"The Crown's submission opposes the application to leave the bow section of the Rena where it is, sitting currently on the top surface of the reef at shallow depths, along with any associated parts of the wreck and debris to a depth of 30m.
The Crown's submission also proposes enhanced monitoring and consent conditions for those parts of the wreck site below 30m."
Mr Finlayson said said the Crown considered a number of factors relating to the application to leave the Rena wreck where it is.
"We considered the environmental, cultural and economic interests of New Zealand and the likely cost and feasibility of the complete removal of the wreck, including international comparisons.
"We also looked very carefully at the health and safety of salvors working in the wreck below 30m and also considered the effect of the proposed consent on the social environment. We carefully considered through this process the principles of the Treaty of Waitangi," Mr Finlayson said.
"In light of these considerations, the Crown believes the bow section and debris field in shallow waters (down to 30m) should be removed as thoroughly as possible.
"These parts of the wreck raise concerns about impacts on the natural character and environment of the area, and have cultural and health and safety consequences. The Crown understands that the owner continues to work on debris removal."
"We consider that the environmental impacts on leaving the sections below 30m could be managed through a tighter set of consent and monitoring conditions.
"Our submission includes recommendations to improve the monitoring and consent conditions in order to ensure the long term effects of what remains of the wreck are appropriately managed."
Mr Finlayson said the submission struck a balance between concerns about the wreck remaining on the reef, and the risks (including health and safety for workers at that depth and the risk of damage to the reef) and cost of full wreck removal of the lower sections in deeper water.
Mr Finlayson said at a press conference this morning that the submission was "an extremely good balance of all the considerations".
He told reporters that the bow section of the Rena had moved around in the aftermath of Cyclone Lusi in March, and it was in everybody's interests for that part of the wreck to be moved.
Government wanted the debris down to 30 metres to be removed because officials believed there could still be a shipping container filled with plastic beads, which could harm sea life and bird life.
Mr Finlayson said: "There is also some copper down there. That is unacceptable so we think that needs to be removed as well." Referring to Government's proposal that the stern should remain on the reef, he said the health and safety concerns for workers operating at a depth of 70 metres were a "major consideration" for the Crown in the wake of the Pike River disaster.
Mr Finlayson said he led the submission because it was important that the Crown spoke with a single voice and did not give contradictory submissions through various agencies.
The Crown's submission was submitted this morning.
Labour has previously pledged that it would ensure the wreck was removed if elected.
Leader David Cunliffe earlier said leaving the ship on the reef would be an "insult to the people of Tauranga, an insult to local iwi, and an insult to our environment to leave that potentially toxic wreck on the reef".
Tauranga City Council has lodged a neutral submission on the application, while Bay of Plenty iwi and the group Restore Our Reef - Remove the Rena have stated they would fight the proposal.
- with APNZ, NZ Herald
