Modification Jervis Bay Mussel Farms Relocation and Expansion

This mussel farm is compromising the ecological integrity of JBMP, and is contradictory to the primary purpose of the marine park, which is to conserve the biological diversity, and maintain ecosystem integrity and ecosystem function, of bioregions in the marine estate; all activities within the park can only be undertaken where they are consistent with the primary
purpose. i.e. maintains ecosystem integrity.

Information that indicates the mussels are becoming invasive
There is evidence that the mussel farm is having a negative impact on the marine ecosystem, and having a negative impact on other users of the Bay and Currambene Creek.

The mussel farm uses the species Mytilus Galloprinvincialis which is a European species. The mussel that is endemic to Jervis Bay is Mytilus Planulatus. There is now evidence that the mussels are becoming an invasive species in parts of Jervis Bay and Currambene Creek.

Failure to fulfil conditions of the licence.
• One Condition of the licence designed to prevent the invasive spread of Mytilus
Galloprinvincialis – an obligation to harvest the mussels prior to reproduction - has been
worded in such a way that the operator has no real obligation to harvest the mussels prior to
reproduction because they are only obliged to do this ‘where possible’. They are not obliged
to publicly record when they have failed to do this, or why they have failed to do this. Hence
we have no real understanding of the failure of SCM or DPE conditions.
• It was noted in the recent Environment report a significant difference between fish
assemblages Update 1 and Baseline, but noted that not enough is known to assess the
significance of this difference. Again in the 2022 benthic survey they note a significant
difference but say not enough is known to attribute cause to the mussel farm. Why was the
study not re-scheduled when they were not able to obtain a full set of data. It has been
reported that juvenile Port Jackson sharks can be found underneath the lease infrastructure.
This is a significant change and has not been reported.
Ecological impacts
• There is a significant question around ‘ecological carrying capacity’ of introduced mussels
into Jervis Bay. This was reported as a potential issue by Joyce et al. and they recommended
further assessment of this prior to commencement. It is not known publicly whether or not
that occurred.
• P. 23 of Joyce et. al states ‘cultivation of exclusively local species would be permitted under
Marine Park regulations’ and installation of shellfish requires special consideration. Their
analysis points out that the mussel farms can act as Fish attractant devices, and that the
overall impact on the health of the ecosystem is not clear.
• A study undertaken by Borschmann (2022) found “there is evidence to support that the
mussel culture is resulting in an increased larval supply (in Jervis Bay), as greater subtidal
recruitment of mussels was found closer to the mussel culture site. It is possible that the
continued supply of larvae from the culture of mussels in Jervis Bay into the future may

continue to seed new populations and may result in similar trends to Twofold Bay. Post-
settlement predation and competition do not appear sufficient to control mussel population

increases resulting from an increased larval supply, as evident by significantly greater
shoreline abundances in Twofold Bay. Once populations establish, study results indicate
Mytilus galloprovincialis can outcompete other epifaunal organisms for space, suggesting
that an increase in Mytilus galloprovincialis populations due to increased larval supply may
have long term impacts on the ecosystem structure through the reduction of species
richness.”
Biosecurity threat
• The current operation presents a biosecurity threat to the JB Marine Park. SCM grow the
mussel spat in Eden and then replant them in JB. This is contrary to advice given in a report
into the viability of aquaculture in Jervis Bay undertaken by Joyce, Rubio & Winberg,
“The risk of introducing foreign pests or pathogens is much greater with translocation of
wild spat collection than with hatchery produced seed. Formerly, mussel seed was collected
in Twofold Bay and moved to Jervis Bay, though in future, this type of translocation from
Twofold Bay may be inadvisable, as Eden is a primary port of call for international vessels. A
source of hatchery spat is preferable from both a biological and production standpoint.”
2009, P.23. (our emphasis)
Just recently on 28th November 2023 a cruise ship (P&O Pacific Adventure) was prevented
from entering New Zealand water due to its dirty hull and biosecurity risk. This same ship
diverted to Hobart, and will then travel to Eden.
Current communication with the community has been all about the ‘benefits’ and inadequate
discussion of the disbenefits. We find this to be a biased presentation of the situation.
They are all serious concerns with regard to the integrity of the marine park. These matters require
independent (not funded by SCM) examination and reporting. That is, there should be rigorous
research before extending the mussel farm, and an examination of the management approaches to
ensure that the mussel farm is not a source of spat.

I object to the project until further research is carried out.

I would like to understand if an independent assessment of the current farms impact on the environment is being undertaken in context, of an expansion of the operation is likely to have on the environment. Similarly, I would also like to understand what criteria is being used to judge further potential aquaculture applications from other businesses to operate in the Jervis Bay Marine Park.

My concerns are:
Use of an invasive species
Biosecurity threat
Failure to fulfil conditions of licence
Bias in information
The modification shouldn’t be allowed without some additional environmental studies being undertaken first.
There should be more stringent conditions, and more accurate reporting around the impacts of the DA.
The questions raised seem of such critical importance to the future of the Marine Park that DPI should immediately suspend the application until appropriate answers are available. Jervis Bay Marine Park should be preserved and not threatened by possible commercial operations.

This is disgusting, this is affecting Jervis Bay that is a significant culture bay to allow this in public waters is beyond disbelief that you will allow this, callala beach means fish and there should be no corporation in or around callala beach, this is beyond a joke to allow it,

We the people of callala do not accept this take you greedy pockets away, you still haven't even upgraded the boat ramp facilities at myola or Callala bay, this application should not be accepted as you are not giving back to the local communities, from the leasing of this projects we are still yet to see one single cent coming out of the leasing, into our facilities

The mussel farm already located in the Bay is already an awesome. No definitive proof has been provided that this will be a positive scheme for the area. We just have to take the word of some spokesperson that says 'its great'. There has already seen a radical decline of dolphin sitings, as well as a massive amount of mussel shells washing up on the beach. The view from the beach is an eyesore, especially at night with the lights ruining the landscape. With Mussels comes seals but they also attract sharks, more aggressive sharks than whatever already lives in the local waters. What will happen to the beautiful white sand our area is famous for. Why has this not been allowed in other areas as to where it was proposed. The expansion will only destroy a pristine part of the world but will ruin a healthy ecosystem. There is no evidence to prove otherwise.

What a surprise…
why waste your time with community consultation when the decision is obviously already made.
If anyone is looking to fight this, my suggestion is to look into the so-called marine biologist who’s opinion allowed the mussel farms establishment; is she a financial beneficiary of the farm?
When the farm was first marketed to us via ‘community consultation’ the mussel operators suggested it would create many jobs for the local indigenous community, about a year ago I asked whether this had occurred, they never responded.
Interestingly the first to propose a aquaculture farm in Jervis Bay was Eddie Obeid and Ian McDonald….

The visual impact of the proposed changes straight off the shore of Callala beach will ruin the entire atmosphere of the area. We choose to live in this area because of the unspoiled, pristine beaches. It is these Unspoiled views which attract tourists to our area. The main driver for our communities economy. An expansion of the aquaculture farms will change the entire outlook of Callala Beach and Myola. The uninterrupted views and natural beauty of Jervis Bay in this area has already been compromised. Many views from Callala beach now focus on a commercial fishing operation not an unspoilt marine park as far as the horizon could see. Furthermore, the aquaculture operations create excessive noise pollution For hours each day. The dolphin and whale boats and naval operations in the area Create noise that is temporary or passes by. The aquaculture boats, create a very loud drone sound, which is continuous for several hours most days of the week particularly when the boat is harvesting. One does not visit Callala Beach and Myola to subject themselves to industrial noise. To further subject the community to significant changes in the coastal vista While other areas of the bay go unaffected is unfair and unnecessary.
Furthermore, the northern side of the bay where the muscle leases are located, does not receive any economic benefit. All benefits, go to the southern side of the bay around the huskisson and woolamia Where the business is located.
However irrespective of these issues I cannot see why the people of Callala Beach should be punished for errors made by DPI. The only reason these leases are being moved and increased in size is because DPI gave the Lease Operator the incorrect coordinates in the first place. In addition, there is no legitimate reason to move the two smaller approved leases located close to Vincentia. As far as I am aware there has been no recent complaints from residents in the Vincentia area and there certainly were no complaints from the 'Vincentia Rate Payers Association' when the original lease proposal was made in 2013.
It appears that DPI are trying to compensate the Lease Operator for their mistake by giving them a larger area of leases and by concentrating them in one location. Hence DPI are effectively punishing the local residents for their mistake instead of compensating the operator in some other way.

My opinion, it is unfair for any further expansion or increase in the aquaculture farming off the shore of Callala beach. This area has already suffered enough from the existing aquaculture leases and receives no benefit in return.

As a concerned resident of the Callala area and frequent user of Callala Beach I am totally against this proposed amendment to the Aquaculture Leases in Jervis Bay.
The proposed amendment will greatly increase the area of the leases located in front of Callala Beach as well as move them closer to the shoreline. The proposed leases will form a continual visual barrier along the length of Callala Beach. This will have a detrimental effect on the visual amenity of Callala Beach as well as increase the detrimental effect on water quality and sedimentation. More detail regarding these issues is given below.

This visual impact will have several adverse results and these are as follows.
A. Tourists come to Jervis Bay because it is seen as a near pristine unspoilt environment. The appearance of this semi industrial development straight off the beautiful crescent of Callala Beach will undoubtedly have a negative impact on tourism generally. This is especially damaging to Callala Beach where local business are already teetering on the brink of closure.
B. Local residents who utilise Callala Beach every day to enjoy its unspoilt beauty will be greatly disadvantaged. Many of the locals are already dismayed with the visual impact of the existing mussel leases.
C. The loss of visual amenity at Callala Beach will reduce land values. We note that the value of beach front properties at Callala Beach has already been reduced by new building policies based on sea rise resulting from global warming. The main asset of these properties is their unspoiled view of the bay and proximity to a clean beach.

Water Qualtiy
In addition I am concerned about the effect of this large increase in the leases close to Callala beach on the Water Quality and Sedimentation. Mussels are filter feeders which means they strain single cell algae and planktonic animals from the water to eat. Each mussel is capable of filtering about 300 litres of water per day and they in turn produce a large amount of faecal waste. “The average mussel farm is stocked with mussels at around 15/m² of seafloor and each mussel produces about 230 mg of waste each day, which translate to 35 g/m² of mussel waste per day. The enormity of this waste production becomes evident if the amount generated is calculated over a year: 125 t/ha/yr of mussel faeces.”1 Valid concerns exist on how this waste will be captured and disposed of and what impact this may have on aqua sports such as swimming. International research indicates that the seabed beneath a mussel farm can change significantly with the build up of mussel waste and shells. This material settles on the seafloor and can adversely alter the marine environment including the chemical and biological composition of the seabed. In New Zealand it is the general practice to locate mussel farms over muddy habitats rather than coarser sand habitats as “particulate waste deposition from marine farms can cause significant changes to habitats with coarser substrates. Mussel waste can also reduce water quality and clarity particularly if currents swirling around farm structures keep them (waste) suspended in the water column. This can result in less sunlight reaching the seabed particularly in shallower waters.”2 Marine studies have proven that a reduction in sunlight can further alter the flora and fauna composition of the environment that would be to the determent of local Jervis Bay species.

However irrespective of these issues I cannot see why the people of Callala Beach should be punished for errors made by DPI. The only reason these leases are being moved and increased in size is because DPI gave the Lease Operator the incorrect coordinates in the first place. In addition, there is no legitimate reason to move the two smaller approved leases located close to Vincentia. As far as I am aware there has been no recent complaints from residents in the Vincentia area and there certainly were no complaints from the 'Vincentia rate Payers Association' when the original lease proposal was made in 2013.
It appears that DPI are trying to compensate the Lease Operator for their mistake by giving them a larger area of leases and by concentrating them in one location. Hence DPI are effectively punishing the local residents for their mistake instead of compensating the operator in some other way.

In summary my opinion is that the only change that should be made is that insisted on by the Navy. This involves the moving of the existing leases out of the Navy Firing Range. No other changes to the approved leases should be made.

Just enquiring about the 160l bouys and other floats since operations began in 2019
There have been several storms of significant impact in that time and one or more 160l bouys have broken free and been observed on Callala beach ( with no apparent attempt to retrieve them) . Do we know the number of bouys etc that have been ‘lost’ and with the additional 2 leases operating will there be more washed ashore?

Thanks for the opportunity to comment and make reference on Modification Application SS1-5657-Mod-1. Our submission is self-explanatory.

Our family hospitality business is located in Jervis Bay and has been and continues to be a supporter of an aquaculture industry in the area and we proudly use the produce in our restaurant. However, first and foremost we support the need for stringent checks and balances to be in place to ensure the ongoing health of the Jervis Bay Marine Park for not just us but future generations to enjoy.
We believe that any expansion of the lease should only occur once the necessary and ongoing research is in place to monitor any negative impacts the industry may have on the marine park and act accordingly. We have had a boat moored in the Currambene Creek nearby the lease for nearly twenty years and in the last few months have noticed an unusual amount of mussels attaching to the hull and finding their way into the various outlets and also the propeller. We gather others are reporting a similar experience. This is not per se an issue for us, but if it is an indication of a more concerning impact on local ecosystems due to the invasive nature and increased quantity of mussel spat finding its way into the various estuaries then perhaps over time we could have a bigger problem. We are not saying no to the mussel farm , or its expansion, we just want to ensure the checks and balances are in place to ensure it is existing in harmony with the sensitive ecosystems of the the Jervis Bay Marine Park. Yours sincerely, Camilla

We request that permission to extend the mussel farm is held off until research into the mussel spread has occurred and a change to management approaches developed to ensure that the mussel farm is not a source of spat or a biosecurity threat. We request this because members of the community have reported mussel spread in Currambene Creek, and the species farmed is known to be an invasive introduced species; also as the bay is a Marine Park the community is concerned about introduction of other pest species with the spat translocation from Eden to Jervis Bay.
See attachment for further details.

So glad to see the expansion of Mussel farming in NSW. We love our weekly mussel soup and looking forward to seeing more NSW mussels at supermarkets.

If we want our children (and their children) to have a future, we need to be rapidly shifting to these more environmentally sustainable farming methods.

I object to the proposed expansion on the grounds that it is contrary to the integrity of Jervis Bay Marine Park (JBMP). There is evidence that the European mussels being grown in the existing mussel farm, which have been designated as an invasive species in a number of countries, have already invaded into the marine environment of Jervis Bay Marine Park (JBMP). Please refer to the submission by Our Future Shoalhaven for documentation of this evidence. This invasion will inevitably worsen over time and more so if the proposed expansion is allowed.

Aquaculture longline leases have operated in this area for a long period of time.
Potential risks including environmental risks are well understood and have been effectively managed over a long period of time.
The modification includes a review of 22 risks identified in the EIS developed in 2014 and concludes 16 risks will remain the same, six are expected to improve with the modification and two new risks are assessed and identified as not being significant.
The modification is supported by science, has undertaken sufficient risk analysis and proposes an effective risk management strategy to manage potential risks.
I support the modification because it is a sustainable method of food production.

I would like to submit my support for this proposal as it makes sense. I have absolutely no objection. This is a very good idea.

I write to express my concern that the expansion of the mussel farm in Jervis Bay, NSW has not been sufficiently considered. The introduction of Mytilus Galloprinvincialis – a species of mussel that is not endemic to the area – needs to be better monitored and reviewed before expansion of the farm is allowed.

The Marine Estate Management Act 2014 No 72 requires that a precautionary principle be applied and this should translate to further indepth review onsite by an independent researcher. The movement of mussel spat from Twofold Bay to Jervis Bay needs to be considered as to whether it constitutes a biosecurity threat to the Bay and its marine life.

If a thorough study shows that there is no damage to the Marine Park, and that the mussels have not become invasive, then it is reasonable that the expansion proceed as the company provides employment in the area.


Sincerely
Dr Katherine Goodnow
Vincentia, NSW

See Attached

Building capacity for such a sustainable aquaculture business as shellfish is vital to the future of Australia's sustainable seafood supply. This project is a standout of best practice and is to be encouraged.