Mod 1

As owner/operator of 2 tourism businesses in Eden, I wish to make a
submission in relation to the proposed amendments to the Operating
Conditions for cruise ships coming in to Eden port.

My specific points are:
 we have worked for over 13 years to make this project a
reality and copious amounts of research, investigation and reporting
have been collated regarding the potential impact of cruise ships
entering the Port of Eden. Through the time that I have been involved
both privately and as a Chamber of Commerce representative, I have
fielded no concerns from the wider community in relation to the
potential negative impact of on-ship announcements and music. I would
suggest that the greater majority of residents and visitors would not
find this sound offensive enough to warrant a formal amendment to
Operating Conditions. In comparison with other sounds/noise heard on a
daily basis in a working port, these announcements are inoffensive and
necessary for the safe and smooth movement of passengers off the ship
and into our town to spend time and money.

 In relation to the potential negative impact of sulphur and
other emissions from a cruise ship in Port, it is heartening to see
rigorous debate as this needs to be managed carefully in the interests
of public health. Clearly the industry is being monitored globally and
plans are now in place for the introduction of 0.5% levels across the
globe from 2020. As there will be a period of approximately only 10
months (during which 9 cruise ships are due into Eden) during which
ships coming into Eden MAY use 2.7% sulphur content fuel, it is also
likely that some or all of those ships may already be using the
globally accepted 0.5%.

To compare the situation in Eden with that of Sydney Harbour is
unrealistic. Sydney Harbour hosts an inordinate number of large
vessels (both cruise and other) on a daily basis in comparison with
Eden. It's air quality cannot be fairly compared with that of
Eden and the impact of any emissions from ships must also surely be
influenced by the high-rise development on the Sydney Harbour
foreshore. It would appear that, in this instance, Eden's situation is
being unfairly lumped in with Sydney's due merely to bad timing.

If these conditions are set in place, we risk all that our community
has worked tirelessly for. Cruise companies are known to be fickle and
can easily avoid this (new/young) port if its
Operating Conditions are too onerous.

The determining body must take a sensible approach to these matters,
or our Governments will have invested $44 million of taxpayers' money
into something that cannot achieve what it set out to achieve and that
is to increase economic activity in and
around Eden and the Sapphire Coast.

Overall it is important to note that Eden is still a juvenile port that
is very much in growth phase within the industry.
Adding unnecessary limitations and restrictions will only serve to
hamper our growth, which collectively we've worked so hard to achieve.
As a non-marquee port, we don't yet have the runs on the board to
exercise demands such as this, without negative implications such as
reduced visitation.
The cruise business now accounts for 5% of annual visitation to the
Sapphire Coast, along with significant roll on effect of return
visitation. The 2017/18 cruise season was valued at $8.1m to the
local economy. This is an economic injection that our local businesses
look forward to, and indeed count on. Why would we knowingly put
operational conditions in place that cuts this off?
Eden's growth has now gained significant momentum and is projected to
place the region as a major beneficiary of the cruise industry. This
reason, along with the fact that many other regional ports are looking
for the same opportunities is a strong impetus to continue our
progress without unnecessary limiting restrictions.

It is very important to note that Eden is still a juvenile port that is
very much in growth phase within the industry.
Adding unnecessary limitations and restrictions will only serve to
hamper our growth, which collectively we've worked so hard to achieve.
As a non-marquee port, we don't yet have the runs on the board to
exercise demands such as this, without negative implications such as
reduced visitation.
The cruise business now accounts for 5% of annual visitation to the
Sapphire Coast, along with significant roll on effect of return
visitation. The 2017/18 cruise season was valued at $8.1m to the
local economy. This is an economic injection that our local businesses
look forward to, and indeed count on. Why would we knowingly put
operational conditions in place that cuts this off?
Eden's growth has now gained significant momentum and is projected to
place the region as a major beneficiary of the cruise industry. This
reason, along with the fact that many other regional ports are looking
for the same opportunities is a strong impetus to continue our
progress without unnecessary limiting restrictions.

I support the application for modification for the noise and air quality
conditions for cruise ships for the following reasons:
- Eden port is a working port with all the noises associated with
fishing industry and other industries. There will be little or no
impact from the sounds of ship's announcements for passengers as they
arrive into port. It is not an offensive noise - certainly nothing as
bad as the type of noise you hear in cities such as sirens etc.
- I have read through all the information about the sulfur levels in
the fuel and am completely comfortable with Eden being subject to the
same conditions that will be brought in globally on 1st Jan 2020. The
short period of time during the transition from the higher levels of
fuel will have little or no effect on Eden's air quality. In fact, it
is very likely the ships will have already transitioned to 0.5% by
then anyway. It seems ridiculous to me that it was ever considered
appropriate for Eden to be subject to the same levels of Sydney.

I have studied the document on view at Eden Library and fully concur with
all proposed amendments. Particularly those amendments relating to
complaints handling, which I feel will obviate nuisance caused by a
very small minority of residents who appear to be getting satisfaction
from their repeated efforts to obstruct this vital new cruise
industry.

We live within 300metres (as the crow flies) from where the cruise ships
will berth and overlook the wharves directly at 247 Imlay St above
Victoria Terrace.
We support the amendments as proposed in regards to both the
amendments to the sulphur levels and noise.
These recommendations are in line with other regional ports in
Australia.
It is important that restrictions for an inner city berth such as
White Bay are not implemented here in a regional port.
The number of cruise ship visits to Eden is growing and the local
economy relies on these visits. It would be devastating if overly
stringent conditions were applied in Eden that resulted in ships
cancelling their visit.
We also operate a Bed and Breakfast, Cocora Cottage B&B overlooking
the wharf and at no time have we found the noise from cruise ships a
problem. In fact it is rare that there is any noise from them at all.
Eden is a working port and residents who surround the wharf are used
to tug and fishing trawler movements and the noise associated with a
working port. By comparison cruise ships are quiet and are only
operating in daylight hours.
Therefore we support the modification request to Eden Breakwater Wharf
Extension project, Infrastructure Approval SS1 7734 submitted on 2
July 2018 in relation to the project

I have practiced as an Environmental Lawyer for several decades and I am
an Honorary Fellow of the Planning Institute of Australia.
In the course of my work I have specialised in a number of mining and
landfill cases in which noise and air quality have been significant
issues.
Based on my experience, I respectfully agree with the reasoning set
out in the Advisian report commissioned by the NSW Department of
Industry in support of the requested modifications.
In addition to that reasoning, I would point out that the expression
"in transit' (wherever used in the original Infrastructure Approval
document wording) is ambiguous and misleading. A legal interpretation
could embrace the whole of a ship's travel between ports of call.
As to the issue of fuel sulphur content, I note that the topography of
Snug Cove and the Eden Wharf area, plus typical climatic conditions,
are not conducive to problems associated with katabatic air flows or
inversion layer development. Snug Cove is located on an isthmus
between Calle Calle Bay and Nullica Bay with a deep saddle in the
wharf environs area. It is reasonable to assume that prevailing air
movement over the relevant area would have a dispersive effect.
Furthermore, such conditions are generated nocturnally and cruise
ships will be berthed at Eden during full daylight hours only.
In addition, the prevailing wind direction during the warmer months at
Eden is north-westerly. This coincides with the cruise season, meaning
that winds passing through the saddle and over the area generally
would tend to blow exhaust fumes over into the wide expanse of Nullica
Bay and away from sensitive receptors.
In my opinion, the requested modifications are reasonable and should
be granted.

Cat Balou Cruises operate tourism charters out of the Port of Eden around
Twofold bay. We are chartered by the visiting cruise ship companies to
provide a two hour historical cruise around the bay.

Visiting cruise ships provide the organisation with an influx of
passengers on our vessel, and due to the increase in passengers, we
are therefore required to utilise more employees therefore providing
extra employment.

It is my personal opinion that putting extra noise and fuel carriage
conditions on the visiting ships will have a detrimental effect on all
the work that has been done to entice them into the port.
I fear that imposing these conditions will result in ships choosing
not to vist this Port and the effects will be felt throughout Eden and
the surrounding area's

I see no reason to make the ships carry reduced sulpher emmiting fuel
when the IMO changes will take effect in early 2020 anyway. I am
currently residing overlooking where the cruise ships anchor and feel
that any noise emmiting from engines or anouncements are very minimal
and have no negative effect.

I don't believe all the restrictions with regard to ships visiting Eden
are necessary. We won't be receiving anywhere near the number of ships
that Sydney recieves each year and our population is tiny by
comparison. Very few peope actually live near the port and the ships
don't stay overnight anyway.
Such stringent limitations with regard to fuel and noise are
unnecessary for Eden!

I support the submission. I live within 300ms overlooking the wharf on
the northern side.
As the level of sulphur fuels will be adopted globally on 1 Jan 2020 I
feel it is unnecessary to subject Eden to special conditions as
imposed at White Bay prior to these global levels being introduced. It
could have a devastating impact on cruise visitations during that
period which would result in an equally devastating impact on Eden's
economy.
Noise from Cruise ships has never been a problem for us or our Bed and
Breakfast. We get more noise from the working port below us that
operates 24 hours. The activity from the wharf below us is why we
chose to live there.

See attached submission.

Please see attached letter.

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