Draft Submission on the Proposed Coromandel Marine Farming Zone from Thames-Coromandel District Council

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1 3 February, 2011 Draft Submission on the Proposed Coromandel Marine Farming Zone from Thames-Coromandel District Council To the Aquaculture Ministerial Advisory Panel Thames-Coromandel District Council (TCDC) welcomes the opportunity to provide feedback on the proposed 300 ha Coromandel Marine Farming Zone TCDC wishes to be heard in support of our submission preferably at the Thames War memorial Civic Centre on Thursday 10 th February, Yours sincerely, Steve Ruru Chief Executive Thames-Coromandel District Council

2 Draft Submission on the Proposed Coromandel Marine Farming Zone Executive Summary Thames-Coromandel District Council (TCDC) supports the Government s proposed creation of a Coromandel Marine Farming Zone, which would provide the opportunity to develop new higher-value species in Coromandel waters and bring considerable economic benefits to the District. TCDC believes that the development of fin fish farming, which would still have to go through an extensive consenting process, can be implemented in an environmentally sustainable manner as set out in the NIWA report. The Coromandel has some of the best water in New Zealand for the development of finfish and the creation of this zone will allow for this potential to be realised for the benefit of both the local and national economies. This submission outlines TCDC's general support for the Coromandel Marine Farming Zone, and offers comments on the specific issues raised in the Consultation document. TCDC wishes to be heard in support of its submission. Contact details are provided at the end of our submission. Main submission Background 1) TCDC welcomes the opportunity to submit on the proposed Coromandel Marine Farming Zone. 2) TCDC is the territorial authority which covers the Coromandel Peninsula and adjoins the western side of the Firth of Thames. TCDC is responsible for the economic, social, cultural and environmental well-being of the District's residents and ratepayers. 3) At present, the Coromandel grows approximately 20% of New Zealand s mussels which represents about $46 million in sales 1. In addition, the Coromandel also has significant oyster farming operations worth about $6 million annually. As a result, the District is a significant participant in development of the NZ aquaculture industry. 4) Aquaculture is an important driver of economic growth and job creation within the Coromandel region. The Coromandel Peninsula provides the primary landbased site for most of the aquaculture industry in the Firth of Thames. With facilities for both processing and harvesting of mussels and oysters, the aquaculture industry already employs approximately 400 people locally. 1 Based on 2007 figures

3 5) Employment opportunities are expected to grow significantly as a result of the proposed Coromandel Marine Farming Zone with the NIWA report indicating that 4,000 tonnes of finfish would create up to 454 full-time equivalent positions, while 8,000 tonnes of finfish could create up to 904 full-time positions. 6) This potential for new jobs is important in the Coromandel, where the resident population is aging, and there is a growth in absentee owners who largely come here to holiday. The development of an industry which attracts graduates in things like diving, skippering, boat maintenance, and food technology will provide an opportunity for long-term careers which will help to keep young people on the Peninsula. 7) The development of a $100+ million finfish industry will create jobs and economic growth, and assist with diversification of the economic base on the Peninsula. 8) A recent BERL report 2 shows that over the past decade to 2008, the Thames- Coromandel District grew at a slower rate than the rest of New Zealand (3% compared with 3.3%), and that growth in employment in the District began to decline by 0.9% by This drop in employment has been exacerbated by the global recession, with the recent closure of a meat works and a major timber processing factory at Kopu. In addition, the building trade and property development which have traditionally been mainstays of the Peninsula s workforce has seen marked declines since the onset of the recession. 9) For these reasons, the growth of a new primary industry in finfish would be welcomed on the Peninsula. Not only does it provide long-term employment in rural areas, but the export-orientated nature of the business, and the fact that the global demand for fish protein is increasing bodes well for sustainable economic and job growth in the future. 10) In addition to the jobs and economic growth, the finfish industry will bring the development of a new industry that will help to future-proof the existing mussel and oyster industries. The diversification of species will increase the flexibility of the aquaculture industry, and can help obviate the risks of diseases, pests or the collapse of specific markets which can affect an industry dominated by a single species. 11) On a national scale, the development of a new export industry worth between $100 million to $200 million a year is a very positive development, which will assist with New Zealand s balance of payments. As world population climbs to the predicted 9.5 billion people by 2050, and the demand for protein and food security grows around the world, the development of a new finfish export will prove beneficial for New Zealand. Coromandel s ideal growing waters 12) The Coromandel is ideal for finfish development, due to its sheltered waters, ease of access, favourable climate and good water quality. TCDC notes that to 2 BERL Thames Coromandel District Economic Performance

4 develop the nation s aquaculture industry, New Zealand needs to develop higher-value species. 13) At present, New Zealand s finfish industry is limited to salmon which are primarily grown in the colder waters of Marlborough. The salmon industry demonstrates the value which can be achieved from finfish with only 7,500 tonnes generating an annual turnover of $102 million. By comparison, the whole of the NZ mussel industry earned just over $220 million from 97,000 tonnes of mussels (2007 figures). This highlights how smaller volumes of finfish can earn significantly higher returns and signals how New Zealand can prosper from the development of higher-value species. 14) To develop new species like kingfish and hapuka, there needs to be a site designated where the finfish industry can grow. As the Hauraki Gulf provides sheltered warm waters, this has been identified as an ideal site by NIWA. TCDC seeks to address the issues surrounding the proposed 300 ha site in terms of the economic, environmental, cultural and social outcomes, as requested in the Ministry of Fisheries consultation document: A) Economic issues 15) The economic outcomes from this 300 ha finfish proposal are positive for this District, and its people. It is not often that a local authority can become party to the creation of a new industry, which has the potential to earn over $100 million a year in an environmentally sustainable manner. 16) TCDC notes that the NZIER report, utilising information provided by NIWA from trials and market investigations, estimates the economic impacts range from $110 million to $210 million per year in export revenues by 2025 depending on the species farmed. 17) This is a major boost to the local economy and also provides a significant new income stream for New Zealand. For example, if the species selected is kingfish, then 8000 tonnes per annum would generate export revenues of $110 million and increase GDP by $90 million. On the other hand, a hapuka farm that produced 8000 tonnes per annum would create export revenues of $210 million by 2025 and increase household consumption by $100 million. 18) TCDC submits that this opportunity to significantly boost New Zealand s export income needs to be taken. 19) While the Aquaculture Legislation Amendment Bill No 3 (if passed in its current form) will allow for the development of finfish in the Wilson Bay zone, TCDC believes that the creation of the proposed new 300 ha zone further north has the potential to provide better environmental outcomes. TCDC notes that under the present terms of the Waikato Regional Coastal Plan, the removal of the fedspecies prohibition proposed in the Amendment Bill would only allow finfish to occur in Wilson Bay as this is geographically-designated as an AMA in the Regional Coastal Plan. However, other considerations in the proposed 300 ha zone further north, such as water depth and flushing, are more conducive to positive environmental outcomes.

5 B) Environmental considerations: 20) TCDC notes that the proposed 300 ha site is found by the NIWA report to be ideal in terms of water depth (30-40 metres), with strong flushing currents (20 cms/s), and a seafloor that is predominantly soft sediment and is not considered of any ecological, scientific or conservation value. 21) TCDC also notes that the site avoids major commercial shipping and ferry routes, recreational boat owner anchorages, recreational fishing spots, areas of marine mammal activity, and areas of significant conservation value. 22) The site, which is 13.5 kms from Coromandel township (and 4.9 kilometres from the closest island, Waimate) is far enough out to sea that the visual impacts are likely to be minor. Furthermore, the site is in a reasonably sheltered zone, which will give protection from larger oceanic swells. 23) TCDC is of the view that sufficient analysis has been completed to enable an informed decision to be made in relation to this proposal. 24) TCDC supports the use of an adaptive management regime which would allow for continuous monitoring of any finfish farming that gains consent. It notes that this regime has been working successfully in the Wilson Bay zone, and would encourage the use of this technique in any finfish consent. 25) TCDC also notes that NIWA recommends a staged development approach, which would allow monitoring of the environmental impacts of certain levels of finfish (and feed) prior to any further expansion taking place. TCDC considers this to be a prudent approach. 26) TCDC supports NIWA s recommendations around issues such as the fallowing of specific sites, controlling the movement of fish and plants, management of biofouling, and farm separation. It also supports NIWA s suggestions around the minimisation of waste and notes that experience in Marlborough indicates that the industry also wishes to minimise fish food waste (both from an environmental and economic point of view). 27) TCDC notes that despite the proposed deeming into the Coastal Plan of this finfish zone, the finfish farm would still be subject to an extensive consenting process. This consenting process would require an assessment of environmental effects, strict resource consent conditions, the use of coastal tendering to ensure the efficiency of development, and an adaptive management strategy. 28) Given these criteria, TCDC is satisfied that the environmental effects of the proposed 300 ha zone can be adequately managed and is, therefore, supportive of proceeding with the designation of the 300 ha zone. C) Cultural impacts 29) TCDC notes that Maori are significant players in the Coromandel aquaculture industry, and currently own about 40-45%. With the development of new aquaculture space, they will also gain further allocation.

6 30) TCDC is not currently aware of any negative impact on cultural values from the proposed 300 ha zone but note that this is an issue which iwi will need to discuss with the independent hearing panel directly. D) Social outcomes: 31) The development of a new $100+ million finfish industry in the Coromandel is likely to have positive outcomes for the social well-being of the community. Rural areas of New Zealand, such as the Coromandel can often struggle to provide well-paying, long-term jobs. TCDC is encouraged by the prospect of the finfish industry being able to boost jobs and economic growth in the Peninsula. 32) The more technical aspects of the finfish industry are likely to attract higherearning graduates and we note that 20% of the staff at NZ King Salmon in the Marlborough Sounds are graduates. This can also provide long-term career paths for local youth in careers liking diving, skippering and food technology. This also generates additional social benefits through the need to provide tertiary education into the local area. 33) The growth of a new industry will also help to bring families to the Peninsula as long-term residents, which in turn ensures the survival of things like schools, and local businesses. These social benefits in terms of long-term employment and all the associated spin-off benefits are important for this District. Infrastructure Development 34) TCDC is aware that the development of a new finfish industry will require the provision of land-based facilities, such as wharfing infrastructure and factory processing opportunities. 35) TCDC is currently undertaking a major review of wharfing infrastructure, with a view to expanding the capacity on the western side of the Firth of Thames to accommodate growth of the industry. In addition, TCDC is looking at zoning additional industrial land that will allow for land-based facilities, as part of its Coromandel Blueprint growth strategy project and review of the District Plan that is currently underway. Outputs from the Coromandel Blueprint project are also being reflected in TCDC's Ten Year Plan so as to ensure, for example, that the development of other infrastructure (e.g. water and waste) needed to support industrial land activity growth can also be provided. Planning Considerations 36) TCDC support the deeming into the Regional Coastal Plan of the proposed 300 ha zone. It submits that the creation of the 300 ha zone will not require the changing of the Coastal Plan s objective for marine farming namely ensuring that any such developments occur in an efficient and sustainable manner, while avoiding adverse effects as far as practicable. Hence, the new zone would be in accord with the Plan s objectives but will provide a new and potentially more environmentally acceptable manner of bringing this objective about when it comes to finfish.

7 37) TCDC notes that the deeming into the Coastal Plan of this 300 ha zone would not be required, if the blanket prohibition on aquaculture outside of geographically-designated areas did not apply. It notes that even if the AMA provision is removed as currently proposed in the Aquaculture Legislation Amendment Bill (No. 3), in the Waikato the development of the aquaculture industry is constrained by the geographical designation which exists in the Regional Coastal Plan. This places additional barriers to aquaculture development which do not exist in other parts of New Zealand. Impact of the Hauraki Gulf Marine Park Act/ NZ Coastal Policy Statement 38) One of the planning issues under consideration in the 300 ha zone is the impact of the Hauraki Gulf Marine Park Act. TCDC notes that this Act talks about the life supporting capacity of the environment of the coastal marine area and islands (Section 7-1). 39) This life supporting capacity is defined as providing for the social, economic, recreational and cultural well-being of people and communities (Section 7-2 (a) (ii), and that this life-supporting capacity is further defined as for the use of the resources of the Gulf by the people and communities of the Gulf and New Zealand for economic activities and recreation (Section 7-2 (b). 3 40) TCDC submits that the creation of the 300 ha zone would provide for the economic well-being of communities, and can do so in an environmentally sustainable manner subject to certain criteria as laid down in the NIWA report. 41) TCDC notes that the Hauraki Gulf Marine Park Act also refers in Section 8 to the maintenance, protection and where appropriate, the enhancement of the environment, cultural, historical, recreational and physical resources of the Gulf. 42) TCDC submits that Section 8(e) provides for economic growth opportunities such as finfish farming. This section states The maintenance and where appropriate enhancement of the contribution of the natural, historical and physical resources of the Hauraki Gulf, its islands and catchments to the social and economic well-being of the people and communities of the Hauraki Gulf and New Zealand. 43) Finfish farming will provide for both the maintenance and enhancement of the economic well-being of people on the Coromandel Peninsula. It is noted that the words enhancement are predicated with the phrase where appropriate and that this test which goes beyond the RMA should be treated with some caution where it is cited to preclude economic and social development. 44) TCDC also notes that New Zealand Coastal Policy Statement has precedence over the Hauraki Gulf Marine Park Act where they may be inconsistent. In the Preamble to the NZCPS, it states: For the coastal environment of the Hauraki Gulf, the HGMPAct requires that sections 7 & 8 of that Act must be treated as a 3 The full text of the Hauraki Gulf Marine Park Act also makes note of the historic, traditional, cultural, and spiritual relationship of the tangata whenua of the Gulf with the Gulf and its islands (7.2 (a) (i)), and to maintain the soil, air, water and ecosystems of the Gulf. (7.2 (c)). Full details of the Act are available on the Hauraki Gulf Forum website.

8 NZ coastal policy statement Section 10 (2) of the HGMPA states that if there is a conflict between sections 7 & 8, and the provisions of the NZCPS, the NZCPS prevails. 45) The NZCPS has a Policy 8 which specifically relates to aquaculture. This Policy identifies the need to recognise the significant contribution which aquaculture can make to social, economic and cultural well-being, and the need to ensure that planning documents provide for aquaculture in appropriate places. Policy 8 Aquaculture specifically states: Recognise the significant existing and potential contribution of aquaculture to the social, economic and cultural wellbeing of people and communities 46) TCDC submits that the proposed 300 ha finfish zone meets these tests of economic, social and cultural well-being and does so in a manner which can be environmentally sustainable. Therefore, it submits that the deeming into the Regional Coastal Plan is an appropriate response given these criteria, and the regional and national significance of establishing a finfish zone for kingfish and hapuka in an environmentally-suitable area. Conclusion TCDC supports the development of the proposed 300 ha Coromandel Marine Farming Zone. It believes that it has the potential to bring significant economic growth and job opportunities to the District, which will provide major long-term benefits to our communities. TCDC believes that the finfish industry can be developed in an environmentallysustainable way, especially given the criteria set down in the NIWA report. Furthermore, it notes that any proposal to farm finfish will still need to go through an extensive consenting process and that this will provide the appropriate checks and balances to make sure that the finfish industry is sustainable in the long-term. TCDC thanks the Ministerial Advisory Panel for considering its submission. Steve Ruru Chief Executive Address for Service: Steve Ruru Chief Executive Thames-Coromandel District Council Private Bag MacKay Street, Thames Telephone: steve.ruru@tcdc.govt.nz