This paper examines the development of adaptive management in New Zealand’s resource management case law. In particular, this paper investigates a Supreme Court decision (Sustain Our Sounds Inc v King Salmon New Zealand Co Ltd), which established a set of criteria for implementing adaptive management through New Zealand’s Resource Management Act. This paper describes King Salmon’s initial request for aquaculture permits, the Supreme Court appeal, and the Supreme Court’s justification for an adaptive management approach. Analyzing this justification, this paper explores the remaining constraints using an adaptive management approach to enable a more agile and flexible resource management system in New Zealand.

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