The enclosed item is the Council review of Marlborough’s Regional Policy Statement and Resource Management Plans.
The following document is the PUA’s response.
Port Underwood Assoc submission on draft RPS aquaculture issues
This can be summarised as
Marine farms should have discretionary activity status, not controlled activity status as the current lack of knowledge of the Sounds ecosystem precludes establishing activities with the permanence of a controlled status. Also, the area is public domain and used for a range of different reasons.
A stronger policy was called for in respect of the size of marine farms. In particualr new marine farms and new extensions should be prohibited within 100 metres of the coastline and should not extend beyond 250 meters from the coastline.
It was noted that the proposal for an extension of marine farms to 300 meters from the shoreline should not be permitted until independent studies are undertaken to demonstrate that this does not have an adverse impact upon other uses and the environment.
It wwas suggested that the mid-bay area of Port Underwood and the entire western coastline of Port Underwood should have a prohibited marine farming status to be consistent with Policy 1.12 of the proposed Marine Farming Policy and other sections of the draft policy statement and management plan. This would add more certainty for all users of Port Underwood and reduce the large amounts of time and money spent by applicants, submitters, and the Council.
In addition, the entire western coastline of Port Underwood should have prohibited marine farming status. Retaining a small section with CMZ 2 status as currently proposed would be an inconsistent anomaly.
It was suggested that the regional policy statement and resource management plan should include a provision to require environmental studies to be undertaken to:
- Determine the level of nutrients in the Sounds
- Determine the level of pollutants in the Sounds
- Determine the impact on nutrients and pollutants to understand the capacity for further marine farming and its impact upon other uses of the Sounds
- Determine the change in levels of nutrients and pollutants in the Sounds subsequent to the introduction of new farms or expansion of existing farms.
Without these studies there will be little understanding of the cumulative impacts of aquaculture and the objective of the Marlborough regional policy statement cannot be met.