga), David Taipari, 

Ben Dunbar-Smith (Thames-Coromandel District Council), John TeMoananui (Te Rūnanga 

a Iwi o Ngāti Tamaterā), Alice Anderson (Te Puni Kōkiri – Waikato), Megan Mackie 

›› 55 




11 February 2011 – 455 Kapanga Road, Coromandel 

Committee: Hon Sir Doug Kidd (Chair), Mark Farnsworth, Justine Inns 



Speakers: 

Richard Stone 

Gilbert James (Coromandel Marine Farmer’s Association) 

Reihana Robinson 

Simon Friar and Graeme Silver (Environment Waikato) 

Betty Williams 

Graham Walters and John Deane 

Ohomauru Nicholls With Jan Ngatai, JW Tukerangi and Betty Williams 

Kate Bartram (Coastal Collective Council) 

Peter Sopp (Coromandel Scallop Fisherman’s Association) with Ron Somerdon 

Jane and Allen Bartram 

Carl Jensen and Carne Clissold (Thames Sailing Club Incorporated) 

Public: 

Public: Graeme Silver, Kurt Muller (Te Kouma), David Sampson and Claire Benge 

(Waipapa Bay Protection Society), Betty Williams, and Michael Baker 

12 February 2011 – 455 Kapanga Road, Coromandel 

Committee: Hon Sir Doug Kidd (Chair) , Mark Farnsworth, Justine Inns 

Ministry of Fisheries: Paul Creswell, Michael Nielsen 

Te Puni Kōkiri: Tony Seymour 


Speakers: 

John Walker (Chairman) with Anne Ward (Coromandel Community Board) 

Loes Beaver (Coromandel Business Association) 

John Tregidga (Chair) with Ben Dunbar-Smith (Hauraki-Coromandel Development Group) 

Toko Renata (Kaumatua) with Hare Mikaere & Liane Ngamane (Hauraki Māori Trust Board) 

Phillip Martelli (Waipapa Bay Protection Society) 

Public: 

Graeme Silver, Kurt Muller (Te Kouma), David Sampson and Claire Benge (Waipapa Bay 

Protection Society), Betty Williams, and Michael Baker 

FEBRUARY 2011 

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Proposed Coromandel Finfish Marine Farming Zone - Ministry of ...

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