Modification Jervis Bay Mussel Farms Relocation and Expansion

Marine Parks are equally important, valuable & precious as any land based designated wilderness area or National/State Park. It is impossible to comprehend that any activity (commercial or otherwise) that involved the deliberate introduction of a species not indigenous to that area into a land based wilderness/Park area would be given approval, particularly when it would be known, or should have been known, that the species introduced would not be able to be managed in a way that would guarantee it would not/could not escape or impact the wilderness/Park area in any way. And yet this is precisely what has happened with the approval of the Jervis Bay Mussel Farm & it's ongoing operations. And now the owners/managers of Jervis Bay Mussel Farm are looking to be rewarded for their incompetence/complacency/ignorance by seeking to expand. Really?

The fact that part of the farm has been established in an area outside the approved location supports the view that A/ the owners/managers are little concerned with ensuring that they operate as per the approval, and B/ there is insufficient oversight by relevant State authority of either the establishment, ongoing operations or the detrimental impact the mismanagement of these mussels are having on the Jervis Bay area.

* The Jervis Bay Mussel Farm should have it's approval revoked, It should be fully removed, and the owners/managers should be held responsible and accountable for cleaning up the environmental impact. I am assuming here that the initial approval included watertight legal obligations on the part of the operators to operate in a way that ensured there could be NIL environmental impact on any part of Jervis Bay or surrounds, and substantial & meaningful penalties for not meeting those obligations. If the initial approval does not include sufficient safeguards, guarantees and penalties that can be applied in any instances of contravention then we should also be examining the fitness of the NSW State Government to make such approvals.

** At the very least there should by NIL expansion approved. The existing environmental issues are the responsibility of the mussel farm & must be fully rectified by the mussel farm. There must be ongoing monitoring & oversight by qualified & independent third parties to ensure all the environmental lapses cease . And any part of the mussel farm outside the approved designated area must be removed.

In conclusion: If a business approached the State Govt of NSW seeking approval to introduce a cane toad breeding facility inside a wilderness area managed by NSW State Govt I'm confident the Govt would reject that application for a number of reasons including the environmental risk. We know how cane toads impact our environment. And yet that is precisely what the Govt has done in approving the Jervis Bay Mussel Farm. These mussels are as feral as the cane toad & are impacting the environment. The longer the mussel farm remains in Jervis Bay the greater that impact will become. And, if the NSW State Govt now wants to say "oh, but we didn't know..." then what was the Govt doing by granting the approval in the first place ? The Govt fully knew that the mussels to be grown on that farm were NOT indigenous to Jervis Bay. Please do the right thing for the environment and Jervis Bay - these mussels do not belong in Jervis Bay and should be removed.

I am concerned by the increase in the mussel farm lease and the ongoing problems and changes that I am observing in Currambene creek and Jervis Bay . I am employed as a Coxswain and diver in the recreational dive industry , and I complete around 150 dives per year in Jervis Bay , as well as dives for Reef life Survey . Although my observations are anecdotal I do hold tertiary qualifications in marine science , one of my concerns is the lack of accurate and comprehensive scientific research done into the effects of mussel farming on the environment , this lack of research risks serious environmental damage to our already stressed ecosystem .
One concern is the high level of mussel recruitment in Currambene Creek , recently an aluminium tender was removed for maintenance and had 100 percent cover of mussels below the waterline . Mussels can be seen growing on many areas other than boat hulls in the creek , It is difficult to believe that these introduced mussels are not competing with the native epifauna in Currambene Creek . Mussels are becoming much more abundant in areas of the bay as well , sites such as The Nursery (Bowen Island) they are abundant and easily found .
Jervis Bay Marine park is a precious , and rare temperate ecosystem , it seems almost incomprehensible that an invasive and non native species can be introduced and allowed to breed in the center of the park , adjacent to Sanctuary protected zones . Management within the park should reflect the infinite value of the natural ecosystem , and all precautions taken to protect this system from anthropogenic damage or change .
There is a large amount of anecdotal evidence to suggest that the current mussel lease is having impacts on the environment so further expansion of the mussel lease will be detrimental to the Marine Park and the wider environment , to expand without comprehensive research and data would be irresponsible or negligent .

11 December 2023

Sally Munk
Project Officer/Contact
Dept of Planning

Application to Modify Existing Commercial Aquaculture Development (Relocation and Expansion)
Jervis Bay NSW
SSI-5657-Mod-1


My objection to the original proposal (11 Nov 2013) is outlined below for your reference and remains applicable today:

1. Jervis Bay is a unique NSW coastal bay that has strong eco-tourism values due to its pristine environmental qualities. The entire area relies on this for generation of local income.

2. Jervis Bay is home to approximately eighty dolphins that are within and around the proposed lease areas every day. No-one can predict with any certainty the impacts upon this population, which has far greater environmental and eco-tourism value to the region than the supposed creation of 30 new jobs.

3. The views of Jervis Bay from local residential communities and beaches have always been highly valued for their pristine, untouched qualities. This is an area surrounded by National Parks and Marine Parks. The proposed leases will impact significantly, adversely and permanently upon these highly valued environmental values. Although the leases are not within the actual Park areas, it is an established principle that the curtilage to these Parks is of high significance in assessment of any proposal that may have adverse environmental impacts.

4. The leases require operation of barges on a daily basis. This will further impact upon the environmental quality of the Bay. The barges and permanent buoys will create visual pollution of the environment.

5. The quietness of Jervis Bay is one of its most important environmental qualities. Operation of the proposed leases will create continuous noise pollution both above and below the water. This will detrimentally impact upon residents and visitors, and potentially with catastrophic impacts upon the resident dolphin population.

6. The clean, clear air and water quality of Jervis Bay is one of its most important and valued environmental qualities. Operation of the proposed leases will have high adverse impacts upon this, through large quantities of organic waste generated by the mussels and continuous operation of the barges, which are likely to be diesel-fuelled.

7. Adverse impacts upon marine life are not limited to the dolphin population, they will extend to all marine flora and fauna within the Bay. The proponents of the proposed commercial enterprise can offer no certainty in relation to the extent or nature of these impacts.

8. The proposed leases are very close to established residential communities at Callala Beach and Vincentia. These waters are used regularly and frequently by all forms of small recreational watercraft. The proposed lease infrastructure will create additional navigation hazards and permanent loss of access to a highly valued public asset.

9. The proposed lease will provide economic benefit to relatively few people, and principally to the private lease operators. The adverse impacts will affect thousands of people however, including local residents and visitors to this profoundly significant and beautiful area. On this basis I urge the Department to not approve these proposed leases in any form.


These Significant issues raised at the time (Nov 2013)were not seriously investigated/considered and the Muscle Lease was granted.

With the introduction of the Muscle Leases it appears over time the significant issues, such as view loss, changes to dolphin habitat, lighting impacts, and a commitment to no further aquaculture development have been largely diminished

Also, the lessees commitment to regular updates since lease inception have not occurred.

Regarding all the changes proposed to the existing commercial aquaculture development at Callala Beach in the Marine Park of Jervis Bay
Including a new, lease area to be constructed between the two existing leases, occupying the entire view corridor from all Callala Beach public access points to the iconic Jervis Bay Heads

This application (as previously) focuses on benefits that serve the interests of the developer/lessee, and fails to demonstrate/create the positive (if any) impacts of this proposal on local communities and natural environment


Please consider:
1 no change to existing aquaculture footprint in front of Callala Beach.
2 no leases to be moved any closer to Callala Beach than current position.
3 Preference for the entire aquiculture leases to be removed

Please note/address my concerns/objection for the following reasons:
1 More research is available on the negative impact of aquaculture farming on the marine environment .

2 Lack of evidence provided in relation to entanglement or death of large marine fauna.

3 Altered long-standing movement patterns and behaviour of marine fauna in Jervis Bay

4 The barges, permanent buoys and lighting create visual pollution

5 The uninterrupted views of Jervis Bay from local residential communities and beaches have been compromised.

6 The lessee has stated that there are public benefits provided through employment for up to 30 local residents. Could the benefits to the wider community. Be provided in detail. Also what are the Financial benefits to the taxpayer and if they are commensurate with the financial gains that are enjoyed by the lessee_

Thank you for considering the issues that concern me and on behalf of the locals and broader community I hope you listen and take into consideration to stop or even better remove this unhealthy/unsightly introduction into the bay

Warm regards

Louise
LOUISE CHAPMAN

There needs a proper impact study on the current lease and then go from there.. Too often the real cost is born on the enviroment & the people that live here this isn't fair or realistic for the impact on future years...

I object to this project

We the Jervis Bay Cruising Yatch Club (JBCYC) are opposed to the expansion and relocation of the existing mussel farms for the following reasons:
1. When the mussel farms were originally approved, one of the stipulations was that they would not interfere with our racing courses around the bay. In their existing position they are interfering with our racing courses however, we have managed this to date by sailing closer to Callala beach thereby skirting around the north west cardinal marker. If the farms are moved a further 250-350m closer to callala Beach, as proposed, this would certainly make it much more difficult to negotiate a number of our set sailing courses.
2. The additional mussel farm in between the two existing farms will effectively cut the bay in half between Callala Bay and Huskisson. This mean sail boats will have to go a significant distance further when transiting between the moorings in Currumbene Creek and our club house in Callala Bay.
3. Club members have already seen a significant increase in fouling of boats and mooring lines since the introduction of the mussel farms. The increase in the maintenance of mooring equipment and boats has had a significant financial cost to the members.
4. The mussel farms have become a navigation hazard that can effect people who are not familiar with the Bay. A larger footprint will bring a more significant risk to all water users and the possibility of environmental damage due to accidents.

Please see attached document containing my comments.

[1] The proposed development of the extended lease area will further impact an area of outstanding natural beauty and negatively economically impact the tourism appeal of Callala Beach, ‘Unspoilt Shoalhaven’ and that of the Jervis Bay region.

Visual impact of increased daily ships, fishing buoys, netting, structure, will now be across the entire Callala Beach seafront, be closer to shore, and continue the light pollution of the Bay at night. If there is rationale to move the existing lease from the high tourism epicentre of Vicentia to Callala due to being ‘less visible’ why should this be the case to move the entire operation to Callala Beach and further impact both the local population and the tourists that choose Callala as their tourism location preference. A granting of this proposal will be to the determent of the Callala local tourism and extended economy.

[2] Unnatural impact to the delicate marine life balance of Jervis Bay

Marine life, including dolphins, are now attracted to the feeding areas of the mussel farms rather than the foreshore areas they located frequently before the establishment of the muscle farms. So much so that the Jervis Bay marine tourist vessels now frequent that location as priority. This has created a change in the natural feeding environment of marine life in Jervis Bay. There is also a concern that sharks will also be further attracted to the rich feeding areas that the mussel farms create. With the proposal bringing the location of the mussel farms closer to Callala Beach shore there is danger that shark frequency and even attack could be a result of this increase in development.

this submission is entirely driven by commercial request of the current operator, and shows no consideration for visual implications for current property owners and the general public. the existing operation is working and any need to change is not apparent. extra area is a further infringement on the beautiful bay, and to lump it all together to further impact the amenity , in a negative way is totally unjustified, and unnecessary and ignore ratepayers and general public views. already we see less of the dolphins , for example. thesis fact. there is no need to negatively impact Jervis Bay any further.

Please see attached objection

I object to any change to the existing commercial aquaculture development at Callala Beach in the Marine Park of Jervis
Bay for the following reasons:
1. Lack of balanced and effective communication with stakeholders. There was one ill prepared community briefing with no data being presented to address previously expressed community concerns.
2. Insufficient time allocated for public exhibition and for the community to understand impacts and respond. We found out about this in a mail drop from the local Progress Association. If Shoalhaven Council can contact property owners, why not the DPI?
3. Time for public comment conducted over quiet pre-Xmas period (ends 13 December 2023). This again smacks of a tone deaf process being carried out to avoid public input. What is DPI afraid of?
4. Significant issues such as view loss, changes to dolphin habitat, lighting impacts, and a commitment to no further
aquaculture development were ignored by the NSW State Govt agencies when the lease was granted. This lease has been operating for 3 years. Why was the monitoring data not presented?
5. Alternative sites within 140sqkm of Jervis Bay were not seriously investigated in response to community concerns.
6. Given previous failure to listen to the community, where is assurance that we will be listened to this time?
7. The current DoPI application focuses on benefits that will serve the interests of the developer/lessee, and fails to
demonstrate concern that the impacts of this proposal will have on local communities.
8. the highly impactful existing leases of 40Ha are proposed to be increased to 70Ha: a 75% increase in area as a result of a 'mistake' by DPI????
9. A new, lease area will be constructed between the two existing leases, occupying the entire view corridor from all
Callala Beach public access points to the iconic Jervis Bay Heads.
10. The proposal is the size of the entire Callala Beach village.
11. Both existing leases are to be increased in size by 10Ha each, because of an error by the DoPI and developer in setting out the existing leases. The impact of aquaculture farming on the marine environment is summed up in a recent posting on the internet by a keen diver who states "On a recent trip to Eden whilst diving in Twofold Bay, I was shocked
and disgusted to find once healthy reefs had been inundated with mussels, displacing much weed and marine life from
12. Lack evidence provided in relation to entanglement or death of large marine fauna. New proposal will further
increase this risk. This is not a new project. Monitoring has been going on. Why was the data not presented?
13. New leases have radically altered long-standing movement patterns and behaviour of marine fauna in Jervis Bay, including the much loved resident dolphin population. Dolphins have abandoned Callala Beach and primarily now feed at the development leases. Local residents confirm that the level of previous level of dolphin visitation has been reduced to an estimated 10% of pre-lease frequency. This issue was raised by many objectors during 2014 consultation, but dismissed
by DoPI/DoPE on basis of no evidence to support this claim.
14. The unobstructed views of Jervis Bay (particularly towards the Heads) were unique and of extraordinarily high value
to the wider community and the key natural heritage values of eastern coastal Australia. These no longer exist.
15. View impacts and sharing was never considered worthy of inclusion in the original EIS. Community raised this issue, DoPI subsequently commissioned a visual assessment report that concluded such impacts would be negligible due to distance from shore, use of submerged buoys and a low angle of view from beach. This conclusion is now demonstrably
incorrect. The proposal to move the Vincentia lease is based on views! How is this to be assessed? Who decides whose view can be sacrificed?
16.- This controversial development is located on public land, and the public has a right to expect Government to deliver a financial benefits to the taxpayer commensurate with the financial gains that are enjoyed by the lessee, yet DoPI will not
divulge, purportedly for "commercial in confidence" reasons.
17. A copy pf the Lease Permit Conditions dated September 2015 states that the annual lease fee $56/Ha (56 x 70 =
$3920 pa, including a Research Contribution of $42/ha = $2940 pa . Would DPI shut this project down for $3920?
18. The lessee has stated that public benefits are provided through employment for up to 30 local residents, and by supporting local businesses who provide a range of services required to operate their business. How these fundamental costs of running a private enterprise at a peppercorn rent could be considered to be of benefit to the wider community
and the public is not clear.
19. Commitment to regular community information briefings by the lessee since lease inception have failed to
eventuate.

This morning I was sent these photos of mussels on the hull and motor of a boat that has been moored in Currambene Creek, near the Woollamia boat ramp. Mussel 2 is an image of the propeller. The photos were taken between 12 and 18 months ago. I have no additional information. Can you attach to the previous HWCV submission. Many thanks

I object to the project due to the Visual Amenity and concerns for the bed of the Bay with impact by its anchors plus other issues

See attachment.

1. Safety: I have concerns regarding the decreased navigational markers from 10-6. I sail regularly with JBCYC and find the current farm markers difficult to see in choppy weather. The reduction will increase the risk of an accident.
Moving the lease closer to Callalah beach will reduce the navigational space which impacts significantly on sail powered vessels.
2. Biofouling (Risk 3): I have personally cleaned mussels from intakes and areas on boats. This is not anecdotal!
The earlier mussel farming quoted in the report was significantly smaller in scale. The SCM proposal is more than 7 times the size. SCM have only been operating since 2029 with their first harvest in 2020. It is likely that significant spats events have only been occurring for 2 years and yet the impact has already been significant. Evidence of mussel biofouling would not be hard to obtain - a study and solid data should be a prerequisite for the expansion.
3. Bio security: mytilus galloprovincialis is an invasive introduced species (scientific papers on this are available). Continued risks of increased spreading within a Marine Park is incompatible with conservation objectives. If the DPI have allowed this species to become endemic within such a short time this is environmental vandalism and they should be held accountable. Instances of Blue Mussels sited in the report are insignificant compared to the current situation.
4. Reported incidents (Risk 20): SCM production has been significantly impacted by mussels falling off the ropes during storms (wave surge) to the extent that “local” mussels were unavailable for a period of months. Presumably the mussels that fell to the bottom consequently died. Was this mortality event reported?
Moving the leases closer to Callahan will decrease the depth by approximately 5 meters which will increase the risk of impact by storm surge.
5. Environmental (specifically seahorse): How is the removal of seahorses “managed” during the harvesting operation. The mechanical harvesting machinery utilised is not conducive to protection of seahorses. What evidence or data is there on impacts on seahorses during harvesting?
In summary the risk assessments that have been carried out are biased and understated.

Our Future Shoalhaven has consulted with other organisations associated with the health and well being of the Jervis Bay Marine Park. From those discussions we have assembled the attached submission that objects to aspects of the application to increase size and move the Mussel leases in Jervis Bay NSW. The organisations consulted are Keep Jervis Bay Unspoilt, Treading Lightly, National Parks Association Milton Branch, and Nature Coast Marine Group Inc.
Bruce McKenzie

I would like to object to approval of the modifications to this project before an independent researcher can verify that the mussels are not an environmental threat to Jervis Bay which is after all a Marine Sanctuary. The mussel farm should not be extended.
It is also advisable that no more mussel spat be brought to Jervis Bay from Eden in case of likely contamination occurring in the Bay.

I strongly object to any expansion of Aquaculture in Jervis Bay.
People live and visit the bay because of its unspoiled natural beauty, and yet you have allowed a commercial operator to scar the pristine seascape with infrastructure. The original approval should never have gone ahead and now you want to make it even worse by bringing it closer to the shore and increasing the size ? To make it worse the taxpayer is actually paying this operator to destroy the environment and make a profit using a public resource, this is completely unacceptable.
There is plenty of evidence from other aquaculture ventures across Australia that prove it causes long term damage to indigenous species and the environment. Most of these affects will take years to show up, however we have already seen the loss of Dolphins which used to frequent the beach regularly. By the operators own admission the Dolphins are now congregating at the lease along with seals and fish. This unnatural increase in wildlife in the bay will of course attract more sharks which will be drawn even closer to the beach if the leases are moved and expanded.
The whole application process is seriously flawed. No notification was sent to Callala residents. We only found out through a Facebook post at the end of November .
The application to expand the lease should be withdrawn until further research on the effects of intensive commercial activity in a marine park can be reviewed and proper public consultation is carried out.