Pindimar Abalone Farm

Please see PDF attached

I wish to add my views on the condemnation of the proposal to create an Abalone farm at Pindimar. While I am writing this letter for myself I also am writing in support of the thousands of citizens who live in the Port Stephens area and to those thousands upon thousands of visitors who holiday in this beautiful holiday destination every year. A major attraction for these people to the area is the pristine waters in the bay and the opportunity this represents for healthy fishing as well as swimming and other water activities.

I am concerned that this issue has already been argued in the Land and Environment Court by the residents and that the creation of the Abalone farm was soundly beaten. A key issue with the earlier decision included the risk to tourism and resident lifestyle and health that could easily result through extensive pollution and the growth of water borne diseases. The new plan resubmitted has doubled the size and increased substantially the probability of even greater environmental and social damage.

Since the time of the first application, even more reports have surfaced about issues of a fouled water environment with outflows from Abalone farms in Victoria and Tasmania. The plan of an Abalone farm that delivers waste into Port Stephens must not go ahead. Both citizens and future Governments of NSW would pay a very high price if this were the case as Port Stephens becomes less and less useable by locals and visitors to the region.

Please see the attached document.

Objection to the Pindimar Abalone Farm Project, 10_0006



Development Assessment Systems & Approvals, Planning & Infrastructure, GPO Box 39 Sydney, NSW 2001.

Attention: Director, Industry, Key Sites and Social Projects.




I am writing to object to the Pindimar Abalone Project. I am concerned about the poor level of risk identification and in particular the failure to address the impacts of this industrial project proposal on what is a small residential community. The traffic management section of the proposal appears to make a number of significant under assumptions including the number of vehicle movements.
The traffic assessment report asserts that 15 Full Time Equivalent Employees (FTE) employees are assumed to generate only 8 traffic movements. 15 FTE is more than 15 individuals and a conservative assessment would be that they each travel separately.
Cambage Street is a small urban street with no through access. Traffic is limited to residents and a small number of visitors who come to observe the area. With no footpaths, it also serves as a pedestrian route used for walking as well as cycling. This level of use is consistent with the low level of traffic movement experienced.
Regular traffic movements from a new industrial project will significantly impact upon residents and the manner in which they are able to use the amenities of the area.

I urge you to insist on an alternative access route that is not via Cambage Street and if this in not achievable this proposal should be rejected due to being inconsistent with the adjoining land use.

See attached PDF.

This plan involves pumping 50 megalitres per day of water ( 20 Olympic swimming pools ) from one of the most valuable water parks in NSW : a bay, with the massive risk of contaminating the ecology of the entire bay.

The proof of safety just does not exist and the example of the damage caused in Victoria is extremely serious : Ganglioneuritis, Perkinsus destroying 90% of WILD abalone on the Victorian coast.

This has been not widely advertised in any news media, yet it is of State and National significance , as this is one of the most beautiful and delicate waterways in Australia.

If this were a coastal project then the damage would be minimised , but to take water in from INSIDE pristine Port Stephens and risk complete contamination of this waterway should not be allowed to be considered.

Submission to Department of Planning for the Pindimar Abalone Project; Application No. 10_0006
I have never donated money to any political party within NSW or any part of the World.
I object to the proposed Abalone project. For the purposes of the Public Exhibition I have provided the following overarching items of concern. However, if this matter were come before an Panel Advisory Committee; I would like to provide greater detail and evidence for my concerns.
1. I do not want the locality of my investment property and retirement destination to be part of an aquaculture experiment for a project that cannot provide evidence that it is scientifically, environmentally, socially or commercially viable.
Contrary to the Director General's requirements, the EA has not provided justification that the project is commercially viable. There are four very general statements on p. xxvii of the Environmental Assessment (EA) stating that:
* the proposal may help reduce fishing pressure on wild abalone populations,
* the species is suited to being farmed within environmental parameters of the site
* the site is suitable, and
* the project will result in economic benefits.
However, nowhere in the EA are there any specific evidence justifying exactly how the project will deliver the above benefits. I am concerned that this project will result in a failed experiment, leaving abandoned infrastructure in the Port, denuded native forested areas, estuarine seagrass meadows and mangrove , and seagrass beds, and that it will infect and/re-infect local abalone and molluscs populations with deadly viruses.
The water quality evidence provided in the EA is up to 14 years old (Manly Hydrolics). It is agreed that Abalone need good quality water, but the ph an temperature of the water in the port is likely to become a problem for captive abalone.
2. It concerns me that I have identified a number of the mathematical errors in the EA, which raising concerns of the thoroughness of the scientific studies and assessments upon which this project is founded.
For example, on page. xxiii, it is stated the farm will have a building footprint of approximately 1.2 ha (about 2.3% of the total site area). However, it is also noted that construction will require clearing of an additional 1.2 ha for bushfire protection. This means the project footprint will actually be about 2.4 ha; which is approximately 4.8% of the total site; almost twice the state amount. This example is perhaps a simple error, however this error raises my concerns that there could be more significant errors in the complex water movement and water quality calculations.
3. I am concerned that the project is likely to exacerbate prevalence of Perkinsus in the local abalone population.
There has been a closure on the harvesting of wild abalone within most of NSW, including the Port Stephens for a number of years, and only recently has limited recreational fishing of wild abalone been open again in the Port (Port http://www.dpi.nsw.gov.au/__data/assets/pdf_file/0003/229746/Abalone-Closure.pdf). The proponent proposes to source broodstock from NSW (p. xxxii) , thereby avoiding Abalone Viral Ganglioneuritis (AVG). However, I am concerned that likely broodstock will be infected with Perkinsus and under aquaculture conditions this parasite will proliferate and escape into the Port to infect wild abalone. I am concerned that inadequate and ad hoc measures will be followed to identify and manage outbreaks of Perkinsus in the farm. In one instance close proximity to the 'Marine' water quality is described as an asset, and yet, in relation to Perkinsus, the excessive distance to the marine environment is considered a protective barrier in relation to disease transmittance. Appendix 5 (Biosecurity & Disease Management Plan) provides no specific information about Perkinsus and how the disease is transmitted. Appendix 5 only provides generic descriptions of 'best management protocols', an 'AquaPlan' and use of sentinel abalone, it does not refer specifically to Perkinsus. Table 4.1 of Appendix 5 suggests that treatment for acquired broodstock includes treating incoming water by aging for 5 days with UV and filtration, however, according to the plans there are insufficient facilities to store 5 days worth of water. The EA suggests that Australia has already been identified as a Perkinsus disease positive nation; surely we should be doing everything possible to control this disease.
I am concerned that the 'swirl separators and protein skimmers' won't provide sufficient biosecurity and disease management of growout and larval rearing facilities.
4. I am concerned that the water quality being discharged from the outflow pipes will have elevated levels of nitrogen which will lead to demise of the Posedonia seagrass beds, and also potential algal outbreaks within the Port. Examples provided from farms of the oceanic coasts of South Australia cannot compare to this estuarine example. A number of industries within the Port rely on 'clean' water; including the oyster growing industry and local touring and fishing industry, would be decimated by algal outbreak and/or further drop in the water quality of the Port.
I am concerned that the sedimentation pond will provide be limited opportunity to treat the water before it is discharged into the Port and over existing sea grass meadows, and water quality is likely to be worst after going through the pond.
5. I am concerned that the disturbance to the foreshore mangrove and the sea grass meadows communities that will occur in the laying of the pipes. There is very little description of the procedure this will involve and I am concerned the impact of this operation has been seriously trivialised.
6. I am concerned of the impact on the flora and fauna of the terrestrial environment. This area is a very special habitat for a number of endangered species and vegetation communities; including Koalas, which has been inadequately surveyed and addressed in the Environmental Assessment report.

NSW PLANNING & INFRASTRUCTURE
Application MP 10-0006 Land Based Abalone Farm 7/5/14
180 Clarke St. PINDIMAR. Proponent - Austasia Leefield Pty Ltd
Council Area - Great Lakes & Port Stephens; Approval Authority - Minister for Planning & Infrastructure.

Dear Sir/Madam,
I wish to lodge my objection to the proposed Pindimar Abalone Farm development.

I run a small, home-based graphic design service and rely on the business that comes to me from local businesses predominately involved in the Tourism Industry. The success and economic strength of this industry rests entirely on the pristine quality of the Port Stephens waterways - an enormously significant asset, not only for locals, but for the nation.

I am also a passionate fisherwoman and spend a great deal of my leisure time in my boat with my two sons, enjoying the waterways and fishing when the weather permits. My passion for this lifestyle is such that I have recently joined the "Friends of Port Stephens", a group committed to protecting the natural environment of the waterways of Port Stephens - particularly in relation to supporting the Great Lakes Marine Park.

It is my view that the future of our Port - and thereby our tourism industry - are at risk should this proposal be approved. Indeed I have numerous concerns about this proposal, including the following:

1. The toxic nature and outrageous amount of effluent that will be pumped into Port Stephens - 24/7! (Eg, 1000kg nitrogen pumped into the port will have a devastating impact on the aquatic flora and fauna in these magnificent waterways, home to turtles, dolphins, sharks and many species of fish).

2. The danger of setting a "precedent" - opening the doors for other locally established aquaculture operations to gain approval for disposal of effluent into the waterways.

3. The lack of baseline data - there is no body responsible for monitoring the health of the Port Stephens waterways - inadequate data has been collected to determine how and when fluctuations in water quality may occur and therefore, make it impossible to prove that the farm actually is responsible for the potential degradation of water quality. This also casts significant doubts on the claims of the proponents as to the viability of the proposal.

4. The data provided by the proponents is inadequate - for example, they have not provided verifiable Water Flow Plans.

5. The data provided by the proponents does not describe the project as "low risk" in terms of its impact on the waterways and local environment! Accordingly, a significant proportion of the proposal presents a moderate or HIGH risk to the environment. This is in their own report!

6. The methods described for the construction/laying of the commercial industrial pipes is outdated technology, indicating the proponent's disdain for modern, best-practice approaches for such operations.

7. The issue of disease prevention is not adequately addressed in the proposal.

Some years ago, I was employed by the local Chamber of Commerce. I was approached by the proponents to discuss the proposal prior to their defeat in the Land and Environment Court with their previous attempt to establish this abalone farm. I agreed to meet them to discuss their proposal - in my own home. I was persuaded by them at the time, that there was NO THREAT WHATSOEVER to the waterways. Indeed, in relation to the quality of the water that is returned to the Port after use in the farm, I was ardently reassured that the water is returned in a perfectly pure and natural state; I was told that this wastewater would be "in even better condition than the water that was extracted from the port in the first place".

I have since learned that this was a bald-faced lie! How anybody could consider the discharge of high levels of nitrogen as "clean water" is alarming - even delusional. I have no doubt that the proponents have no interest or concern for any negative impact they may have on this precious, precious asset of Port Stephens.

Whenever there is ANY risk to the quality of the water in this precious marine park, the answer
MUST always be NO. This proposal represents a powerful and unacceptable risk to the waterways of Port Stephens, and therefore the tourism industry that employs so many people in this special region, and I strongly urge you to reject it.

Yours faithfully,

I Object to the proposed Pindimar Abalone Farm Project. I object to a proposal for a land-based factory in this environmentally sensitive area due to its environmental impacts.

The grounds for my objection are as follows:

- Circulation of pristine seawater through 4 x 650mm pipes at a rate of 50 mega litres per day resulting in the discharge of waste and effluent, including the discharge of 1000 kg of nitrogen and other waste materials inside of Port Stephens.
- Construction of pipeworks that will extend into the Port by half a kilometre.
- Discharge of waste and effluent into the estuary, which can take up to 12 - 14 days to flush, with the potential to damage important ecosystems.
- The risk of mollusc diseases such as Ganglioneuritis, Perkinsus, which has affected Victorian and Tasmanian coastal areas.
- Factory noise and odours affecting nearby residents, holiday-makers and tourists
-Sediments and erosion, causing habitat destruction
- Increased traffic and trucks on inappropriate roads, factory light spillage/pollution, factory operating noise, and extra load on the already fragile local electricity supply

Abalone Farms are located in coastal environments and in areas where the temperatures do not exceed 19 degrees Celsius. The estuary is an inappropriate and unsustainable location. It would lead to ongoing and lasting impacts and potential for overdevelopment.

Yours sincerely

Christopher Levins

On behalf of the Foundation for National Parks & Wildlife, I object to the proposed Pindimar Abalone Farm.

The Foundation is a fundraising and grant-making organisation. We support conservation works both on and off park. We run a grants program supporting private landowners that voluntarily protect the conservation values of their own properties and have made a commitment by permanently protecting their land.

Tallowfield Wildlife Refuge is neighbour to the proposed Abalone Farm. The Foundation provides grants for conservation works on properties such as Tallowfield Wildlife Refuge and therefore has an interest in protecting the values these properties maintain.

The proposed development is likely to affect the Wildlife Refuge by removing mature trees with nesting hollows as well as through under-scrubbing and thinning. These activities will reduce the value of the areas broader wildlife corridors, the Tallowfield Wildlife Refuge itself as well as the surrounding protected areas including the national park and marine sanctuary.

Highest consideration should be given to the impact on surrounding protected land and to its owners who voluntarily protect its conservation values. The work these landowners do is free and of benefit to the Australian environment and public at large. Their work is be supported and encouraged rather than jeopardised.

Kind regards,
Susanna Bradshaw
CEO, Foundation for National Parks & Wildlife

I would like to make a submission in objection to the project. The attached pdf outlines my concerns.
Regards
Martin Robinson BEng(Environmental)

We act for the Pindimar Bundabah Community Association Inc.

We have been instructed by the Association to engage certain experts to provide advice on the environmental assessment prepared by the proponent for the Pindimar Abalone farm.

We have now been instructed to forward the reports by

1. Mr Julian Fyfe in relation to Marine Water (wastewater) management and
2. Assoc Prof Robert Day in relation to disease risk and the impact of high summer water temperatures.

These are by way of further submission from the Association, and relate to its objection to the proposal.

The Association requests that the decision maker consider the issues raised in these reports, when determining whether approval should be given at all or the conditions that ought to be imposed on any approval.

Please note that we expect to receive an updated report by Assoc Prof Day with references attached and we will forward that to you in due course.

If you have any questions about these reports, please do not hesitate to contact us

Ian Ratcliff | Senior Solicitor | EDO NSW
Level 1, 71 Molesworth Street, PO Box 868 Lismore NSW 2480 AUSTRALIA
T: +61 2 6621 1112 | F: +61 2 6621 3355
E: [email protected]
W: www.edonsw.org.au

Submission attached.

I am very concerned of pollution to the Port Stephens bay

I would like to strongly object to the Pindimar Abalone Farm project. From my understanding the Pindimar Abalone Project, now on exhibition, seeks to build a large land based abalone farm and siphon 50 megalitres of water, through the farm into Port Stephens. They are proposing to build this farm not on open ocean but 9km from an inlet to the sea. Abalone farms are incubators of disease as has been expensively demonstrated in Victoria and we object to another source of possible disease being introduced into this fragile, beautiful and valuable location especially in view of the fact that abalone are not a vital food source, but an exotic delicacy that most Australians never eat. These Abalone will all be exported and only make money for a few investors. I would like to propose that we preserve the waters of the Port to enable it to be as clean as possible not only for the current residents but for future generations as well as the very important tourism industry.

I strongly oppose the proposal for the Abalone Farm. We have opposed it previously and continue to object for the same reasons as before. The current proposal is back with only minor adjustments however of significant concern is that it is now twice as big as the previous plan. I object to this proposal, again because of the risks to the environment including pollution of Port Stephens, risk of disease incubation, destruction of the local ecology, and introduction of heavy industry in an inappropriate location. This plan is a huge mistake and if successful the citizens and future Governments of NSW will pay a very high price as the Port becomes less and less useable by locals and visitors to the region.

The EPA has completed a review of the exhibited EA and advises that the proponent has not addressed concerns raised by the EPA in the adequacy review regarding potential impacts to receiving waters. Accordingly the EPA is unable to issue recommended conditions of approval for the proposal at this time.

The Greens NSW raise a number of concerns with the proposed development including the impact of a development of this size so close to a Marine Park Sanctuary Zone, the likelihood of high morality rate of abalone in the final project and the risk of spreading disease in surrounding waters.

The RFS has reviewed the EA. including the Bushfire Protection Assessment prepared by Australian Bushfire Protection Planners Pty Ltd, issued 3 February 2014, and recommends conditions of approval for the proposed development.

OEH acknowledges that in general the EA is considered adequate with respect to biodiversity/threatened species and Aboriginal cultural heritage matter, albeit some minor matters need to be resolved.