Port Stephens Finfish Research Facility (SSI-5118)

I would like to support the Marine Finfish Research lease in Providence Bay at Port Stephens. I have been holidaying at Hawks Nest and Port Stephens for over 15 years and I have a keen interest in the natural environment of the area. However I believe unless we move to develop aquaculture as a means of managing sustainable fisheries we will continue to see the decline and decimation of wild fisheries both in Australia and internationally.
I believe the future lies in the cultivation via aquaculture of a smaller number of species for mass consumption, combined with much smaller targets of specialist high end wild caught fish.
The Port Stephens research project will be able to trial methods of production as well as determining appropriate species for future use in commercial operations.
I understand some years ago there was a successful attempt to grow snapper in cages in Providence Bay and that the only reason the project did not continue was that the Australian seafood market was not ready to accept aquaculture fish into the market. I also understand there was no environmental impact on the surrounding wild fish population or the seabed. Given this, it would seem crazy not to support this project as an example of the future of seafood production in this country.

This submission refers to our full support of the proposed 20 hectare aquaculture research lease in Providence Bay, offshore from Hawks Nest in NSW.

Please find attached our letter of support from the NSW Aquaculture Association Inc.

This region needs to see Aquaculture grow, the world needs aquaculture to grow to ease pressure on our wild stocks and address the worlds growing population.

Aquaculture provides new jobs and has many flow on positive outcomes for a community, such as processing and value adding the product, transport & distribution and hopefully the replacement of imported products, and could potentially have export markets for the end product

Marine Lease, Providence Bay, Hawks Nest.
I have some concerns about this proposal.
Visual Pollution. Experience with the earlier Marine Lease located to the south of the present proposal has lead me to conclude that the sight of the cages on the horizon is a feature inconsistent with an area of outstanding natural beauty.
The Marine Leases are clearly visible from the lookout on Yacaaba, a point of interest for many visitors to the area. To refer only to the effect from Tomaree in the department's information appears designed to misinform.
The use of artificial feed sources can produce fish unsuitable for human consumption. Keeping fish closer to the surface than would be normal in the wild also presents problems. The experience of the earlier failed snapper fishery should be used.
What about the existing lease ? It isn't being used, it should revert to the state.
Is it possible to angle the narrowest side to the shoreline so that there is less visual effect ?
Thank you for the opportunity to comment.

Please see the attached. We wish to comment, but also enquire further into the proposal.

We wish to make the following comments regarding this proposal, having seen the information at the Hawks Nest Community Hall on Friday 23rd November, where we discussed the matter with the representatives there. Thank you for that opportunity.

We recognize that there is a need to augment wild seafood catch with farmed seafood. We are uncomfortable with the quantity of imported seafood, with some doubts as to the sustainability of some of that catch. As a result, we do not knowingly purchase any imported seafood, but we also restrict purchases of farmed seafood. We endeavour not to purchase seafood which has been recognized as endangered, or unsustainable. We eat 1 - 2 seafood-based meals per week.

Our reservations/enquiries are:

* Has there been a full and thorough investigation of the current marine life in the proposed area, including all resident and migratory species, both underwater, including whales, turtles and migratory fish, seaweed species, shellfish and invertebrates, and also pelagic birds including albatross, shearwaters, terns, gannets, little penguins etc, and the endangered Gould's petrel, all of which dive for their food in the area. This investigation should also have included the seals, sharks and dolphins.

If not, we would have concerns about which benchmark will be used to properly measure any effects on this existing wildlife by the proposed fish cages and this research.
* We note that that all ropes, nets, etc are from nylon or polyethylene. As we regularly pick up fragments of such every time we walk along Bennet's Beach, is there any reason why ropes and nets made from natural fibres cannot be used, even in part, given that they do eventually decompose fully, unlike the man-made equivalent. We continue to see distressing photographs of the result of these non-biodegradable fragments floating in our oceans. Can we hope that with regular inspection and maintenance no fragments of ropes and nets will escape. Can we ask what chemicals will be used to clean the nets and ropes?
* Our question regarding whether at the end of the proposed 5 year research Pices or a similar commercial enterprise would be granted permission to continue fish farming in the area was not fully answered, and we now ask that question again.
* We discussed the ongoing problems experienced in Tasmania by salmon farmers and resident seals, and will watch with interest the impact on the local seal colony.

We consider that the fish cages will be more visible than NSW Fisheries has stated. From the shoreline they will appear on the horizon, but from the lookout next to the surf club - and from the deck of the surf club itself- they will be very obvious. Many locals and tourists appreciate the amenities of this lookout and its adjacent picnic facilities. Some of us also climb Yacaaba, our mountain, and enjoy the view.

We attach the following photographs, taken by Barbara, of southern right whales which spent a few hours close to shore last year. Photos taken from the lookout next to the surf club.



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We chose to live in this region because it is a place of great natural beauty, as well as being home to a good community. We are concerned at any development which might mar that. On the day that we paid the deposit for our home here, in 2006, we climbed Yacaaba in celebration. From the summit we watched as a humpback whale and her calf swam south along Providence Bay, quite close to shore, before passing between Yacaaba and Cabbage Tree Island. We have had the wonderful experience of walking along Bennet's Beach, becoming aware that a humpback whale and her calf were swimming south not far beyond the breakers, and keeping pace with them as they continued, again passing between Cabbage Tree Island and Yacaaba. There are frequent sightings of whales in the designated area.

Thank-you for this opportunity to comment on the proposal.

See attached PDF response to planning research lease dpi

I have reviewed the Marine Finfish Research Lease Providence Bay EIS and strongly support the proposal. I am an environmental scientist and planner based in Port Stephens and have followed this project with interest. The proposal provides great sustainbility outcomes for aquaculture as well as economic multipliers for the Port Stephens area.
I believe this new and inivative proposal will benefit the region and contribute to the diversity of aquaculture of Port Stephens as well as advancing new technology that could have wide ranging benefits for fin fish aquaculture globally. Well done!

The NSW Aquaculture Research Advisory Committee (ARAC) is a statutory body established under the provisions of the NSW Fisheries Management Act 1994. ARAC comprises an independent chair and representatives of the oyster and non-oyster aquaculture industries.

ARAC advises the Minister on the level of contributions to and expenditure from the trust accounts established for annual contributions made by permit holders (oyster and land-based research levies) and advises on the directions/priorities for research that will benefit the NSW Aquaculture Industry.

ARAC fully supports sustainable seafood and has had positive discussions on the Marine Finfish Research Lease Providence Bay, Port Stephens - ARAC strongly supports
this research.

I would like to offer the attached letter of support for this application. Marine aquaculture in NSW specifically cannot go forward unless this EIS is approved and this research is allowed to be be validated at a commercial level.

Thank you for the enlightning exhibition demonstrated at the local hall last week. Personally and as spokesman for our club I wish you all the best. As recreational fisherman we see wild fish stocks deminishing before our eyes as a result of over fishing.If your research leads to availability of fresh fish to those who cant catch their own our wild stocks may get some relief. We feel proud to have this in our back yard as we hope it may generate local employment, tourism and endourrces our pristine enviroment. Thanks again and good luck.

Department of Planning & Infrastructure Application
Application SSI-5118

Marine Aquaculture Research Lease, Providence Bay, Port Stephens

I wish to object to Application SSI-5118 on the following grounds:

The data supplied within the Environmental Impact Statement (EIS) grossly underestimates and misrepresents the number of migratory species who pass through the area each year.

For example Humpback Whale Megaptera novaeangliae (listed as vulnerable) has a mere 3 sightings listed in the Wildlife Atlas. Each year in June, an Annual Whale Census occurs along the NSW coast. In 2008 and 2009 over 20 individuals were sighted and recorded on this day alone. More recent information,ORRCA can be obtained through ORRCA and their partnership with NPWS. ORRCA work closely with NPWS in the area attending and documenting strandings and deaths. This important community environmental group appear to have not been included in the consultation procedure.

The Grey Nurse Shark Carcharias taurus (listed as critically endangered) has been regularly sighted by scuba divers over the past 12 months on a number of occasions around north and western sides of Cabbage Tree Island, and also Fingal Island, much closer proximity than outlined in the EIS.

Research by Dr Barry Bruce over the past few years has identified the area as important for the juvenile Great White Shark Carcharodon carcharias (listed as vulnerable). The impact of the fin fish lease to their annual migration can only be implied.

Research on local dolphin species behaviour has been undertaken by local dolphin watch operators - installing the structure will impact long term data sets.

The EIS quotes Environment Protection and Biodiversity Conservation Act 1999 (EPBC Act). In my opinion, the fin fish research lease does not adhere to the aims of the Act. It has not provided sufficient information to protect a number of vulnerable and critically endangered species ( in particular those listed above), does not promote the conservation of biodiversity and does not provide for the protection and conservation of marine heritage.

The Port Stephens area is an important tourism hub and sustainable tourism activities: dolphin watching, whale whale watching and offshore scuba diving bring tourist dollars to the area. Many people have their first experience with larger marine mammals abord these vessels and come away with a greater awareness and appreciation of the need to protect these species and the marine environment. The loss of income to these local businesses will be substantial if the facility is allowed to proceed in addition to a loss of an environmental education opportunity.

I request the submission review panel to use the precautionary principle when assessing the application and EIS. It is impossible to provide a closed system for the proposed lease. The ocean is complex and adding new inputs - both fish stock and feed may have far reaching impacts (financial, geographic and temporal). Flow on effects cannot be managed within a short timeframe as the site will not be monitored 24 hrs/day and travel between the facility and land base will potentially add to reaction times if there is an incident.


The application does not abide by the principles of ecologically sustainable development as it does not protect the marine biological diversity of the area and does not assist in the development of a strong, growing and diversified tourist economy which can enhance the capacity for environmental protection for many years, and generations to come.

I would ask the submission review panel to consider these points before making a decision on the application and request it does not proceed.

To whom it may concern;

Re: Fisheries Proposed Marine Research Lease for aquaculture usage

Interactions between aquaculture and marine mammals are not benign. Consequences of aquaculture posed to marine mammals as per literature include death or injury via entanglement in gear, displacement of marine mammals (e.g. displacement of marine mammals from key regions of foraging importance) altered food chain, disruption of migratory routes, competition of space and human intervention (Wursig and Gailey, 2002; Kemper et al., 2003; Markowitz et al., 2004; Capps and Mann, 2005; Ribeiro et al., 2007).

Assessments of potential impact or posed impact of aquaculture are evaluated via baseline assessments of habitat usage, behaviour and distribution of animals and proximity to habitat (Markowitz et al., 2004) followed by research on comparing habitat usage, behaviour and distribution of animals during aquaculture operation.
The region proposed for aquaculture, consists of small odontocetes (bottlenose dolphins and common dolphins) large cetaceans (e.g. migratory Humpback whales) pinnipeds and sharks (e.g. critically endangered grey nurse shark). Reservations need to be expressed on the development of aquaculture in this area on the following grounds:
a) no baseline data is available on the common dolphins that utilise this area, and minimal data available on bottlenose dolphin usage outside Port Stephens region
b) possibility that the migratory routes of humpback whales may be altered by the presence of aquaculture
c) entangled of cetaceans, pinnipeds and sharks
d) potential displacement/disruption to foraging behaviour of animals that cannot evaluated in the absence of base line data and therefore, effective mitigation strategies cannot be implemented
e) potential entanglement of grey nurse sharks . The pregnant females of grey nurse sharks travel from Wolf Rock, Queensland and are considered to pup in waters near the proposed aquaculture development. This poses risks to entanglement of breeding females and males (males also observed in area) and entanglement of pups to a stock that is classified as critically endangered and susceptible to entanglement.

Therefore, I would recommend that before such lease is considered or pre- development of this industry that baseline data on all concerning taxa is accumulated to develop a better understanding of the potential consequences on an individual, species and ecological level can be better assessed. Furthermore, this should be accompanied by during data and reviewed by independent university researchers.

Port Stephens branch of NSW Farmers Association has, in General Meeting, voted to support the proposal by NSW DPI for a 20 hectare aquaculture lease at Providence Bay.
We believe that such research developments are essential to the future supply of marine produce, both in Australia and world-wide.
With increased pressure on wild fish stocks, and increased fishing effort globally, fish farming is clearly the way of the future,
and needs to be supported and encouraged wherever possible.
Thank you for the opportunity to comment.

Please see attached letter of submission

Crown Lands is writing in response to your letter dated 22 October 2012 in relation to the Public Exhibition of the EIS for the above mentioned proposal.

Please see attached.

Please see attached.

Please see attached.

As requested.