Category Archives: Submissions and Letters

Submission on Mitigation of Sedimentation in the Sounds

The Guardians is sending a submission to the Council Plan relating to the issue of sedimentation from forestry activities and the damage that this causes to the life of the Sounds.

The submission itself can be read here:

Mitigating Fine Sediments from Forestry Submission
Mitigating Fine Sediments from Forestry Submission
Mitigating Fine Sediments from Forestry Submission.pdf
436.8 KB

Please support this by adding your support to the document. You can do this by sending your name, address and email to the Guardians of the Sounds using our contact form.

The Councils own weighty document on the subject can be downloaded here:

Mitigating Fine Sediment from Forestry in Coastal Waters of the Marlborough Sounds
Mitigating Fine Sediment from Forestry in Coastal Waters of the Marlborough Sounds
3.8 MB
Posted in Foreshore and Seabed, Forestry, Submissions and Letters | Comments Off on Submission on Mitigation of Sedimentation in the Sounds

Submission on Marine Protected Areas Act

To the Ministers and advisors responsible for the Marine Protected Area discussion document:
As the lead conservation group in the Marlborough Sounds and environs, with a substantial number of supporters and members, Guardians of the Sounds (GOS) support the need to reform the Marine Reserves Act 1971, as the current legislation is too restrictive in only allowing marine reserves for scientific purposes.

The primary objective of the Marine Protected Areas Act should be to create marine reserves/MPA’s for the purpose of protecting and restoring biodiversity within the whole of New Zealand’s marine environment (as recommended and promoted by the IUCN). We support legislation that can deliver a comprehensive, adequate and representative network of Marine Reserves (fully protected areas) and other Marine Protected Areas. These areas should contain representative examples of the full range of marine communities and ecosystems and also outstanding, rare, distinctive or important marine habitats. We particularly need more, and larger, no-take reserves in our coastal waters close to population and recreation centres, where pollution, sedimentation in particular and fishing pressure have seriously degraded many marine ecosystems and their biodiversity. In addition, these no-take Marine Reserves can provide significant opportunities for ecologically sustainable business ventures, education and scientific research.

The Minister for the Environment, Dr Nick Smith, recently stated that New Zealand should aspire to be world leader in ocean management, but we are currently woefully behind what is happening in other countries. GOS believe we have to look beyond our borders to find a robust and achievable solution for the Marlborough Sounds and other areas under threat in our Exclusive Economic Zone (EEZ), one of the  largest in the world.

For example, at the recent World Parks Congress in Australia in late 2014, a recommendation was made to urgently increase the area that is managed in systems of Marine Protected Areas to at least 30% of each marine habitat, which has no extractive activities. This is a further increase in the Convention on Biological Diversity’s Target for 10% of marine areas to be conserved in MPAs by 2020, which New Zealand is still well short of achieving.

GOS are of the firm belief that a potential and realistic solution for this revised act to ensure protection and restoration of marine biodiversity exists and has been proven to work for decades. Namely; large scale, comprehensive and adequate systems of marine management in the shape of Marine Protected Areas (MPA’s), incorporating spatial planning and sanctuary zones (NZ marine reserves). These are already in place around the world, the most famous probably being the Great Barrier Reef Marine Park (GBRMP).
GOS also believe that for maximum efficiency and ease of public involvement and support, all existing and proposed MPA’s designated under this new MPA act, should be managed and overseen by a specific, adequately resourced Marine section within the DOC, rather than across a number of agencies and Ministerial Departments as proposed.
GOS believe it is also crucial that this legislation is applied to the whole of New Zealand’s marine environment including the Exclusive Economic Zone (EEZ) and the Extended Continental Shelf and not restrict it to only the Territorial Sea. We need robust legislation that delivers protection within New Zealand’s whole Marine Environment, and certainty for its flora, fauna and users. A resilient economy requires a vigorous, healthy environment. This long term protection of the marine environment should not now or ever be constrained or compromised by oil, gas, mineral mining, or other extractive interests.

Marine Protected Areas must have the primary purpose of protecting biodiversity, and so we support the inclusion of Marine Reserves, species-specific sanctuaries, and Seabed Reserves as tools in this legislation. However, in order to ensure ‘New Zealand’s international obligations in relation to the marine environment are met’, they must be available throughout the whole of New Zealand’s Exclusive Economic Zone (EEZ) and Extended Continental Shelf and not restricted to the Territorial Sea, as currently advocated.
While we support the creation of the Kermadec Ocean Sanctuary, the proposed MPA legislation must also include a formal and straightforward mechanism for creating other Marine Protected Areas in the EEZ.
GOS do not support including Recreational Fishing Parks in this legislation as they have no known conservation value and do not protect or enhance biodiversity. The IUCN also state that recreational fishing parks are not marine protected areas per se. In particular, GOS do not believe that the proposed Marlborough Sounds Recreational Fishing Park, first announced by Dr Nick Smith and Nathan Guy, prior to the last election, will achieve any significant improvement for the overall biodiversity, benthic, pelagic and coastal habitats. Also of concern, given that less than less than 20% of the population of New Zealand fish recreationally (MPI figures 2010), this proposal could be seen by the remaining 80% as being irrelevant, inappropriate and far too exclusive, catering only to one user group and even an offensive name by those who would wish to see the habitats, flora and fauna of the Sounds managed and protected for the benefit of all.
Tools for the sustainable management of fisheries are already available in the Fisheries Act 1996 and if, due to election promises, a decision is taken to pursue this approach, Recreational Fishing Parks should remain there. If fishing parks are to be included in the existing Fisheries Act legislation, they must allow for a representative network of no-take Marine Reserves within them to give them conservation value and to enhance the educational, scientific and recreational opportunities for non-extractive users; snorkellors, divers, eco-tourism etc.
Blue cod have been heavily depleted everywhere by commercial and recreational fishers over the years and have understandably showed signs of recovery (increase in size and abundance) when their habitat is protected ie.Taputeranga Marine Reserve. This is one of the few reserves worldwide that had a baseline study performed before the establishment of the reserve in 2008, allowing a more adequate approach for the detection of changes due to reservation status. Results to date suggest that there is a positive reserve effect on the abundance and size of blue cod. GOS believe that habitat protection for Blue Cod in particular from all fishing impacts in the Marlborough Sounds, should include all the enclosed bays and 463m off all islands (as at Long Island MR) i.e. fishing of any type only permitted in open channels.
GOS fully support MPAs being recognised in Regional Coastal Plans. We also support applications for land based activities subject to the RMA being required to take into account their effect on MPAs, as pollution from land based activities such as excessive nutrients and sediment are a major source of degradation of our coastal environment.
GOS fully support all existing no-take marine reserves being transitioned, with all their current protections, to the new legislation. There should also be a provision for restoration of existing marine reserves and potential new ones, given the level of degradation from human activities in particular, as well as environmental impacts
Given that the Marlborough Sounds has almost 20% of New Zealand’s coastline, GOS believe that it should be the first marine and coastal area to be afforded the same level of protection and management as the multi zoned, spatially managed GBRMP and that planning for this designation should proceed ASAP. To that end, GOS would also hope to be involved in further developments and amendments to this proposal to develop a new MPA Act, in order that it meets current and future international commitments.


Bill Foster
Vice-Chairman, Guardians of the Sounds
PO Box 197, Picton, 7220

Posted in Aquaculture, Fisheries, Sounds Biosphere, Sounds Management, Submissions and Letters | Comments Off on Submission on Marine Protected Areas Act

Application for a Fish Farm, in Beatrix Bay – Pelorus Sound

Ngai Tahu have applied for same. Hearings of submissions for, or against, late February.

Posted in Submissions and Letters | Comments Off on Application for a Fish Farm, in Beatrix Bay – Pelorus Sound

Submission to the Aquaculture Bill Select Committee

The Guardians of the Sounds, an environmental group made up of Marlborough Sounds property owners , recreational users and tourism operators, would like to make our feelings known to your select committee and would very much like the opportunity to address your committee in person.

The Marlborough Sounds, and in particular the Queen Charlotte Sound, is the largest recreation and tourism area between the Hauraki gulf and Fiordland., it is not only Nationally important but Internationally important. Our tourists tell us that there are very few Sounds like this in the world and it is of international importance that they are protected, enhanced and restored for future generations.

Continue reading

Posted in Aquaculture, Submissions and Letters | Comments Off on Submission to the Aquaculture Bill Select Committee

Foreshore and Seabed Submission

Dear Minister

My wife Takutai and I attended your road show in Blenheim. I raised an issue; you said I would be contacted so there would be further discussion.
Your secretary took our contact details but as yet contact has not been made!

Ownership of the seabed is an issue about perception. In 1850 Maori owned and controlled the vast majority of NZ, the pakeha population was roughly 2,000 people Maori population over 500,000.

Continue reading

Posted in Aquaculture, Foreshore and Seabed, Sounds Management, Submissions and Letters | Comments Off on Foreshore and Seabed Submission

ERMA: Hearing dates set for reassessment of methyl bromide

Dates have now been set for five hearings to be held in May 2010 as part of the next stage of the methyl bromide reassessment process.

The period for commenting on the application for reassessment closed in late February 2010. A total of 92 submissions were received. ERMA New Zealand is now reviewing submissions. Once done, the staff will prepare an update paper for the decision-making committee of the Environmental Risk Management Authority to consider. This will include a summary of submissions and any further relevant information, as well as the staff’s recommendation in light of submissions.

Some of the issues raised in the submissions include buffer zones, modelling, monitoring, recapture and public health concerns.

Approximately 40 per cent of submitters asked to speak at a hearing.

The hearings are set down for:

  • Monday, 17 May in Wellington;
  • Tuesday, 18 May in Nelson;
  • Wednesday, 19 May in Picton/Blenheim;
  • Thursday, 20 May in Tauranga; and
  • Friday, 21 May in Auckland.

Venues and times will be confirmed shortly and submitters who have asked to speak at a hearing will be contacted to make arrangements.

After the hearings, the Environmental Risk Management Authority will consider all information put before it, from all sources, before making its decision on future use of the substance.

The decision could approve the use of methyl bromide for some or all of its current uses, add stricter controls, or prohibit some or all of its uses.

A final decision is expected in mid to late 2010.

For further information on the reassessment, visit the homepage at

Members of the public are welcome to attend the hearings, though only submitters may speak.

If you would like to attend a hearing, please register your interest with Samantha Smith,, 04 918 4880 begin_of_the_skype_highlighting 04 918 4880 end_of_the_skype_highlighting, to ensure you are advised of venues and times.

Posted in Methyl Bromide, Submissions and Letters | Tagged | Comments Off on ERMA: Hearing dates set for reassessment of methyl bromide

Submission to Foreshore and Seabed Review panel

Kia Ora koutou,

The Guardians of the Sounds would like to acknowledge Maori rights to the Foreshore and Seabed, those rights had never been extinguished through legislation, nor had it ever been purchased, the foreshore and seabed legislation was in our view a modern day act of confiscation.

Guardians have fought long and hard to protect the natural environment of the Totaranui,( Queen Charlotte Sounds.) and the culture and physical health and well being of our people.

The whole foreshore and seabed debarcle started here in Marlborough, as a result of squabbles over  unfair allocation of the seabed for aquaculture farms , this was because of the way that the MDC hearings committee had allowed themselves to be manipulated by the industry players. In other words they had allowed themselves to be corrupted.

Well after all their posturing it is happening again, the MDC have stuck a backroom deal with the  aquaculture industry, they are seeking a variation to the district plan which will get rid of the tendering process,and allow aquaculture companies to apply for private plan changes to select AMA areas.( Aquaculture Marine Areas. )    All this without public consultation.

If a company wants a farm in an area that is not designated as an AMA it can apply to the MOF’s and they will allocate them with an experimental license.

This will mean that the seabed of the Marlborough Sounds will end up being owned by large multinational companies who will monopolize the seabed , the terrible pollution that results from aquaculture farms will ruin the sounds environment and the Sounds people will be powerless to stop it.

You might well say that marine farmers don’t own the sea bed that they only have a right to occupy for a period of time, that’s correct technically, the term is usually for 25 yrs , however we have tried to get salmon farms removed when their time was up but was told that  council  could apply new  conditions, but could not remove the farms.  So once they are allocated these companies have a transferable right to the seabed in perpeturity.

The Port Company a subsidiary of the MDC have recently embarked on a course of action which will give them not ownership per say, but absolute control of the foreshore and seabed of Shakespear bay, Waikawa Bay and whatamungo Bays.

This is over allocation of boat moorings and the right to occupy the seabed. When coastal occupancy charges are introduced the MDC will be making a fortune out of the seabed allocations in the Marlborugh Sounds and Maori wont have a bar of it.

The Port Company also have plans for a massive marina development in Waikawa Bay, out over our cockle beds and are steaming ahead with these plans over top of Iwi objections.

These are all issues that need to be addressed by the Foreshore and Seabed Act, the implications are far more serious than just concentrating on public access.

Another thing to be wary of is that all NZ Port companies are council owned and their returns are very poor, any council accountant will tell you it would be far better financially for them to privatize, this would inevitably result in foreign ownership of NZ Ports.

An interesting thing was discovered during the claims process, and that was that when Picton town was purchased by The NZ Company from Te Atiawa they also purchase ownership of Picton Harbour, so back then it was acknowleged that Maori had legal ownership of the seabed.

Posted in Aquaculture, Submissions and Letters | Comments Off on Submission to Foreshore and Seabed Review panel

Private Plan Change to create AMA Areas

Sounds property owners , Tourism operators, recreational users, Sounds property owners, tourism operators, recreational users, fishermen, divers, walkers all need to be aware of the Councils current intent to have a variation to change the Sounds plan to get rid of the current Tendering process. This will enable any company applying for an AMA area can be assured they are successful in the resource consent process that they will be granted that area.

The government have instructed local government to create AMA (aquaculture marine areas.) This would be an unpopular move, council have collaborated with the aquaculture industry and told them if they get rid of the tendering process and give them surety the industry can then apply for whatever areas they want as AMA’s (eg areas which are currently prohibited)

This will facilitate another gold rush of applications. I realise the current state of the economy is not conducive to growth but it will pick up. As soon as demand exceeds supply the private plan changes will flood in. At the moment rules in the current plan are not robust enough to regulate or do compliance properly.

Council know and has said later this year they will have a variation to rewrite the Aquaculture laws.

This is fundamentally wrong, they are going to get rid of the tendering process. This will allow industry to choose their own AMA areas and have surety. Knowing that the public won’t be able to affect the process and later after the damage is done they will have an upgrade of the Aquaculture laws.

You say that the industry need surety; the public need surety as well.

This is the cart before the horse.

Council says it is user pays and why should the public have to fund AMA applications for the benefit of industry. That sounds reasonable, unfortunately we know what the end result of these changes will be. The establishment of AMA areas should have been a process instigated by council through a public consultation round so that the public have a chance to say if, where or not at all, with this process Industry chooses and the public have to use a very expensive process using lawyers to object.

The Sounds will become one great big aquaculture farm. We will be unable to stop it, at the hearings the applicants will have a couple of lawyers, RMA consultants, landscape architect, expert witnesses and if the public cannot match their line up, and of course we cannot, the economic argument will win every time. It will allow for privatisation of our sea bed.

Continue reading

Posted in Aquaculture, Sounds Management, Submissions and Letters | Comments Off on Private Plan Change to create AMA Areas

Wilding Pine

23rd December 2007

To whom it May concern,

The Guardians of the Sounds an incorporated society with a membership made up of local marlb people, Sounds property owners and Sounds users from both around NZ and overseas, we have been actively campaigning for the restoration of the natural Sounds environment for 10 years.

One of the concerns at the top of our list is the issue of wilding pines, they are multiplying at such an alarming rate, that we believe that within 10- 20 yrs the whole Southern side of the sound will become one big pine tree plantation.

We simply cannot sit and wait for the Agencies to act, because by then it will be too late. This is a grass roots from the ground up community initiative , it is about the Sounds community taking ownership .

We endorse and support the efforts of The Marlborough Sounds Restoration Trust, The reports they have had prepared are very thorough , having been prepared by professionals who are the South Islands foremost experts in their fields with excellent local knowledge who are well known to our local DOC and District council agencies .

Guardians will help and support the MSRT in any way possible.

Your Sincerely,

Pete Beech,

Chairman ,Guardians of The Sounds.

Posted in Forestry, Submissions and Letters | Comments Off on Wilding Pine

Submission re Marine Environment and Blue Cod Fishery

Submission re Marine Environment and Blue Cod Fishery in the Marlborough Sounds.
April 2008, Danny and Lyn Boulton

To embrace eco-system based and integrated management preserving a minimum of 35% of the coastal area of the Marlborough Sounds.

Before you say no be sure you understand the science and evidence that supports this submission’.

Continue reading

Posted in Aquaculture, Fisheries, Sounds Management, Submissions and Letters | Comments Off on Submission re Marine Environment and Blue Cod Fishery