Category Archives: Submissions and Letters

Submission to EPA against King Salmon by Pete Beach

It is with a heavy heart that I make this submission, over 20 yrs ago I formed an environmental watch dog group called “Guardians of the Sounds “ to try and protect the natural resources of our Sounds and protect the rights of the Sounds Community.

After 20 yrs of advocacy work you would think that the govts role in Sustainable Management of the Sounds would of improved out of sight.

We have seen the transition of the Ministry Of Fisheries , who did a terrible job of managing our fisheries resource to now calling themselves MPI, they have formed a virtual partnership with the Foreign owned multinational “King Salmon. “ along with Te Atiawa Trust.

You know as well as I that what they should be doing is creating a long term Sustainable, Holistic, management plan for NZ’s native fish stocks, that will guarantee healthy fish stocks into the future . the individual quota system is fundamentally floored in that it focuses on individual species rather than a holistic model , and it will fail.

When the native fish stocks are all gone they plan to replace them with farmed fish ! and plan to legislate to make the Sounds into one great big aquaculture growing area.

The really sad thing is that they know full well that it will become a polluted , diseased, cess pit within 20 yrs. It doesn’t worry them because like the fishermen, bottom scallop dredgers, divers, sealers, whalers, forestry industry,pastoral farmers, Dairy farmers and freezing works before they will create a mono culture farming Salmon that will give good returns initially but will be non Sustainable long term.

The current fisheries management is failing because of competition greed and corruption, their fish farming model will fail because of pollution and disease.

My whanau have lived, worked, fished, farmed and built boats in the Sounds for 7 generations, collectively we have experienced all of the failed monocultures, for the last 30 yrs we have kept a very close eye on Salmon farming both here and around the world.

Everywhere they have farmed them in sea cages intensively they have been an environmental disaster, and here is no different. It is the same water, the same fish, same methods, same feed.

How can a government in this day and age with all their educated staff, environmental advisers, scientists, Agency staff, like DOC, MOE allow a rort like this to happen .

We like to think that our great grandfathers didn’t know what the effects of deforestation of the Sounds would cause or the hunting of the southern Right Whales would lead to their virtual extinction. But they do , they know exactly what is going to happen as a result of this application.

We are so tired of reading the lies from King Salmon , they argued for years that their farms where sustainable, no pollution, no disease, our farms don’t cause algy blooms. We wont put our fish farms over your traditional fishing spots or spawning areas, we wont prevent you from gathering Kaimoana, our industry wont affect your custmary or recreational fishing or diving areas, your people wont get sick . diseased salmon wont infect native fish stocks.

They are still saying that their farms are fully assimilative, rubbish ,the bottom under farms that were closed 15 yrs ago are still black oozy muck, that nothing can live in, we are sick of their lies And we are ashamed that a responsible well informed government could ignore decisions made by the Supreme Court, blaze ahead by applying to move these farms and increasing the amount of feed 3 fold without waiting for results on the environmental impact of the latest high flow farms and conspire with a multinational company and take away our democratic rights.


Company scientists and expert witnesses are nothing but paid lairs, they are saying that the farms are unsustainable in low flow sites, contrary to all the King salmon dogma that the Ministry Of Fisheries and MDC has accepted as gospel all these years.

This application By MPI is an acknowledgement that all the Science that King Salmon has been promoting as sustainable all these years is false, the Sounds community have known this all along but the agencies wouldnt listen to us.

The belief that moving farms into high flow sights will make the industry sustainable is misleading and potentially disastrous for the Sounds Eco system. The reason they have made this application in defiance of the Supreme court is because they know that there is no way that fish farms that are stocked at current levels will ever be able to achieve the target that MPI have set of one Billion Dollars worth of product a yr by 20 25. This application is all about intensification.

We have been told that the amount of feed applied for would produce the equivalent amount of nitrogen as the amount of sewerage from 400,000 people or 56 ,000 dairy cows.

I suspect that you will recommend that these sites are granted as “ Controlled Activities “ with very long licenses, Controlled Activities are licences in Perpetuity, and should not be allowed, any licence for a fish farms should be reviewed every 5 yrs as they are in Norway.

Personally I don’t believe these farms shouldn’t be allowed in the Sounds full stop, but in some ways the low flow sites are the better of the two evils, in a low flow site the waste falls to the bottom , this forms an anaerobic build up underneath the farms that in time give off methane gas, phosphorous and other toxins that eventually become anoxic, the lack of oxygen kills their own fish.

If you move those farms into high flow sites, only 20% of the waste falls to the bottom the other 80% gets distributed all around the Sounds by the flood tide. In 6 hrs a toxic algy bloom will travel the length of the Sound. This has been proven. The nitrogen enrichment will result in the only creatures living in the Sounds will be Algy blooms and jelly fish, they will be creating a Dead Zone, this has happened in the Adriatic, The Gulf of Mexico, The Sea Of Japan, why would it not happen here.

The other risk is that shown in other countries is the increase in acidification that could have a serious impact on the shells of our Kaimoana and threaten the paua industry.

It is wrong for a government that has a duty of care to provide for the health and safety of its people to allow an industry to operate and develop that has knowingly caused paralytic algy blooms capable of causing peoples diaphragms to seize and their lungs to stop, these people could die from eating contaminated kaimoana.

I f this happens and the Ministry of Health have prior knowledge are they not responsible.

I told the Ministry of Health who had erected a sign in Waikawa that said If you eat shell fish you could get sick . I told them that they should change the sign to say that “If you consume kaimoana contaminated with Paralytic Algie bloom you could DIE ! “

Every year for the last five years we have been unable to collect Kaimoana over the summer months because of Paralytic algy blooms. If Te Atiawa Trust wasn’t partnered up to this company they should be enraged about losing the fundamental traditional right to gather Kaimoana and the lost of yet another popular fishing and diving spot to another massive fish farm which will destroy all the native ecology for hundreds of metres all around it.

What MPI don’t appreciate is that Totaranui is like a washing machine bowl, the tide will spread the nitrogens and toxins to every part of it, Cancer although concentrated in one area of the body will eventually kill the host.

Does the 2nd article of the Treaty of Waitangi not say, “Full Exclusive and UNDISTURBED possession of lands forests and fisheries ! A company that is knowingly poisioning our kaimoana and our community is in contravention of Article 2 of the Treaty of Waitangi.

At the EPA Hearing in 2013 the Judge told us that our references to the Treaty of Waitangi were

“ Nothing but a distraction, “ This was a terrible insult to Maori, did he say this because of a lack of understanding about Te Ao Maori / ( Maori world view of the natural world, ) or was it because he felt that The Treaty Of Waitangi has no basis in the law and he wasn’t obligated to give regard to it.

The treaty is mentioned in over 30 acts, my understanding is that law makers must take these acts into consideration, The main one being the Conservation Act 1987 section 4.

“This act shall be so interpreted and administered as to give effect to the principals of the Treaty of Waitangi.” Local Maori strongly support the concept of Kaitiakitanga as defined by section 2 of the RMA 1991- “ The exercise of guardianship, and in relation to a resource, it includes the ethic of stewardship based on the nature of the resource itself.”

Chinnook Salmon is not a native species , but the adverse effects of Salmon farming have a very real potential to threaten our Mahinga kai , native fish stocks and threaten the health and safety of our community.

Section 8 of the RMA says “ shall take into account the principals of the treaty of Waitangi. “

Section 6 e requires decision makers to “ recognise and provide for the relationship of Maori and their culture and traditions with their ancestral lands water, site wahitapu and other taonga.

Section 7, sets out persons exercising functions and powers under the act are to have particular regard to including Kaitiakitanga

Under the Treaty of Waitangi ( fisheries claims, ) settlement act 1992 “ it states, May be seen as an affirmation of customary rights that would other wise be recognised by the common law. “”

I have included this because, if as a court you feel that you are not required to acknowledge the Treaty of Waitangi or just see it as a “Distraction, “ please pay recognition to our customary rights to be able to gather kaimaona and fish( without getting sick) and to help feed our kids and be able to swim in clean unpolluted water that is recognised by international and customary law, if not in LAW but in LORE.

I certainly hope that this court pays due regard and respect to the Treaty of Waitangi the founding document of our country.

We have shared our LORE, ( Oral histories, ) before with the EPA, who took no notice.

The old people had a holistic view of the Sounds ecosystem, they believed that all of the elements the air, the bush, the sea, the river deltas and lagoons , the tide the fish , kaimoana all had a life force and that they where all dependant on each other for mutual survival.

They called the Sounds Totaranui, the emphasis is on the word Tara which is a womens private parts, the name meant that the Sounds was their mother, and Tory channel was the Mothers womb, the high peak directly behind the channel Entrance was called Raiatea, the penis that fertilised the womb.

The Bay called Onapua , the Pua is the receptacle for life where the seed is germinated , isn’t it interesting to learn that it is from this bay where they believe the Algy blooms originate.

And the southern most headland of Arapawa is Called Rua O Moko , ( this name has a duel meaning, ) one is””

“ God of Earth Quakes,” the other meaning is “ The Unborn Child, “ and the earth quakes are the mothers birthing pains.

This middle section of the channel was the most densely populated by Maori over the Summer months, where they were actively involved in gathering and storing enough kaimoana to carry them through the winters.

They lived in bays on both sides of the middle sections of the channel their pa sites where called called Kaihinu, and Moioio Island, because these bays and headlands are much more sheltered than the exposed bays at either end like Okukuri and Maraetai/ Dieffienbach where the Southerly storms become extremely violent.

Of course the same applies today, and that central section of the channel was the most favourite fishing spots for customary and recreational fishermen & divers

The MPI have taken it upon themselves to make The channel into a salmon farming / aquaculture growing area, I was told the other day that the MDC Aquaculture working group has been asked to divide the whole of the Marlb sounds up into paddocks ! I suspect that MPI have plans to develop the Marlb Sounds into one great big aquaculture growing area to the detriment of all other user groups and our Sounds communities rights to Tourism, customary and recreational fishing and diving.

Remember that there are hundreds of people today who are descended from Maori who lived in Tory channel and Arapawa Island, also hundreds who descend from whalers and fishermen from Tar White.

There are also very significant Urupa like Moioio Island where over 300 souls where slaughtered during the musket wars and the grave site of Huriwhenua, one of Te Atiawas paramount chiefs.

Don’t take it for granted that because Te Atiawa Trust has thrown their hand in with King Salmon that local whanau Hapu agree with it, at the last EPA hearing , Whanau Hapu called iwi hui where they were given a clear mandate to tell the Te Atiawa Trust to oppose their own partners.

They were told by the Trust that when the people voted them onto the Trust they had given them a mandate to make independent decisions.

King salmon were very clever in being able to convince Te Atiawa Trust to join them as partners, this court needs to acknowledge that Te Atiawa are just one of 8 Iwi in the Top of the South.

I guarantee that in the future local Maori who have been disenfranchised by their own Iwi trust will turn on them. Nothing is more important to Maori than their rights to be able to harvest fish and kaimoana , especially for weddings, 21’sts, tangi at the Marae, this marriage with King Salmon will end badly for Te Atiawa Trust, already the chairperson has been forced to step down.

It wont be long before local Maori will need to go to the supermarket to buy their Kina and mussels out of plastic punnets !

The new Salmon farm at Ngamaho will pollute and destroy the best cockle bed in NZ in the bay directly to the South of the farm, the EPA refused to listen to our warnings about this.

I am a 5th generation Soundie, I have lived in the Sounds my entire life, I’ve never been anywhere, I’m 60 yrs old and have spent my life plying these waters, for the last 25 yrs I have been a commercial skipper first working as a commercial fisherman then skippering commercial tourist boats and water taxis. For the last 20 yrs my wife Takutai and myself have been running an ecotour operation in the Sounds and Tory channel.

After spending a lifetime studying the ecology of the Sounds I whole heartedly agree with the Maori analogy of the Sounds being the Mother and the Channel being the mothers womb.

You need to look at the big picture, ocean water being swept all the way by southerly storms all the way from Antartica, rich in Zoo plankton and phytoplankton, when it reaches Cook Strait it is forced into a funnel, Tory Channel leads directly off Cook Strait. Phytoplankton nets that we have dragged around in Tory Channel entrance called Kura Te Au show that the strong tidal flow is rich in Zooplankton and Phytoplankton.

This is spat or fish eggs that sweep up the Kaikaura Coast , they have a high oil content which evaporates over 3 days and when they reach the Channel they sink to the bottom. When the fish and Kaimoana spat in Tory channel it is carried by the flood tide and distributed all around Totaranui.

Before the Fast Ferries trashed it, Tory channel was regarded as the most productive area of fish and Kaimoana in NZ.. What I want to make sure that you understand is that , If there is one area of Totaranui that you should protect over all others its Tory channel, The Mothers Womb, if The ecology of the Channel dies , which it will with intense aquaculture, the the egology of Totaranui will die with it. Be clear on that point it is very true !

The Sounds ecology has reached a tipping point, there are only 20 Hector Dolphins left who dwell permanently in the Sounds, and for the last 4 yrs the bottle nose Dolphins have disappeared all summer long. This is a result of the MOF allowing the destruction of the bottom of the Sounds ecology as a result of the bottom dredging by Scallop and kina dredgers, both commercial and recreational .

When the flood tide leaves Tory channel and enters Totaranui it sweeps straight across to the other side where the Ruakaka Salmon farm is sited, there is one of only 3 King Shag roosting sites in Totaranui, we know that the algy blooms caused by salmon Farming are disastrous for the King Shags. The shags are bottom feeders and feed in the tidal flow that sweeps across between Dieffenback and Bull head.

We take out a lot of bird watching parties , our tourism industry would suffer greatly from the loss of these wonderful birds, we have known people to travel all the way from Europe just so they can tick that box.

There are already too many salmon farms in Tory channel for the ecosystem to be able to assimilate. Don’t allow another one, it could well be the straw that breaks the camels back.

There are lots of issues over shipping, ( another large salmon farm set up opposite a blind corner is a navigational hazard, I saw 3 ferries all passing each other right opposite that point just the other day.

We have experienced what happens when a fish farm breaks lose from its moorings and sweeps down the channel, its happened before and will happen again. Fish farms shouldn’t be sited along a shipping route.)

Sedimentation caused by Forestry, bottom dredging for scallops, Kinas and collapse of the fish stocks. I have an accumulated knowledge based on the oral histories of 3 generations of my ancestors who like me spent their whole lives living in the Sounds and we have also learned to respect the oral traditions of Maori who have lived in the Sounds for between 1 and 2,000 years. MPI are making management decisions about things you and your scientists know nothing about, be very careful, the Sounds ecology is in a state of collapse. Don’t tip it over the edge with misguided belief in short term gain.

I see the ecology going thru its paces every day , the Maori people in whanganui are asking people to think of their Awa, the whanganui river as a living entity. That is a wonderful concept , think about the analogy with the Sounds and ask yourself if you are making the right decisions. ( would you disrespect your mother ! )



As a tourism operator who over 20 yrs has taken thousands of foreign tourists and thousands of kiwi school children around the Sounds, let me tell you that the foreign tourists are all well aware of the pollution and disease issues with Salmon farming and they don’t want a bar of them, they don’t want to be taken to look at them and they don’t like talking about them, they have travelled to the bottom of the world to look at our pristine nature show.

In the last 2 months We have taken out 12 school classes who are wanting to learn more about the sustainability of salmon farming in the Sounds, there is a big public backlash from the people of Marlb, to this proposal, interesting that now its coming from the schools

The Government has allowed our fresh water rivers and streams to become terribly polluted, please explore the parallels between the effects of over intensification of dairy farming ,make sure that your decisions don’t do the same to our beautiful Sounds. We have stripped her of all the whales and seals, we have filled in all the lagoons and dredged out the deltas where the baitfish bred, With no breeding grounds left there is no Bait fish to entice the enormous pods of pilot whales that used to come into the Sounds in my grandfathers time, we have ploughed up the bottom and destroyed her ecology and through mismanagement we have allowed the fish stocks to be decimated.

We have deforested the hills, for their 2000 yr old podocarps, pastral farmed for 150 yrs, now covered the hills with exotic pines, the sedimentation from which has smothered all our kaimoana beds and kelp beds.

The wilding pines eradication has cost NZ and the local community millions of dollars to remove with no help from the forestry industry.

Don’t make the same mistake with yet another mono culture , we know that salmon farming will fail, and we know that when it does the aquaculture industry will just turn their backs and walk away, it will be left up to the Sounds community to clean up the mess.

Finally, the thing that I am extremely concerned about is MPI taking the management rights off our local government in regards aquaculture.

Many of us stakeholders have spent yrs now consulting on our Sounds plan, then MPI come along and tell our council that they are taking Aquaculture out of the district plan . How dare they !

They have defiled our democratic process, this is the Dilution of Democracy, whats next, when they decide that they want to fast track forestry, will they pull that also.

They are on a slippery slope !!! where does this stop.

Democracy is a frustrating system, but it’s the best system we have got, if a law is unjust as a community we can change it , if there is no law we can create one.

We elect people as councillors to represent us, people who know our history , our culture and environment, if they don’t know we can educate them , but we rely on them to manage our Sounds.

This is local government by the people for the people.

This is Democracy, MPI have no right to interfere in this process, and to call the application by one company a matter of National importance is an insult to everyone’s intelligence.

If they must grow this industry that takes fish stocks off poor people to convert into feed to sell to rich people , look for a Truly Sustainable method, I think that storms and raising water temperature will prevent open sea farming .Although it is Ideal for mussel farming ,there is an open sea mussel farm being developed now out in Clifford bay which has been developed because of over crowding of mussel farms in the Pelorus, and lack of sustainable growth because of over competition and lack of feed. Pure economics will drive this development.

I think that land based fish farming is the future, where they dig their ponds out of the land, pump in the cool clear waters of Cook Strait, circulate around the ponds, feed the fish on Sea weed which the industry can farm themselves to what in time will all be herbivore fish, control the water temperature and filter the waste out ( to be processed in an environmentally acceptable manner) before the filtered water is returned to the sea.


The farm will be near the town like Blenheim, Riverlands, or lake Grassmere where there are huge lagoons right along side the road and rail network. close to the coast, easy access for the large quantities of feed and be close to the town for workers access. Yes it would be more expensive and would reduce their profit margins, but the only reason their profits are so good is because they don’t pay rates for their sites and they just dump their waste in the sea. The Ministry of environment should insist on this industry having to dispose of their waste effectively without pollution.

The company will have to pay rates for the land and will have to pay to dispose of their rubbish, like every other industry, As a govt agency MPI need to make this industry clean up their act

MPI’S turning a blind eye to the terrible pollution of our rivers is bad enough, they should man up and clean up this industry, why should the Sounds environment have to subsidize their waste.

King Salmon say this technology isn’t available , Rubbish, they have had them in Canada and Norway for years.

The Norwegians have developed this technology into an extremely productive and profitable enterprise where every part of the process is controllable, water temperature, oxygen levels and the disposal of their waste. Even their waste is processed into a marketable product, this is a truly sustainable system.

The last EPA hearing process cost them between 11 and 15 million dollars , that would of built a magnificent land based closed containment farm that the whole community and country would be proud of.

Remember that King Salmon is just one stake holder, a small player compared to our tourism industry, yet it has the potential to destroy the tourism industry, the Sounds ecology is dying, please don’t make it any worse by adding 5 times the nitrogen and remember the precautionary principal.

Every action has a reaction and every creature in the marine ecosystem is symbiotic.

It is economic necessity that will drive the development of off shore mussel farms, however the only thing that will get Fish farmers to develop land based , closed containment farming is Government policy based on long term sustainable management with due regard to environmental effects , customary rights and the health and safety of our community .

As it stands Fish farmers don’t have to buy the area of seabed they covet, they don’t have to pay rates, they don’t have to dispose of their waste and if and when they leave , they don’t have to dredge their pollution off the bottom , they just turn their backs and leave.

I have limited my submission to only cover Totaranui, That doesn’t mean that I am not concerned about Hoiere, but there are residence from there that have a far better knowledge than me of their own rohe, only thing I will say is that the pollution from the high flow sites there will be distributed by the tide right thru the Sound. One good thing is that in time it will probably destroy the mussel industry, which should be moved out into the open sea.

MPI shouldn’t be looking at high flow sites, they need to be looking at ways of getting Salmon farming out of our Sounds altogether.

I would like to think that with good science and good management we could put in place a long term management plan for a sustainable recreational and customary Sounds fishery. However I suspect that the ever increasing numbers of recreational boats with their more and more sophisticated fish finding technology will mean that the fish resources of the Sounds will inevitably collapse . which will result in the Sounds being made into a marine reserve which long term will be of far greater ecological and economic value to NZ.

I don’t expect that the decision that this court makes will be anything other than MPI policy,

What I will be very interested in is to see your decision peer reviewed by the supreme court and to see whether or not the Supreme court is influenced by government peer pressure or whether the justice system stands above politics.

Peter Beech ( Patron of Guardians of the Sounds )


Posted in Aquaculture, King Salmon EPA Inquiry, Sounds Management, Submissions and Letters | Comments Off on Submission to EPA against King Salmon by Pete Beach

Sounds Salmon Farms Hearing Presentation by Norm Gourdie

I am Norm Gourdie. I’ve lived here in the Sounds, in Ngakuta Bay, the one in Queen Charlotte Sound, just up the Sound from Picton, since 1981, that’s 36 years, and I am passionate about looking after this environment, and all of NZ, the world for that matter.

I am not a practised speaker, so I will be reading my comments, practically as written. You may have a problem with my use of emotive words in my presentation as I am a bit passionate about this issue.

I am just a layman, I have not studied Hearing Protocol and Etiquette, so I ask you to excuse me if I haven’t adhered precisely to the correct format and detail in my comments. You may find my views strongly worded, but this, now, is actually a milded down version of my feelings, in my attempt to use diplomatic language. However I would appreciate your attention and assiduousness in passing them on to the Minister.

My comments will avoid repetition of the technical evidence and expert comment presented in other opposing submissions. Though I request the panel to note, that I endorse and support any information presented here that is factual, true and has integrity.While, at the same time I would urge the panel to join me in rejecting any manipulation of information, whether by selectivity, glossing over relevant points, or lying by omission, and accept only full honesty and full disclosure. In my view the information provided by MPI to the public, before the submission period, was in the nature of propaganda, painting a rosy picture of their proposal, and omitting relevant negative aspects.

I am addressing this important issue voluntarily, using only my own money and especially my own time, I actually resent having to devote my time in fighting this issue, but it is important to do so, to counter a campaign lacking in integrity and credibility, that threatens the well being of the beautiful and, in healthy ways, the bountiful potential of the entire Marlborough Sounds and its visitors. I am concerned the Government are using the South Island and its sea as their dumping ground. Would this sort of pollution be acceptable in the Bay of Islands? No, I think not. They have given the Bay of Islands many new Marine Reserves but have denied the Sounds any, presumably to keep the gate open for greater exploitation here.

And, in saying that, I must express my mildest disappointment in the Ministry for Primary Industry, the Minister himself, and this National Government as a whole, who, in this case, are doing all they can, legally or not, morally or not, in spending an exorbitant amount of money and staff time, in a, patently obvious championing, of one company, New Zealand King Salmon, to help boost their profits, a company that is largely foreign owned, to boot. And to the obvious detriment of the environment. Had they used those resources of money, and staff time, to work towards a cleaner, greener NZ, they would have achieved a much healthier alternative for the world than their bending over backwards to provide the wealthy world with another luxury, at the neglect of the poor. I despair, that this appears to be business as usual, for them?

I question whether MPI’s brief – mandate, whatever, gives them the go ahead to use tax payers’ money to boost a monopoly operation which uses and abuses the Sounds’ environment, absolutely free, while taking very little account, as shown by their selective proposal documents, of all the other values, including the obvious economic benefits, of maintaining the Sounds in a clean, beautiful state.

In adopting the machinations that they have, this Government, its Minister and its Ministry, is being, undemocratic, condescending to its public, and unfair in its selective misdissemination of relevant information. This is especially illustrated by omission of mention of their salmon farm diseases, the glossing over of intelligence and facts, including data on, algal blooms, economics, King Shag welfare, inadequate reporting of monitoring of existing farms as required by the BOI, misrepresentation of statistics, and effects on other species, landscape and natural and cultural aspects. A whole lot of additional research and information, with the full, unskewed disclosure, of the effects of salmon farm interference in the Sounds, should have been produced by King Salmon before the proposal was even looked at. I’m not sure whether this amounts to a lack of information, or selective provision of information, or manipulative disinformation, but I find this approach, to be immorally sneaky, disrespectful to everyone involved, and personally insulting. What sort of government have we got that they think this basic dishonesty is acceptable? I don’t. Perhaps I am an idealist but whatever happened to basic humanity, honesty, respect and plain speaking here, in this wonderful,world leading, country of ours?

Others, appearing, have submitted more detail in regard to those issues so I won’t elaborate. However, please note I do support evidence submitted that shows detriment to the Sounds and its waters, in more detail than my own, and rebuke the Ministry for their selective failure to investigate fully these aspects.

Very little attention has been paid by MPI on many areas of relevance. Aspects such as; Benthic destruction, Water column maltreatment, Nitrogen imbalance, Oxygen depletion, Methane production, Ozone depletion, Consequent global warming effects, Head in the sand neglect of data from other salmon farm best practice, in different parts of the world, Navigation hazards, Effects on the welfare of fish, shellfish and a natural, balanced, sea invironment for all of the native species already living in the Sounds, these are vital questions, to which MPI has hardly attended.

Even the panel’s terms of reference appear to be used as a means of direction towards MPI’s wants. They appear to be applying not fair but foul means to achieve their, craved for, outcome. It seems the previous attempt, via the BOI, was not lucrative enough for them, so they’re trying, underhandedly, in my opinion, a method which is less democratic, less transparent, less opposable and tries to deviously bypass the previous, existing, legal rulings and limitations regarding salmon farming in the Sounds.

King Salmon is a careless operator who, throughout their time of interference with the Sound’s environment, have been a serious polluter. A dearth of monitoring by MPI and evidence that the existing high flow farms are, even now, not meeting the benthic guidelines, suggests, very strongly, to me that King Salmon will continue to focus on their profits and treat the welfare of the Sounds as insignificant. How can anyone reasonably believe that they will perform any differently in the future, or that MPI, in their blinkered support for NZKS, will perform any better at policing them? What future is in store for the Sounds if this disaster goes ahead? More destructive intrusions will likely follow this precedent.

This acceptance of the ongoing defilement, by King Salmon, illustrates clearly the attitude of the Government toward the Sounds. The Sounds biodiversity is already compromised by the Salmon Farms and the failure and indifference of the Ministry to prevent their pollution. Are they going to get King Salmon to clean it up? I ask the Minister to seriously consider this and answer.

I agree with the EDS’ analogy of comparing, King Salmon’s wanting to expand and move their polluting farms to areas with greater flow, to the dairy farmer polluting a small stream then, ‘in mitigation’, increasing his herd and dumping the augmented waste into a faster flowing stream, to dissipate it. This illustrates very clearly to me, the distorted attitudes of those up North, and business, towards our Marlborough Sounds, seeing its values as insignificant, and to be ignored in favour of more money.

MPI. What arrogance, their proposing to ride roughshod over the existing legal structure, which has been carefully studied and instituted in law including; the Supreme Court rulings, the RMA’s intent for the area, the MDC and community’s Regional Plan, the Regional Policy Statement, the Coastal Policy Statement. What disrespect they show the MDC in totally ignoring their local expertise, and ability to manage their own area. How deep in the mire are MPI digging, in trying to use s360A for its very first outing in the hope of getting what they want for King Salmon’ profits?

Already much work, careful considerations and legally binding rulings have been produced regarding Salmon farming in the Sounds, highlighting the values of the area, and limiting the intrusion of salmon farms, but here we are having to go over it all again because the Govt thinks it can inveigle in a new intrusion, for King Salmon exploitation of the area, by giving the same aims a slightly different, dodgy, angle.

I don’t understand this. Surely this is not what Government departments are authorised to do. I worked for DoC for 18 years where, I”m sure, there was a well principled culture. MPI seems to have a deceptive, unhealthy climate pervading their own environment from the top? I wonder if there is something questionable in this love affair, between this Ministry, and what they seem to see as an attractive company. Be mindful of the history, particularly by the MPI’s’ MSWG – Marlborough Salmon Working Group, of less than fair, and even unprincipled, behavior towards the volunteer groups, representatives and individuals, as you consider MPI’s approach to this argument. I thought government was meant to be for the people. This government is concerned, not with people, but purely for the economy, even the OECD identifies this. Please remind Government of the Paris accord and how they should be paying much more attention to the environment, even in the South Island.

MPI have shown now they are very aware of pollution from salmon farms yet the’ve practically ignored doing anything about it before, irresponsibly condoning it as if it was totally acceptable here in the Sounds. They appear to be taking, again selective, interest now that it suits them, so they are pretending now to be the salmon shit police, when they were so quiet before, letting King Salmon away with it all these years. Can we trust them to act any differently in future?

It would be laughable how MPI, in their proposal, note the area of the new farms to be equivalent to the existing, when in fact the effects will be multiplied so hugely, except we can’t laugh when this is such an important distinction. Are they suggesting that 4 or 5 times the uneaten feed and 4 or 5 times the shit excreted from these farms are not going to impact on the water and seabed in a greatly extended area? They look at just their abbreviated footprint, no further. They either don’t know or are not revealing this information, if they have researched this. I find their attitude towards everyone involved to be condescending at least. I ask, was this a puerile attempt to hoodwink us?

Where is DoC? Where is MDC involvement? Where is the Ministry for the Environment? The very people who have the mandates and the expertise to consider the relevant issues in play here. Silence. All muzzled by Govt pressure to reinforce MPI’s’ one sided plan, with the aim of bulldozing through their inappropriate support for King Salmon. It is these organisations, in accord with the community, who’s plan is being threatened with overturning. Who are the experts on the environment but DoC, the Environment Court, the Ministry for the Environment, for heaven’s sake? Are they misnamed that they have been excluded, totally silenced here? Or do MPI consider this proposal has nothing to do with the environment?

I would like to complain, loud and clear, about the very short time frame we, the opposition, were given to compile our case and I apply for an extension of time now, to research especially, what additional information MPI has kept from us. We are ordinary people who have normal lives to live. This process is an imposition at best, an unhealthy stress, trying to gather the facts and putting them together in such a short time allowed, knowing that the MPI have been working on this for years. That is patently not fair. I put, to you, that they have been acting far from fairly throughout this process, and urge you to take this into consideration here. One public ‘drop in’ opportunity, if you could call it that, a one sided propoganda exercise that was meant to satisfy the public consultation requirement. Yes, I attended one.

I’m closing now.

Perhaps you have noticed, but I emphasise I am, gargantuously, opposed to this proposal and I would like you to tell the Minister, from me, to reconsider its legitimacy. I, personally would prefer to see all salmon farms removed from the Sounds. There are, after all, alternative, open sea and land based, options available. Perhaps more costly at this time, but minimal in comparison to the cost to the environment of this proposal’s impact.

I have only attended a hearing once, before the Planning Tribunal. That was a good experience, especially because we won our case. I ask, please, that you now, don’t, put a blot on my success record. Please recommend to the Minister that this case be thrown out on its ear, and berate him for ever presenting the proposal in the first place, wasting your time and mine and all that taxpayer’s money.

Thank you for listening.

= Norm.

Posted in Aquaculture, King Salmon EPA Inquiry, Sounds Management, Submissions and Letters | Comments Off on Sounds Salmon Farms Hearing Presentation by Norm Gourdie

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
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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.

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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.

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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.

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