Jervis Bay Aquaculture Facility

See attached

See attached letter.

On behalf of the members of the NSW Aquaculture Association we are pleased to offer our support for Fisheries NSW to establish Commercial Shellfish Aquaculture Leases within Jervis Bay, NSW. We support the establishment of all three leases, the 10 hectare lease off Vincentia and the two 20 hectare leases off Callala Beach, Jervis Bay, NSW.

Currently over 75% of the seafood consumed in Australia is imported, with over 85% of the seafood consumed in NSW imported. To reduce our reliance on imported seafood we need to turn towards aquaculture. The NSW commercial fishing industry is not expected to increase from current sustainable catch levels and potentially may reduce after the current reorganization. NSW needs more aquaculture to increase its seafood security and this proposal will contribute towards this aim.

Once approved these three leases will not only provide an opportunity to increase our seafood security which is so desperately needed, but provide an opportunity to increasing local employment with immense benefit for the local community generally.

As per the EIS the leases will have little impact, with no nutrient input (feeding) of shellfish, little visual pollution with only navigation buoys positioned on the corners, and with the mooring, anchor and backbone ropes kept under tension there is little risk of marine fauna entanglement. The NSW Aquaculture Industry is regulated to employ "Aquaculture Best Industry Practice" to ensure the environment of NSW is protected and the aquacultured produce from NSW is the cleanest, greenest, safest, sustainable seafood that money can buy. We all support the regulatory authorities, as just one small rogue aquaculturalist can have devastating consequences for the whole Australian aquaculture industry. The NSW Aquaculture Association Inc. has full confidence in the regulatory authorities: Fisheries NSW together with the NSW Food Authority will ensure the produce from lease to plate is cultured, harvested and sold safely for the environment, the community, the farmer and the consumer.

The members of the NSWAA fully support Fisheries NSW to establish these leases and make them available for tender to shellfish growers.

Please see attached file with our complete submission

Please find attached the following submission

See my Attachment for the reasons for my objection.

Refer to submission details in attached PDF file.

A .pdf file of our submission will be uploaded.

EDEN SEA FARMS
PO Box 213 Eden NSW 2548

The Hon. Katrina Hodgkinson
Level 30 Goveror Macquarie Tower
1 Farrer Place
Sydney NSW 2000

12 November 2013
Dear Minister
Re - Commercial Shellfish Aquaculture Leases Jervis Bay , NSW
I write in support of the proposed establishment of Commercial Shellfish leases within Jervis Bay. I am a Director of Eden Sea Farms the only commercial mussel farm in NSW holding some 49 hectares within Twofold Bay Eden, NSW.
We would welcome expansion of our industry within NSW where in general marine aquaculture has been neglected to the detriment of the State and Australia. Most other states have a thriving diverse aquaculture industry and while NSW has been a leader in oyster farming, inertia has prevented us developing other marine aquaculture undertakings especially those of a economic and environmentally sustainable nature. This is in the light of a decline in the commercial fishing industry highlighted by the closure due to reduced input of fish of the Eden Fishermans Cooperative.
Mussel farming within Twofold Bay has been operating in various forms for + 20 years with a major expansion some 10 years ago when the current mussel farming operation expanded with the addition of 32 hectares granted as Aquaculture Leases.
This expansion encountered considerable opposition from ill informed commentators. This resulted in significant costs to the proponents who had to undertake various studies to establish additional base line data before the leases were granted.
We undertook and continue independent scientific benthic studies at considerable expense to monitor the impacts if any of the farm on the harbour bottom under the farm and to date there has been no measurable impacts found.
Extrapolating from our experiences in Twofold Bay it can reasonably be argued that there would be no deleterious effects in the area proposed for mussel farms in Jervis Bay given the current flows within the Bay and infrastructure proposed.
We were subject to a number of objections concerning infrastructure and mussel shell washing up on beaches and while there was some initial impact resulting from failures in old raft infrastructure the newer longline structures has minimised the loss of material and we do not receive complaints from the public and in fact find them very helpful in informing us of occasional floats that wash up after a heavy weather event.
Concerns' regarding visual impact of the longlines was another additional study that had to be undertaken and despite vocal claims that the farms would be an eyesore the experience of the last 10 years confirms the conclusions of the study that the farm would not impact adversely on the outlook from the shore. In fact the farm has become a tourist attraction with the cruise boats regularly visiting the lease site.
There is a considerable demand from tourists for our product and interest in the process when they visit the wharf where mussels are cleaned for market with significant numbers of visitors saying they cannot get quality mussels at home.
This allows interplay with our staff and helps visitors gain an understanding of the strict environmental and Safe Food requirements that Australian quality seafood has to meet that a lot of imported product does not have to comply with. A similar interaction is likely in Jervis Bay that can only enhance the public's understanding of the need to protect our marine environment.
We encountered a lot of concerns from the public and various government agencies re the potential for marine animal entanglements. Given that Twofold Bay is a major stopover point in the whale migration route between the tropical waters of Queensland and Antarctic waters we are very conscious of the potential for such occurrences but in the 10 years of longlines there has been no such occurrence. Furthermore there is a significant dolphin and seal population within the Bay - a major tourist attraction when whales are not present - and again there have been no problems encountered As Jervis Bay longlines will be constructed similarly to our infrastructure I can see no reason why any entanglements will occur.

Accordingly I would support the expansion of NSW's marine aquaculture industry with the establishment of Commercial Aquaculture Leases in Jervis Bay.

Yours sincerely


Chris Boyton
Director
Eden Sea Farms

EDEN SEA FARMS
PO Box 213 Eden NSW 2548

The Hon. Katrina Hodgkinson
Level 30 Goveror Macquarie Tower
1 Farrer Place
Sydney NSW 2000

12 November 2013
Dear Minister
Re - Commercial Shellfish Aquaculture Leases Jervis Bay , NSW
I write in support of the proposed establishment of Commercial Shellfish leases within Jervis Bay. I am a Director of Eden Sea Farms the only commercial mussel farm in NSW holding some 49 hectares within Twofold Bay Eden, NSW.
We would welcome expansion of our industry within NSW where in general marine aquaculture has been neglected to the detriment of the State and Australia. Most other states have a thriving diverse aquaculture industry and while NSW has been a leader in oyster farming, inertia has prevented us developing other marine aquaculture undertakings especially those of a economic and environmentally sustainable nature. This is in the light of a decline in the commercial fishing industry highlighted by the closure due to reduced input of fish of the Eden Fishermans Cooperative.
Mussel farming within Twofold Bay has been operating in various forms for + 20 years with a major expansion some 10 years ago when the current mussel farming operation expanded with the addition of 32 hectares granted as Aquaculture Leases.
This expansion encountered considerable opposition from ill informed commentators. This resulted in significant costs to the proponents who had to undertake various studies to establish additional base line data before the leases were granted.
We undertook and continue independent scientific benthic studies at considerable expense to monitor the impacts if any of the farm on the harbour bottom under the farm and to date there has been no measurable impacts found.
Extrapolating from our experiences in Twofold Bay it can reasonably be argued that there would be no deleterious effects in the area proposed for mussel farms in Jervis Bay given the current flows within the Bay and infrastructure proposed.
We were subject to a number of objections concerning infrastructure and mussel shell washing up on beaches and while there was some initial impact resulting from failures in old raft infrastructure the newer longline structures has minimised the loss of material and we do not receive complaints from the public and in fact find them very helpful in informing us of occasional floats that wash up after a heavy weather event.
Concerns' regarding visual impact of the longlines was another additional study that had to be undertaken and despite vocal claims that the farms would be an eyesore the experience of the last 10 years confirms the conclusions of the study that the farm would not impact adversely on the outlook from the shore. In fact the farm has become a tourist attraction with the cruise boats regularly visiting the lease site.
There is a considerable demand from tourists for our product and interest in the process when they visit the wharf where mussels are cleaned for market with significant numbers of visitors saying they cannot get quality mussels at home.
This allows interplay with our staff and helps visitors gain an understanding of the strict environmental and Safe Food requirements that Australian quality seafood has to meet that a lot of imported product does not have to comply with. A similar interaction is likely in Jervis Bay that can only enhance the public's understanding of the need to protect our marine environment.
We encountered a lot of concerns from the public and various government agencies re the potential for marine animal entanglements. Given that Twofold Bay is a major stopover point in the whale migration route between the tropical waters of Queensland and Antarctic waters we are very conscious of the potential for such occurrences but in the 10 years of longlines there has been no such occurrence. Furthermore there is a significant dolphin and seal population within the Bay - a major tourist attraction when whales are not present - and again there have been no problems encountered As Jervis Bay longlines will be constructed similarly to our infrastructure I can see no reason why any entanglements will occur.

Accordingly I would support the expansion of NSW's marine aquaculture industry with the establishment of Commercial Aquaculture Leases in Jervis Bay.

Yours sincerely


Chris Boyton
Director
Eden Sea Farms

Please see uploaded pdf attachment

Please see attached PDF
Text version below

Dear Sir/Madam
My comments are limited to the assessments of impacts of the proposed leases, section 8.2. In particular the section dealing with the impact of resource competition from shellfish spat.
The following quote is taken from page 186 of the EIS
Resource Competition (EIS Page 186)
"There is the potential for cultivated spawning shellfish species to influence the distribution of individual shellfish species within Jervis Bay with possible consequences for the balance or makeup of wild assemblages of biota"......." Concerns exist that an increase in the number of mussels introduced to Jervis Bay will increase the size of the spawning population in the bay and increase recruitment pressure on rocky shores and rocky reefs."
This section addresses in part questions that I posed in an earlier submission to Graeme Bowley late December 2012. Graeme responded advising me of the timetable for the EIS and the opportunity to make submissions.

The major question was, will increased spat input into the bay have adverse effects on:-
a. Sessile animals, tunicates, barnacles, limpets, on the intertidal area?
b. Increased fouling of boats?

After careful reading of the EIS I remain unconvinced that the EIS adequately answers these questions.
The EIS implies increased spawning will be of little consequence.
"The capacity for cultured stocks to contribute to wild recruitment also needs to consider the characteristics of the spawning cycle for shellfish (which take a number of years to reach full spawning potential), the farming methods (which remove the larger and more mature specimens for sale prior to them spawning) and the lack of appropriate spawning triggers in Jervis Bay (in effect a sudden and prolonged cold snap). Collectively these factors generally work together to reduce the likelihood there would be large farming-induced spawning events in Jervis Bay."
Certainly farming methods that involve removal of larger mature specimens will limit spawning. However if shellfish are grown to a reasonable size, it is evident from figure 67 that some gamete production is inevitable. Indeed I understand that without substantial reproductive tissue in muscles shellfish are hardly marketable. The EIS argues (last para page 186)
"cultured mussels in Jervis Bay were previously harvested between about 10 and 14 months of age. Figure 67 indicates that at this age the mussels have low reproductive capacity and therefore would not be significantly contributing to the wild population of mussels in Jervis Bay."
Note: Figure 67 presents data of growth rates and gamete production from Long Island Sound (USA).
At face value, the conclusion drawn in this paragraph would be a reasonable assumption, however it is misleading as growth rates at the two locations would be markedly different. For example Hammerson (2004) indicates at depths of 6- 7 ft, winter water temperatures in Long Island Sound vary between 0-4OC and summer temperatures 20-23oC. The summer water temperature at this location might approach that in JB however the winter temperatures are vastly different. Thus to imply similar growth rates and maturity states at the two sites is poor science and misleading.
The lack of appropriate spawning triggers in JB is also suggested to limit spawning of the cultivated shellfish. However this suggestion is clearly countered by the statement (page 186),
"Certainly, practical experience gathered in Jervis Bay has recorded heavy natural spatfall occurring...".
The triggers might not be reliable for commercial harvesting of spat, but evidently such triggers do occur.
Another quote page 187 implies that spatfall will not be a problem to the ecology of the bay.
"Mussel farming had occurred previously in Jervis Bay from late 1970s to 2008 with no significant impacts from recruitment being identified."
The key words in the above quote are "being identified". In the absence of supporting evidence in the form of an appropriate survey to measure changes that may have occurred, this argument is unconvincing. If such data existed, I suggest that they would have been presented. Further, the intensity of the proposed shellfish production is likely to far exceed the more limited and less structured cultivation previously undertaken.
Thus I believe the likelihood of markedly increased spat production from the aquaculture leases and the inevitable population of mussels that become established after dislodgement from the ropes has been underestimated in the EIS.
I also believe that the ecological consequences of such increased spat production have not been suitably addressed in the EIS. Increased fouling of moored boats in Callala Bay and in Currambene Creek will cause additional costs to boat owners. Increased fouling of navigation markers, mooring ropes and buoys will require increased maintenance.
However, while the impacts on man would be inconvenient, my major concern is the impact of spatfall on the environment of the marine park itself. Reefs and intertidal regions may be regularly overwhelmed by unprecedented levels of spat settlement to the detriment of existing sessile animals and thus the ecosystem of the bay. More frequent cleaning of moored boats will add to the shedding of toxic antifouling compounds in environmentally sensitive areas, particularly along Currambene Creek.

Comments on proposed monitoring
Proposed monitoring for deleterious impacts in and around the proposed leases is to be applauded. However there appears to be no proposal to assess impacts at more distal locations to detect changes due to enhanced spat establishment. If the leases are established, I believe it is incumbent on the proponents of the scheme (NSW Dept Primary Industries) to perform such surveys, report their findings and use such data to regulate stocking rates.
In my earlier submission, I raised the potential importance of mussel predators (starfish?) present in the vicinity of the lease thriving and thereby increasing their output of offspring that in turn will lead to changes throughout the bay. If the leases are established it would be important to assess changes in predator levels.
Finally, Dr Chris Hardy, CSIRO, Ecosystems Sciences has developed sensitive DNA means to assess differences in faunal assemblages including assemblages in marine sediments. If the leases are to be established, it might be useful to consider if ecogenomic approaches would be a useful addition to monitoring efforts.

Attached

Please find copy attached of my submission regarding Commercial Shellfish Aquaculture Leases, Jervis Bay, NSW.

I object to p0roposal