SUSTAINABLY GROWING KING SALMON
DRAFT CONDITIONS OF CONSENT
Resource Consents for All Farms
(There will be separate sets of Conditions for each Farm. However, for succinctness, these
Draft Conditions have been written as though they are for one farm and, where there are
differences between farms, these have all been shown. Comments (which will not form part of
the Conditions) are included in Italics)
22 June 2012
Track Changes are shown for Amendments since Draft provided to the EPA 3 May 2012
Coastal Permit
Duration of this coastal permit – 35 years from the date of commencement of this consent [20 years
for White Horse Rock].
Occupancy and Activity
Occupation and Activity Area
1
The occupancy and activity shall be limited to the area shown on the attached plan [Plan for
each consent area to be attached to each consent] and specified within the schedule of
co-ordinates (NZTM) contained in Table 1 (other than for the arrival and departure of vessels
servicing the farm)1.
Table 1: Farm Co-ordinates (NZTM)
Farm Name
Waitata
Kaitira
Tapipi
Easting (NZTM)
1,680,467
1,679,987
1,680,152
1,680,632
1,683,876
1,684,465
1,684,415
1,683,826
1,681,302
1,681,053
Northing (NZTM)
5,464,412
5,464,052
5,463,832
5,464,191
5,464,390
5,464,499
5,464,770
5,464,661
5,462,540
5,462,657
1
Note: While the occupancy and activity associated with the marine farm and marine farming will occur within
the area specified in Condition 1 (subject to the exemption specified), some effects arising from the activities may
be experienced beyond the boundary of this area. For example, the marine farm will be able to be seen and
heard from beyond the boundary of the area, and some waste material will travel beyond the boundary.
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Farm Name
Richmond
Papatua
Kaitapeha
Ruaomoko
Ngamahau
White Horse Rock
2
Easting (NZTM)
1,680,798
1,681,047
1,680,942
1,681,212
1,681,094
1,680,825
1,701,610
1,700,845
1,701,434
1,702,199
1,697,924
1,697,401
1,697,535
1,698,058
1,697,510
1,697,562
1,697,328
1,697,276
1,706,282
1,706,694
1,706,495
1,706,082
1,680,380
1,680,150
1,680,256
1,680,143
1,680,105
Northing (NZTM)
5,462,114
5,461,996
5,460,999
5,461,052
5,461,641
5,461,586
5,459,487
5,458,697
5,458,126
5,458,917
5,435,759
5,435,465
5,435,225
5,435,519
5,434,723
5,435,321
5,435,341
5,434,744
5,435,362
5,435,797
5,435,986
5,435,551
5,464,338
5,464,156
5,464,353
5,464,264
5,464,126
The consented area may be exclusively occupied to the extent necessary to undertake the
activity and ensure the safety and security of the marine farm and all its structures.
Farm Layout
3
The farm layout shall be generally in accordance with the Farm Layout Plan lodged with the
resource consent application and attached to this consent as Figure 1. [Plans to be
amended to show final building layout]
Farming Limited to Salmon
4
The marine farming activity shall be limited to the marine farming of salmon.
5
All farmed salmon shall be from roe sourced in New Zealand.
Noise
6
All marine farming shall be conducted so as to ensure that noise arising from such activities
does not exceed the following noise limits when measured no closer than 250m from any
marine farm surface structure:
•
0700 hours – 2200 hours Monday to Friday
and 0700 hours – 1200 hours Saturday
55 dBA L10
•
On any day between 0700 hours and 2200 hours
No Lmax limit
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•
At all other times including any public holiday
45 dBA L10, and
75 dBA Lmax
7
Noise shall be measured in accordance with NZS 6801:2008. Adjusted levels shall be
determined in accordance with NZS 6802:2008. Any construction activities will meet
standards specified in NZS 6803:1999.
8
The following activities shall be exempt from the above noise standard:
a
b
c
9
Noise generated by navigational aids, safety signals, warning devices, or emergency
pressure relief valves;
Noise generated by emergency work arising from the need to protect life or limb or
prevent loss or serious damage to property or minimise or prevent environmental
damage; or
Noise ordinarily generated by the arrival and departure of vessels servicing the marine
farm.
Prior to any development being undertaken at the farm, a Noise Management Plan shall be
prepared by a suitably qualified acoustic engineer, and provided to the Marlborough District
Council, to confirm that the noise limits above can be complied with and to provide details of
the noise mitigation treatment to be implemented to achieve this. The Noise Management
Plan shall also include provisions that prohibit outdoor radios or similar external speakers on
the farm. The Noise Management Plan may be updated at any time by the consent holder
and the updated Plan provided to the Marlborough District Council. The current Noise
Management Plan shall be complied with at all times.
Submerged Artificial Lighting
10
Underwater lights shall be permitted to be used by the consent holder for the primary purpose
of controlling maturation in salmon. Only the amount of lighting required for beneficial
outcomes for salmon maturation shall be used (unnecessary over-powering of the lights shall
be avoided). A specific approval as to underwater lighting is required from the Harbourmaster
under sections 200, 444(2) and 444(4) of the Maritime Transport Act 1994. A plan of the
underwater lighting shall be supplied to the Marlborough District Council and the
Harbourmaster clearly identifying where lights will be used on the farm at least one month
prior to the lights being installed. The lights shall be installed in accordance with that plan,
subject to any requirements of the Harbourmaster.
King Shag Roosting Site - Buffer Area [Papatua, Waitata and White Horse Rock Farms]
11
As shown on Figure 2 a buffer area of 100m shall be maintained from the King Shag roosting
sites in the vicinity of the [Papatua, Waitata and White Horse Rock] farm, as at the date of the
commencement of this consent, within which no activities associated with the farm shall
occur.
Structures
Location, Layout, Design and Size of Structures
12
The layout of the farm surface structures, and the sub-surface mooring and anchoring
structures shall be generally in accordance with the Farm Layout Plan lodged with the
resource consent application and attached to this consent as Figure 1 [Plans to be
amended to show final building layout]
13
Salmon farm net pens on all farms (except Papatua) shall be steel framed net pens. Net pens
at the Papatua farm shall be plastic circle net pens.
14
All structures shall be situated and secured so as to remain wholly within the boundaries of
the occupancy area specified in Condition 1 at all times.
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15
All salmon farm net pen structures (other than temporary net pens for transferring salmon to
or from the farm) shall be located within the Cage Area Boundary shown on Figure 3. [This
does not apply to White Horse Rock]
16
[At the Papatua farm,] the Cage Area Boundary shall be divided into four rectangular blocks
as shown on Figure 3. A maximum of two rows of circular net pens shall be established at
this farm (one row for two blocks). The net pens may be moved within, and between, the
blocks, in accordance with Condition 42.
17
[Other than at Papatua,] a corner of (one of) the first salmon farm net pen(s) established on
the farm shall be located on the point nominated for that purpose in Condition 20. So long as
there remain salmon farm net pens on the farm, net pens shall be located so as to extend
contiguously from the nominated corner in either direction. [In the case of White Horse Rock,
(one of) the first salmon net pen(s) established on the farm shall be located at one end of the
row of salmon net pens shown in Figure 1 and so long as there remain salmon farm net pens
on the farm, net pens shall be located so as to extend contiguously from that end of the row.]
18
The maximum area of salmon farm net pen structures within the farm (other than temporary
net pens for transferring salmon to or from the farm) shall be 1.5 hectares
except for:
Papatua - where the maximum area shall be 1.26 hectares;
Ruaomoko - where the maximum area shall be 0.75 hectares; and
White Horse Rock – where the maximum area shall be 0.50 hectares.
19
[To be updated to reflect NZ King Salmon’s proposal for buildings (barges) contained
in the evidence of Mr M Preece] Only one building shall be located on the farm (other than
the exceptions below for Ruaomoko, Papatua and White Horse Rock). The building shall
have a maximum footprint of 280m2 and a maximum height of 7.5m above water level.
Except that:
a
b
c
There shall be no building at the Ruaomoko farm. This farm may share the building at the
Kaitapeha farm.
There shall be no building at the Papatua farm.
There shall be no building at the White Horse Rock farm if the Waitata farm is also
developed, in which case the White Horse Rock farm shall share the building at the
Waitata farm.
[At the Kaitapeha farm] All structures shall be located so that they are not visible from the
house in Kaitapeha Bay nor from the beach in the immediate vicinity of the house.
20
The Marlborough District Council shall be notified that structures have been installed on the
farm, and provided with a plan showing the location of those structures, within one month
following the initial installation of the first structure(s) associated with the farm, and within one
month of the addition of any further structures. [Other than at Papatua,] when the Council is
notified of the initial installation of the first structure(s) on the farm, it shall also be informed of
the co-ordinates of the starting corner of the farm for the purposes of Condition 17. The
starting corner shall be shown on the plan provided to the Council at that time.
Marine Farm Lighting and Marking
21
The placement of marine farm lighting and marking shall be approved by the Harbourmaster
under his Maritime Delegation from the Director of Maritime Safety pursuant to sections 200,
444(2) and 444(4) of the Maritime Transport Act 1994.
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Structural Engineering Design, Installation and Maintenance
22
The design, including the design loading, for the anchoring and mooring warp system shall be
specified by a suitably qualified and experienced professional engineer (with appropriate peer
review) to cater for the maximum wave loading, and maximum and minimum spring tidal
levels and currents. The design report and plans shall be provided to the Manager, Resource
Consents, Marlborough District Council, prior to the anchoring system being installed. The
anchoring system shall be installed in accordance with this design and plans and the
installation shall be undertaken under the supervision of a suitably qualified and experienced
professional engineer.
23
During installation of the anchoring and mooring warp system, a test pullout loading shall be
undertaken of a representative screw anchor, in order to confirm the anchor pullout capacity,
in accordance with the Engineering Feasibility Report dated September 2011, prepared by
OCEL Consultants Limited and lodged with the application. A report describing the results of
the test, and confirming the pullout capacity of the representative screw anchor shall be
prepared by the engineer specified in Condition 22, and provided to the Manager, Resource
Consents, Marlborough District Council.
24
The anchoring and mooring warp system shall be monitored and maintained in accordance
with a “Salmon Farm Mooring Monitoring and Maintenance Schedule” prepared or reviewed
and accepted by a suitably qualified and experienced professional engineer and provided to
the Manager, Resource Consents, Marlborough District Council. This Schedule shall be
provided to the Council prior to any structures being located on the farm. The monitoring shall
include continuous monitoring of the actual mooring loads caused by the hydrodynamic forces
on the farm by tidal currents and waves, designed to demonstrate that the design loading on
the anchors and mooring warps is not exceeded. If monitoring shows that design loadings
have been exceeded, the causes of the loading exceedance shall be investigated and
rectified.
25
The mooring system shall be designed and maintained such that the maximum loading on
any mooring is the lesser of 20% of the anchor pullout capacity determined in accordance
with Condition 23, or 20% of the mooring line tension capacity after allowing for the
deleterious effects of splices and ties.
26
The structure and mooring system shall be designed such that, under all design cases, the
failure of a critical component under the design loading case does not result in the
progressive break-up of the structure or progressive failure of the mooring system.
27
The consent holder shall maintain all structures to ensure that they are restrained, secure and
in working order at all times, so as to not create a navigational hazard.
28
All investigations, design, supervision of construction, operation, monitoring and contingency
planning shall be undertaken by suitably qualified personnel experienced in such works, or
works of a similar nature.
Navigational Information and Safety
29
Within one month of the initial placement of the first structure(s) within the occupancy area
specified in Condition 1, the consent holder shall notify the Harbourmaster and Land
Information New Zealand that the structures have been placed within the area, and provide
them with a copy of the Farm Layout Plan required by Condition 3 and a copy of the plan
required by Condition 20. Any subsequent additions or disestablishment of the structures
shall be notified in a similar manner. [For Papatua, within one month of the placement of the
first structure(s) within the occupancy area specified in Condition 1, the consent holder shall
notify the Harbourmaster and Land Information New Zealand that the structures have been
placed within the area and provide them with a copy of the Farm Layout Plan required by
Condition 3. Any subsequent disestablishment of the structures shall be notified in a similar
manner.]
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30
Following the exercise of this consent, the consent holder shall ensure that a notice alerting
mariners to the presence and location of the farm is broadcast on Marlborough Radio as
directed by the Harbourmaster.
31
The farms at Ngamahau, Ruaomoko and Kaitapeha shall be fitted with a Class B - AIS
transponderGPS high precision position monitoring system or other similar equipment
approved by the Harbourmaster.
32
For the Ngamahau, Ruaomoko and Kaitapeha farms, a contingency plan shall be developed
and implemented to deal with the circumstances where a significant earthquake occurs in the
Marlborough or Wellington regions, a tsunami warning is issued by New Zealand Civil
Defence, a vessel collides with the farm, or a farm (or part of a farm) comes loose of its
moorings. The plan shall be prepared in consultation with the Harbourmaster and Cook Strait
passenger ferry operators who use Tory Channel. For the situation of the farm coming loose
of its moorings the plan shall include:
a
b
c
d
e
An immediate broadcast on channel 19 to alert ferries in the vicinity;
The notification of the Harbourmaster;
An emergency call to tug operators to help get the farm under control;
The steps likely to be necessary to recover the structures from the sea or seabed, and to
render them safe;
Other responses as appropriate.
The current version of the contingency plan shall be made available to the Harbourmaster
and to each Cook Strait passenger ferry operator.
33
The consent holder shall, prior to the initial placement of first structure(s) within the
occupancy area specified in Condition 1, prepare a navigation risk reduction and
management plan. The navigation risk reduction and management plan shall provide details
of the procedures to be put into place to operate the salmon farm in compliance with
Conditions 22-33 and minimise the potential for adverse navigation effects due to the
operation of the salmon farm.
Colours and Materials for Structures
34
The building, including its roof and all ancillary features (such as drain pipes), shall be
finished in non-reflective materials and painted in a dark colour (such as Karaka Green).
Curtains are to be provided for the windows of rooms used for staff accommodation and the
curtain fabric is to be a dark colour. [Does not apply to Papatua,]
35
All exterior above-water metal structures (other than the surface of walkways) are to be
painted or otherwise finished in dark recessive colours.
36
Black or dark colour is to be used for predator nets, grower nets and bird netting which are
normally above-water.
Discharges to Coastal Water
Discharge of Feed
37
Only extruded pellets or similar shall be fed at the farm.
38
The initial feed discharged (per annum) to the farm shall not exceed the Maximum Initial Feed
Discharge specified in Table 2.
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39
Subject to the requirements of Condition 41 below, any increase in the annual tonnage of
feed discharged to the farm shall not exceed the Maximum Increase in Feed Discharge
specified in Table 2. (Specific provisions for Papatua are specified in Condition 42 below).
40
Subject to:
a
b
the requirements of Conditions 43-45 (relating to compliance with Environmental Quality
Standards (EQS)); and
any specifications for farm management in the Marine Environmental Monitoring and
Adaptive Management Plan (MEM-AMP) for that year (Conditions 64-72),
in any year, the tonnage of feed discharged at the farm shall not exceed the Maximum Feed
Discharge specified in Table 2.
Table 2: Initial and maximum annual feed discharges, and maximum incremental feed
discharge steps
Farm
Maximum Initial
Feed Discharge
(tonnes per annum4)
Maximum
Increase in Feed
Discharge (tonnes
per annum4)
Maximum Feed
Discharge (tonnes
per annum4)
Waitata
3000
1000
6000
Kaitira
3000
1000
6000
Tapipi
3000
1000
5000
Richmond
1500
500
4000
3000
3
5000
500
40002
1
Papatua
2
1
Kaitapeha
2000
Ruaomoko
30002
1000
60002
Ngamahau
1500
500
4000
White Horse
Rock
1500
500
30001
1
1 Except that:
the combined initial annual feed discharge for Waitata and White Horse Rock shall be 4000 tonnes;
and
the combined maximum annual feed discharge for Waitata and White Horse Rock shall be 8000
tonnes
2 Except that:
the combined initial annual feed discharge for Kaitapeha and Ruaomoko shall be 4500 tonnes; and
the combined maximum annual feed discharge for Kaitapeha and Ruaomoko shall be 8000 tonnes
3 Increases in annual feed discharge for Papatua to be determined following each rotation and
fallowing cycle – refer to Condition 42 below.
4 The annual feed discharges may exceed the maximum feed discharges specified in Table 2 by up to
15%, provided that, over any continuous 3 year period, the average annual feed discharges do not
exceed the maximum feed discharges specified in Table 2 by more than 5%.
41
There shall be no increase in the tonnage of feed discharged to the farm unless the following
provisions are satisfied (specific provisions for Papatua are specified in Condition 42):
a
The farm shall have operated at or near (±15%) its current maximum annual feed
capacity for at least 3 years;
and
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b
At least two successive years of annual monitoring results shall be comparable, based on
the monitoring undertaken in Condition 67, assessed as follows:
• The Enrichment Stage (ES) from the annual monitoring, assessed in accordance with
Condition 45, shall not be statistically significantly more than the ES from the previous
year, based on the average result for all monitoring stations (Table 4) within each
compliance Zone. This requirement must be met for each of the Environmental
Quality Standards (EQS) compliance Zones for which ES are specified in Condition
45;
and
c
The farm complies with all the EQS specified in Condition 45 and is less than the relevant
maximum EQS for each Zone.
Subject to any specifications for farm management in the MEM-AMP for that year, and
provided that a - c above are satisfied, the annual tonnage of feed discharged to the farm may
be increased by no more than the Maximum Increase in Feed Discharge specified in Table 2.
Any other amendments to the management practices at the farm, in order to ensure
compliance with the EQS in any year, shall also be specified in the MEM-AMP for that year.
42
For the first five years at least, the Papatua farm shall be managed as a 4 yearly rotation and
fallowing regime, with each location for each row of net pens occupied for 1 year followed by
3 years of fallowing of that location (refer to the Farm Layout Plan required by Condition 3).
To achieve this, each row of net pens will moved each year within, and between, the Cage
Area Boundary blocks occupied by that row of net pens.
The effectiveness of the rotation and fallowing regime in achieving the EQS specified in
Condition 45 shall be assessed after five years, and every year thereafter (i.e. after the
second and every subsequent occupation of each net pen location). At that time, the
appropriateness of the feed discharge tonnage over the previous 5 years shall be evaluated
by comparing the monitoring results following the first and second, and subsequent,
occupations of the same locations. There shall be no increase in the tonnage of feed
discharged to the Papatua farm unless the criteria specified in 41a – c are satisfied.
If the provisions specified in Condition 41a-c above are satisfied, the increase in tonnage of
feed that may be discharged at the Papatua farm will be specified in the MEM-AMP for that
year.
Any other amendments to the management practices at this farm, in order to ensure
compliance with the EQS in any year, shall also be specified in the MEM-AMP for that year.
The discharge of feed is subject to Conditions 43-47 relating to Environmental Quality Standards and
Copper and Zinc Levels below.
Discharge of Marine Biofouling and Antifouling
The discharge of marine biofouling and antifouling shall be subject to Conditions 43-47 relating to
Environmental Quality Standards and Copper and Zinc Levels below
Environmental Quality Standards
43
The effects of deposition on the seabed shall be assessed against Environmental Quality
Standards (EQS) established for the farm, as required by Condition 45. The MEM-AMP shall
specify the monitoring to be undertaken in order to determine whether compliance with the
EQS is achieved, and the management actions to be undertaken to ensure compliance, as
set out in Conditions 64-72.
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44
EQS compliance Zones shall be defined for the farm, in accordance with Figure 4 and the
dimensions and areas contained in Table 3.
Table 3: Maximum distances of Zone 2/3 and Zone 3/4 boundaries from the nearest
edge of the salmon farm net pens; and the maximum total affected areas of Zones 1, 2
and 3.
Farm
Waitata
Kaitira
Tapipi
Richmond
Papatua
Kaitapeha
Ruaomoko
Ngamahau
White Horse
Rock
45
Zone boundary dimensions (maximum
distances)
Distance from
Distance from
nearest net pen to
nearest net pen to
Zone 2/3 boundary
Zone 3/4 boundary
Metres (m)
Metres (m)
150
600
200
800
137
550
60
250
50
100
112
450
225
900
75
300
60
300
Zone Area (Maximum
area)
Total area of Zones 1,
2 and 3 (the footprint)
Hectares (ha)
24
20
20
10
35
15.7
30
12
7.5
a
For all farms, other than Papatua, the above Zones shall be fixed. At Papatua, the
locations of the Zones will move with the net pens.
b
Notwithstanding, Condition 44a, the size and shape of the above Zones will be reviewed
(to enable comparison with the zone dimensions contained in Table 3), after 3 years of
operation at the Initial Feed Discharge level in Table 2, as part of the Annual Monitoring
Report (AMR - refer to Condition 69) for that year. The dimensions and area of the Zones
may be amended as a result of a recommendation in the AMR, provided that the total
area of Zones 1, 2 & 3 does not alter by more than ±10% from the area specified in Table
3.
The seabed beneath and in the vicinity of the farm shall comply with the EQS specified in
Table 4. Zone dimensions and area for compliance purposes shall be defined in accordance
with Condition 44. Enrichment Stages (ES) shall be defined in accordance with Figure 5 and
Table 5.
Table 4: Environmental Quality Standards (EQS)
Zone
Zones 1 & 2 –
beside and
beneath the net
pens
Compliance Monitoring
Location
Measured beneath the edge of
the net pens – ‘Pen’ Stations
on Figure 4
EQS
•
•
•
•
•
Zone 3 – near to
the net pens
Measured at the Zone 2/3
Boundary Stations on Figure 4
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•
ES≤ 5 (except for Papatua)
ES<6 (for Papatua)
No more than one replicate core
with no taxa (azoic),
No obvious, spontaneous outgassing (H2S/methane),
Bacteria mat (Beggiatoa) coverage
not greater than localized/patchy in
distribution.
Infauna abundance is not
significantly higher than at
9
corresponding ‘Pen’ Station
Zone 4 – outside
the footprint area
Measured at the Zone 3/4
Boundary Stations on Figure 4
•
•
ES < 3
Conditions remain statistically
comparable with relevant /
appropriate reference Station(s)
In the event of non-compliance with the above EQS, and subject to any review of conditions
of this consent specified in Condition 76, the consent holder shall work with the consent
authority to ensure full compliance is re-established within 24 months.
Copper and Zinc Levels
46
Composite samples of sediments beneath and beside the net pens (measured beneath the
edge of the net pen – ‘Pen’ Stations on Figure 4) shall be assessed against the ANZECC
(2000) ISQG-Low criteria for copper and zinc, as a first-tier trigger level. Monitoring,
measurement and analysis shall be undertaken in accordance with Conditions 64-72.
47
Where total metals analysis of composite sediment samples exceeds the ANZECC (2000)
ISQG-Low criteria for copper and zinc, the MEM-AMP (refer Conditions 64-72) shall include a
hierarchical schedule of monitoring of increasing focus and intensity and, ultimately,
management action based on the decision hierarchy contained in Figure 6.
Discharge of Greywater
48
Greywater may be discharged from the staff facilities contained within the building on the
farm. This discharge may include greywater from showers, wash basin, kitchen and laundry
facilities, but shall not include the discharge of sewage. The greywater discharge shall not
exceed 500m3 per day from each building.
Discharge of Coastal Water
49
Coastal water may be discharged where it has been taken and used for the purposes of
firefighting, outdoor cleaning and maintenance, fish grading, harvesting and assessment, and
other similar activities necessary for undertaking marine farming in accordance with the
conditions of this consent.
Taking and Use of Coastal Water
50
Coastal water may be taken and used for the purposes of firefighting, outdoor cleaning and
maintenance, fish grading, harvesting and assessment, and other similar activities necessary
for undertaking marine farming in accordance with the conditions of this consent
Disturbance of, Damage to, the Seabed
51
The seabed may be disturbed during the installation, testing and maintenance of the
anchoring system for the marine farm in accordance with Conditions 22-28. The area of the
seabed disturbed or damaged during the installation, testing and maintenance of the
anchoring system shall be kept to a reasonable and practical minimum.
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Discharge to Air
52
Discharges to air may occur from the operation of the marine farm and the carrying out of the
marine farming activity, in accordance with the conditions of this consent. This may include
the discharge of odour; and discharges to air from diesel generators and other diesel- and
petrol-powered equipment necessary for, and ancillary to, undertaking this operation and
activity.
General
Operational Procedures
53
The consent holder shall have in place, and implement, operational procedures to ensure that
the salmon farm operates in accordance with the conditions of this consent and minimises the
potential for adverse effects due to the operation of the farm.
54
In addition, the consent holder shall have in place, and implement, operational procedures to
implement best management practices to:
a
b
c
d
monitor and minimise feed loss from the salmon farm net pens;
minimise the number of fish dying in the net pens;
remove dead fish promptly from net pens;
minimise interactions of sharks, seals and other predators with the farm, including no
feeding of these predators;
e
minimise the potential for sharks, seals or other predators to enter the salmon farm net
pens through the use of predator-resistant materials in net pen construction and predator
exclusion nets enclosing the salmon farm net pen structures and extending sufficiently
high above the water around the farm to exclude such predators, but no higher;
f
ensure all nets remain free of holes or tears that could allow access by sharks, seals or
other predators;
g
ensure all nets are well tensioned;
h
ensure all anchor warps are sufficiently tensioned at all times to prevent entanglement of
cetaceans;
i
ensure all lines associated with the farm are secured at all times, and that any loose lines
are secured and/or retrieved promptly;
j
ensure that all net and cordage debris, plastic strapping and other farm, domestic or
other non-biodegradable waste is collected, retained and disposed of on-shore, and that,
if any loose debris does enter the water around the farm, it is retrieved from the seabed,
water column or foreshore promptly;
k
ensure that all beaches in the vicinity of the farm are kept free of debris from the farm;
l
ensure all hazardous substances are stored and used in a manner which ensure that
they are able to be contained at all times, and there is no discharge of hazardous
substances to coastal water;
m minimise entry of seabirds to the salmon farm net pens through the use of bird netting
over each net pen;
n
ensure that, as far as practicable, filling of the ‘mort’ bin (storing dead fish) only occurs
when wind speeds are greater than 3 m/s;
o
establish target times for cleaning the grower nets once they have been raised, to
minimise the time that any one net is held out of the water in order to minimise the
potential for odour from this source
mp ensure that, as far as practicable ,there is only one grower net being lifted and cleaned at
one time, to minimise the potential for odours from this activity.
55
The consent holder shall make available for review by the Marlborough District Council a copy
of the operational procedures required by Conditions 53 and 54, provided that the consent
holder may remove from that copy any commercially sensitive information contained in the
operational procedures.
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56
The operation of the salmon farm shall at all times be in accordance with the consent holder’s
current operational procedures prepared to achieve Conditions 53 and 54.
Marine Mammal Management
57
The consent holder shall prepare and implement a marine mammal management policy
(developed in consultation with the Department of Conservation) to minimise the interactions
of marine mammals with the farm, and to prescribe actions should marine mammals become
a nuisance in relation to the farm or interact with the farm in a manner that could result in
harm to the marine mammal. This policy shall include training for staff on the farm (including
in the identification and safe handling of live seals and other marine mammals), a regular
reporting system for farm managers and staff regarding interactions between the farm and
marine mammals, and liaison, information sharing and notification procedures with the
Department of Conservation.
Biosecurity Management Plan
58
The consent holder shall prepare and implement a Biosecurity Management Plan with the
objectives of minimising the risk of the spread of marine pests, diseases and parasites as a
result of the establishment and operation of the salmon farm.
59
The Biosecurity Management Plan shall include on-farm, as well as vector-based,
management measures to reduce the risk of spread, including:
a
b
c
d
e
f
Direct vector management, such as the implementation of a regular regime of vessel hull
coating with antifouling paint
General on-farm management measures, and targeted measures to control or contain
specific species;
Routine practices to manage fouling of nets and structures;
A passive surveillance regime, in which farm workers watch out for target pest species, or
any unusual fouling on farm structures, during their daily activities;
An effective disease surveillance in salmon stock;
The use of harvesting methods consistent with best practice management for the
minimisation of disease risk.
60
The Biosecurity Management Plan shall be provided to the Marlborough District Council prior
to the exercise of the consent. The Plan shall be reviewed at least annually by the consent
holder to ensure that the management practices specified in the Plan are consistent with
Condition 58 and 59. Any revisions to the Plan shall be provided to the Marlborough District
Council immediately following completion of the revisions.
61
Biosecurity management at the farm shall at all times be in accordance with the current
provisions of the Biosecurity Management Plan.
Marine Environmental Monitoring and Adaptive Management
62
A Baseline Monitoring Plan shall be prepared and provided to the Marlborough District
Council. This Plan shall specify the monitoring to be undertaken, in order that the following
baseline information can be obtained prior to any development being undertaken on the farm
(in the case of a, b and c) and prior to fish being stocked on the farm (in the case of d and e).
The baseline monitoring shall include, but not be limited to, one survey of the following:
a
Spatial information on the distribution of soft-sediment habitats and communities across
the occupancy and activity area specified in Condition 1; and across the area of EQS
compliance Zones 1, 2 & 3 specified in Condition 45;
b
Quantitative and qualitative mapping of environmental variables across the occupancy
and activity area specified in Condition 1; and across the area of EQS compliance Zones
1, 2 & 3, as specified in Conditions 44 and 45, including quantitative (replicate) data for
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the environmental variables from each of the proposed on-going monitoring stations and
at appropriate reference stations;
c
Habitats that support notable biological features within and adjacent to the farm (“reef”
monitoring) (within 1km from the net pens); and in at or near locations highlighted as
potential areas for nutrient accumulation by the outputs from spatially explicit nutrient
modelling; as well as comparable habitats at appropriate control / reference sites;
d
A selection of representative soft sediment sites in neighbouring bays near to, and
removed from, the farm, highlighted as areas of potential exposure to increased
biodeposition; as well as comparable habitats at appropriate control / reference sites;
e
63
Wide-scale water column monitoring for nutrient and cholorophyll a concentrations,
phytoplankton composition and biomass, salinity, temperature, turbidity and dissolved
oxygen (DO) at the following locations, in both Pelorus and Queen Charlotte Sound and
in Port Gore:
i.
Locations that are expected to have the greatest potential for farm-related
cumulative enrichment effects (as predicted by spatially explicit nutrient modelling);
ii.
Locations that are expected to have progressively lesser farm-related cumulative
enrichment effects (as predicted by spatially explicit nutrient modelling);
iii.
Within the inner Sounds; and
iv.
Near the entrances to Cook Strait.
Baseline data shall be collected at these locations on at least 4 occasions prior to fish
being stocked on any of the farms consented through the Board of Inquiry process of
2012. The monitoring stations for this wide-scale water column monitoring shall be
established as long-term monitoring stations for the purposes of undertaking the longterm, wide-scale water column monitoring specified in Condition 68f.
The baseline monitoring shall be undertaken in accordance with the Baseline Monitoring
Plan and a Baseline Monitoring Report prepared and provided to the Marlborough District
Council. The Baseline Monitoring Report shall include, but not be limited to, the following:
a
Presentation of the results from the baseline monitoring;
b
A synthesis and review of all available water quality data relevant to the enrichment status
of the general Pelorus Sound and Queen Charlotte Sound regions. in order to provide a
historical baseline of conditions;
bc Any recommendations as to the specific location or installation of farm anchoring
structures;
cd Any recommendations regarding ongoing monitoring following the development of the
farm.
64
For each year of the operation of the farm, the consent holder shall prepare a Marine
Environmental Monitoring and Adaptive Management Plan (MEM-AMP) and an Annual
Monitoring Report (AMR) in accordance with Conditions 64-72. In general terms:
a
the MEM-AMP shall provide a summary of the relevant recommendations from the
previous year’s AMR, and specify the proposed monitoring and farm management actions
for the following year (as relevant to the potential effects set out in Condition 65). The
MEM-AMP may be prepared as one Plan jointly with the MEM-AMP(s) for other farms
managed by the same consent holder.
b
the AMR shall provide the details of the monitoring results from the previous year, an
analysis of the monitoring results (including in terms of compliance with the EQS), and
recommendations for changes to the monitoring and farm management actions for the
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following year (as relevant to the potential effects set out in Condition 65). The AMR may
be prepared jointly with AMR’s for other farms managed by the same consent holder.
65
66
The MEM-AMP and AMR shall address, but not be limited to, the following potential effects
from the operation of the farm:
a
Effects of deposition on the seabed and foreshore;
b
Effects on, and from, the quality of, and nutrient accumulation in, the water column.
The MEM-AMP shall specify the following in relation to the potential effects from the operation
of the farm set out in Condition 65:
a
A summary of the recommendations from the Baseline Monitoring Report (in the case of
the first MEM-AMP for the farm) or from the previous year’s AMR regarding farm
management practices and monitoring;
b
A description of all farm-specific compliance and other monitoring to be undertaken for
the coming year. This shall include the methods, locations and frequency of the
compliance and other monitoring, including any control / reference sites. This shall reflect
any recommendations contained in the AMR for amendments to the dimensions and
areas of the EQS compliance Zones specified in Table 3 and/or to the location of the
representative compliance monitoring Stations specified in Table 4, following the
monitoring undertaken after 3 years of operation at the Initial Feed Discharge level in
Table 2. (Refer to Conditions 67 and 68 below for more detailed requirements);
c
Any management actions to be undertaken at the farm for the coming year in order to
ensure continuing compliance with the EQS;
d
In the case of any non-compliance with the EQS in the previous year, how the
management of the farm will ensure full compliance is re-established within 24 months
from the non-compliance being demonstrated, in accordance with Condition 45;
e
In the case of copper and zinc, if the ANZECC (2000) ISQG-Low criteria set out in
Condition 46 were not achieved in the previous year, the schedule of monitoring and
management actions required in accordance with Condition 47;
f
Any other actions to be undertaken to avoid, remedy or mitigate any significant adverse
effects from the operation of the farm identified in the previous year’s AMR.
The MEM-AMP shall take into account any recommendations from the Marlborough District
Council’s independent peer review (Condition 72).
67
The MEM-AMP shall include the following farm-specific compliance monitoring:
a
The level of sampling and range of environmental variables to be measured at each of
the monitoring stations required for compliance with the EQS in Condition 45, including
appropriate reference stations;
b
The sampling intensity and comprehensiveness shall be dependent upon the age of the
farm, how stable the feed levels have been over the last 12 months, and whether or not
the farm has been compliant with the EQS over the last 2 years (or the nature of any
breaches);
c
Monitoring of copper and zinc in order to ensure compliance with 46 and 47 using a
decision-tree approach, whereby monitoring effort increases in focus and intensity as
trigger levels (representing the increased likelihood of ecological effects) are reached.
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68
The MEM-AMP shall also include any other studies or monitoring to be undertaken by the
consent holder in relation to the potential effects from the operation of the farm set out in
Condition 65. This shall include the following:
a
Monitoring of habitats that support notable biological features within and adjacent to the
farm (“reef” monitoring), as well as comparable habitats at appropriate control / reference
sites. This monitoring shall be continued until at least 3 years after the farm has reached
a stable level of feed discharge [This condition will only apply to those farms with notable
biological features in the vicinity of the farm].
ab Monitoring of ephemeral (e.g. Ulva sp. and benthic algal films) and perennial algae (e.g.
Homosira banksii) percentage cover and the abundance of grazing invertebrates (e.g.
cats’ eyes snails (Turbo smaragdus) and Kina (Evechinus chloroticus) on intertidal and
shallow subtidal rocky reef areas in the vicinity of the farm (within 1km from the net pens),
as well as comparable habitats at appropriate control / reference sites. This monitoring
shall be continued until at least 3 years after the farm has reached a stable level of feed
discharge.
bc Monitoring of sediment depositional effects at soft sediment sites in neighbouring bays
near to, and removed from, the farm, chosen based on potential exposure to increased
biodeposition. This monitoring will be undertaken at a selection of representative soft
sediment sites and shall be continued until at least 3 years after the farm has reached a
stable level of feed discharge [The same monitoring will be able to be undertaken for a
group of farms, as it will assess the cumulative effects from all farms in that group].
cd Targeted water column surveys for the purpose of quantifying the localised effect of the
individual farms on surrounding water quality. This shall involve a series of fine-scale
surveys in the vicinity of the farm (within 1km from the net pens) (and at control/reference
areaslocations) over a two year period, measuring: salinity, temperature, chlorophyll,
turbidity, dissolved oxygen (DO), nutrient concentrations, phytoplankton composition and
biomass along transects that move away from the farm and span potential nutrient
gradients. The surveys shall be undertaken following operation at the farm’s Maximum
Initial Feed Discharge and again after the farm has reached a stable level of feed
discharge. [at least twice per year and continued for at least two years after the farm has
reached stable maximum production levels and no future increases are proposed.These
surveys shall be undertaken at selected representative farms (e.g. one farm in each of
Queen Charlotte and Pelorus Sounds) and do not need to be undertaken at every farm
operated by the consent holder.]
d
After 3 years of operation at the Initial Feed Discharge level in Table 2, a repeat of the
baseline monitoring undertaken in accordance with Condition 62a and b, incorporating
the farm-specific compliance monitoring in terms of Condition 67 for that year.
e
f
Long-term wide-scale water column monitoring for nutrient and cholorophyll a
concentrations, phytoplankton composition and biomass, salinity, temperature, turbidity
and dissolved oxygen (DO) at locations stipulated in Condition 62e. This monitoring is to
be undertaken at least 4 times per year with focus on mid summer periods of highest
salmon feed rates and periods associated with winter/spring and/or autumn diatom
maxima. Monitoring will be undertaken at the same frequency throughout the staged
development of the proposed farms until at least 3 years after production levels have
stabilised. The monitoring design and frequency will then be the subject of review.
g
Wide-scale monitoring of ephemeral (e.g. Ulva sp. and benthic algal films) and perennial
algae (e.g. Homosira banksii) percentage cover and the abundance of grazing
invertebrates (e.g. cats’ eyes snails (Turbo smaragdus) and Kina (Evechinus chloroticus)
on intertidal and shallow subtidal rocky reef areas at or near locations highlighted as
potential areas for nutrient accumulation by the outputs from spatially explicit nutrient
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modelling and at control / reference locations where minimal nutrient accumulation is
predicted.
h
One-off monitoring of the effects of submerged artificial lighting on the biology of the
water column (e.g. zooplankton composition and abundance), when the submerged
artificial lights are fully operational. [To apply to any farm which is exposed to lower
current speeds than Clay Point where the assessment of effects of submerged artificial
lighting for this application was undertaken].
i
Occasional monitoring by farm staff of the effects of submerged artificial lighting on
changes in night-time feeding activity by fish, seabirds and marine mammals in and
around the illuminated net pens.
j
Occasional monitoring of feed loss levels, including how the feed loss varies over time.
k
Occasional monitoring of the size and composition of aggregations of pelagic and
demersal fish beneath the farm.
gl
Occasional monitoring of key heavy metal and organohalogenated contaminants of public
health interest in long-lived bentho-pelagic fish species, of recreational, commercial or
customary interest, residing in the near vicinity of the farm.
[A contribution may also be offered towards long-term monitoring (10+years) for any effects
resulting from changes in the quality of the water column across the wider Sounds
environment over time. Such a programme should involve multiple stakeholders and be
established to collect robust Sound-wide information.]
69
The AMR shall specify the following in relation to the potential effects from the operation of
the farm set out in Condition 65:
a
A statement as to the tonnage of feed discharged each month over the previous year and
the maximum biomass of fish on the farm during that year;
b
The results of the monitoring undertaken in the previous year;
c
A comprehensive analysis of the results of that monitoring;
d
An assessment and conclusions as to whether compliance with the EQS specified in
Condition 45 has, or has not, been achieved for the previous year;
e
Amendments to management practices at the farm in order to ensure that compliance
with the EQS in Condition 45 continues to be achieved or, in the event of a noncompliance, to ensure that full compliance is re-established within 24 months of
monitoring first identifying non-compliance as required in accordance with Condition 45.
f
An assessment and conclusions as to whether compliance with the ANZECC (2000)
ISQG-Low criteria for copper and zinc set out in Condition 46 has, or has not, been
achieved for the previous year;
g
Where the ANZECC (2000) ISQG-Low criteria for copper and zinc have been exceeded,
recommendations as to any amendments to monitoring and management actions at the
farm, in accordance with Condition 47;
h
Following 3 years of operation at the Initial Feed Discharge level in Table 2, a review of
the results of the monitoring undertaken in terms of Condition 68d. This shall include, a
comparison of those monitoring results with the dimensions and areas of the EQS
compliance Zones specified in Table 3, Condition 44. In accordance with Condition 44b,
the AMR shall specify any recommendations for amendments to the dimensions and
areas of the EQS compliance Zones, and to the location of the representative compliance
monitoring Stations specified in Table 4, Condition 45, for the subsequent years;
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i
Every 3 years from the first year of operation of the farm, every 3 years thereafter until at
least three years after the farm has reached stable maximum production levels and no
future increases are proposed, and then every 5 years after that, the AMR shall include a
review of the wider-scale water column and ecosystem monitoring results for the
purposes of:
i.
assessing the sufficiency of the information collected:
ii.
assessing any trends occurring;
iii.
assessing any wider ecosystem implications of the monitoring results and any
evident trends, and whether or not any adverse effects on the wider ecosystem are
discernible as a result of the operation of the farm;
iv.
assessing any evidence of a trend towards a shift in trophic status;
v.
recommending in relation to future incremental changes in feed discharge levels;
i.vi.
when, and if, appropriate, recommending a suitable indicator for assessing future
water column ecosystems changes.
hj
Where the monitoring has identified any significant adverse effects from the operation of
the farm (other than the effects being monitored through the farm-specific compliance
monitoring in Condition 67), any recommendations as to farm management actions or
additional monitoring necessary to address those effects;
ik
Any other recommendations for amendments to the monitoring programme for the
following year.
70
The first MEM-AMP for the farm shall be provided to the Marlborough District Council
following the provision of the Baseline Monitoring Report to the Council in accordance with
Condition 63 and prior to any salmon being placed at the farm. Each subsequent annual
MEM-AMP shall be provided to the Marlborough District Council by 31 July each year. The
AMR shall be prepared and provided to the Marlborough District Council by 30 April each
year.
71
Each year, the farm shall be managed, and monitoring undertaken, in accordance the MEMAMP for that year.
72
The Marlborough District Council may require an independent peer review of any particular
part, or the whole, of the Baseline Monitoring Plan and/or Report, the MEM-AMP and/or the
AMR, required by Conditions 62-72. Such a peer review may be undertaken in relation to the
Baseline Monitoring Plan and/or Report; and in relation to the MEM-AMP and the AMR only in
any of the first 3 years following the initial development of the farm and at any fifth year
thereafter. Such a peer review shall be at the cost of the consent holder.
Social Impacts
73
The consent holder shall prepare and implement a Social Impact Management Plan (SIMP)
with the objective of setting out the responsibilities of the consent holder in relation to the
social impacts of the establishment and operation of the salmon farm, and to describe
organisational relationships between the consent holder and other stakeholders and
communities. The SIMP shall:
a
provide a summary of the potential social and economic impacts (benefits and adverse
impacts) to be addressed through the SIMP;
b
outline specific social impact management plans for which the consent holder is
responsible;
c
outline the consent holder's on-going Community Engagement Strategy; and
d
present a proposed framework for monitoring, reporting and reviewing social impacts and
the SIMP.
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74
The consent holder shall develop the following management plans and provide them to the
Marlborough District Council prior to initiating development work on a site:
a
A Residential Amenity Management Plan to minimise the risk of neighbours
experiencing significant reductions in residential amenity due to off-site visual, noise and
odour effects from the salmon farm.
b
A Wildlife Nuisance Management Plan to minimise the risk of neighbours experiencing
significant reductions in amenity values due to wildlife nuisances attributable to the
salmon farm.
c
A Solid Waste Management Plan to minimise the risk of reductions in neighbouring
amenity values caused by the accumulation of solid waste debris along the shoreline
resulting from the salmon farm.
d
A Staff Recruitment and Training Plan to maximise opportunities for Marlborough
residents to gain employment in teh consent holder’s expanded Marlborough operations
resulting from the development of the salmon farm.
These Plans may be combined together or form part of a wider management plan, provided
the matters referred to are addressed in any such document.
Biological Compensation [Ngamahau site only]
75
The consent holder shall undertake a benthic biological survey to investigate and describe
biological features in the Tory Channel biogeographic area. This survey shall consist of a
search for, and description of, new, potentially high quality or significant biogenic habitats in
this biogeographic area.
Review of Conditions by Consent Authority
76
In accordance with the provisions of sections 128 and 129 of the Resource Management Act
(or any provision in substitution therefore), the Marlborough District Council may, at the
time(s) specified in Table 5 below, review the conditions of consent over which it has
reserved control, by serving notice of its intention to do so for one or more of the purposes
specified in Table 5:
Table 5: Purpose and Times of Potential Review of Conditions of this Consent
Purpose(s)
Time(s) Of Service Of Notice
To deal with any adverse effect on the
environment which may arise from the
exercise of the consent and which
cannot be adequately avoided,
remedied or mitigated by any term or
condition incorporated within the
consent, pursuant to the provisions of
section 128(1)(a)(iii) of the Act.
On any anniversary of the exercise of the consent
To modify the monitoring programme.
Within 2 months of receipt of the AMR required by
Condition 69.
To review the tonnage of feed that may
be discharged in accordance with the
conditions of this consent, in order to
ensure compliance with the EQS in
Condition 45 is achieved
Within 2 months of receipt of the AMR required by
Condition 69.
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Within 6 months of receipt of the AMR required by
Condition 69.
18
To require the consent holder to adopt
the best practicable option to avoid,
remedy or mitigate any adverse effect
on the environment relating to the
activity.
Within 6 months of receipt of the AMR required by
Condition 69.
To review the navigation risk reduction
and management plan to ensure that
management practices result in
compliance with Conditions 22-33.
On any anniversary of the exercise of the consent.
Other Matters
77
Pursuant to section 36 of the Act and Marlborough District Council’s Schedule of Fees, the
consent holder shall pay all actual and reasonable costs associated with any review of this
resource consent.
78
Inspection and monitoring by the Marlborough District Council’s Regulatory Department in
respect of the conditions of this consent may take place annually or more frequently in the
event that a previous inspection or complaint indicates the need for more frequent inspection
and monitoring.
79
The costs of these inspections and any formal monitoring programme established in
consultation with the consent holder will be charged to the consent holder in accordance with
Marlborough District Council’s Schedule of Fees approved pursuant to section 36 of the Act.
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Figure 1a-h: Farm Layout Plans
Relevant Farm Layout Plan prepared by OCEL included in Maps and Plans attached to AEE [To be amended to show final building layout]
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Figure 2a: Buffer Areas around King Shag Roosting Sites in the vicinity of the Papatua Farms
(Taratara)
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Figure 2b: Buffer Areas around King Shag Roosting Sites in the vicinity of the Waitata and
White Horse Rock Farms (Boat Rock Point)
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Figure 3a-h: Cage Area Boundaries
Relevant Cage Area Boundary Plan for each Farm as included in Plan Change
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Figure 4: Environmental Quality Standard (EQS) - Definition of EQS Compliance Zones (from
Figure 17(a) of Evidence of Mr N Keeley)
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Figure 5: Schematic Diagram of Enrichment Stages (from Figure 8(B) of Seabed Report)
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Table 6: General Description and Environmental Characteristics of Enrichment Stages (ES)
(from Table 6 of Seabed Report)
ES
General description
1
Natural/pristine conditions
2
3
4
5
6
7
Minor enrichment: Low level
enrichment. Can occur naturally or from
other diffuse anthropogenic sources.
'Enhanced zone'
Moderate enrichment: Clearly enriched
and impacted. Significant community
change has occurred.
Major enrichment 1:Transitional stage
between moderate effects and peak
macrofauna abundance. Major
community change.
Major enrichment 2: Highly enriched.
State of peak macrofauna abundance.
Major enrichment 3: Transitional stage
between peak and azoic.
Severe enrichment: Anoxic & azoic;
sediments no longer capable of
supporting macrofauna. Organics
accumulating.
Environmental characteristics
LF
Environmental variables comparable to unpolluted/ unenriched pristine reference site.
HF
As for LF, but infauna richness and abundances naturally
higher (~2×LF) and %OM slightly lower.
LF
Richness usually greater than for reference conditions. Zone
of 'enhancement' – minor increases in abundance possible.
Mainly compositional change. Sediment chemistry
unaffected or with only very minor effects.
HF
Changes as for LF
LF
Notable abundance increase, richness and diversity usually
lower than reference. Opportunistic species (i.e. capitellids)
begin to dominate.
HF
As for LF
LF
Diversity further reduced, abundances usually quite high, but
clearly sub-peak. Opportunistic species dominate, but other
taxa may still persist. Major sediment chemistry changes
(approaching hypoxia).
HF
As above, but abundance can very high while richness &
diversity are not necessarily reduced.
LF
Very high numbers of one of two opportunistic species (i.e.
capitellids, Nematoda). Richness very low. Major sediment
chemistry changes (hypoxia, moderate oxygen stress).
Bacteria mat (Beggiatoa) usually evident. H2S out-gassing on
disturbance.
HF
Total abundances can be extreme (10×LF ES 5 densities).
Diversity usually significantly reduced, but moderate richness
can be maintained. Sediment organic content usually slightly
elevated. Beggiatoa formation and out-gassing possible.
LF
Transitional stage between peak and azoic. Richness &
diversity very low. Abundances of opportunistic species
severely reduced from peak, but not azoic. Total abundance
low but can be comparable to reference. %OM can be very
high (3-6 times Ref).
HF
Not previously observed
LF
None, or only trace numbers of macrofauna remain. Some
samples with no taxa. Spontaneous out-gassing; Beggiatoa
usually present but can be suppressed. %OM can be very
high (3-6 times Ref).
HF
Not previously observed
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Figure 6: Decision Hierarchy for Copper and Zinc (From Figure 2 of Evidence of Mr R Sneddon)
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