Seaweed Aquaculture Lease, Disaster Bay - Eden 1

6 May 2026

Dear Planning NSW

I strongly object to this proposal.
My main concern is that this is a unique and pristine area.
I just feel that due process has not been followed assessing the value of this asset - Disaster Bay and Nadgee Wilderness area.

Without infrastructure, this Wilderness Coast has immense appeal to tourism - especially when properly managed to avoid overcrowding and over-visitation. The Eden economy already benefits from the Light to Light Walk and also from people walking the Wilderness Coast.
Disaster Bay is a unique place on the entire New South Wales coast. It is the last true Wilderness. The interlinked Greencape, Disaster Bay and Nadgee Wilderness is the jewel in the crown for the Sapphire Coast. To place any infrastructure here - apart from the historic Greencape Lighthouse and Cottages - is a little like starting a quarry at Ayers Rock, at Uluru!
I do feel that the project has failed due process with insufficient, truly public engagement including our local First Nations people. If this project was about planting seaweed to replenish existing seaweed, that would be a different matter. But it is not. It is about a kelp farm with infrastructure, buoys, lines, lights, plastic pollution and vessels disrupting a known whale migration route and whale resting area.

There must be other places that have already had infrastructure incursions, that are better placed, with colder water for a kelp farm. Tasmania may be ideal, but this also depends on the rate of warming of the oceans from global warming.

We need to think long term.
This is definitely the wrong development for the Sapphire Coast.
Why wreck a beautiful wilderness coast in the meantime? Why? The monetary gains, the so-called jobs and benefit to the Eden economy are just that - so-called.

This is probably the last true Wilderness Coast in NSW. Let's keep it that way.
Regeneration of native, endemic species of kelp is essential in all locations around the planet. Kelp forests are the nurseries for so many species.

Native seaweed is critical for the environment but should be absolutely quarantined from any threat of infection from seaweed farming. It is a real possibility and a real threat, that may put existing, last remaining seaweed colonies at risk.

This should be the focus - regeneration, not farming or harvesting that will tip this project into carbon emissions rather than carbon sequestration and will tip this project into polluting the waters with oceanic reach depending on the currents, impacting the feeding of whales on their migratory routes.

Peter Cocker

Submission on the Auskelp Eden 1 Kelp Aquaculture Farm
SSD-41680467 — Environmental and ecological objection
To: NSW Department of Planning, Housing and Infrastructure
Application: SSD-41680467 — Seaweed Aquaculture Lease, Disaster Bay – Eden 1
Proponent: Auskelp Pty Ltd

Introduction
I write to object to the proposed Auskelp Eden 1 Kelp Aquaculture Farm in the waters of Disaster Bay off Wonboyn. My family and I have been visiting this stretch of coast for many years and the proposal would establish a 200-hectare commercial aquaculture lease in waters directly adjacent to the Nadgee Nature Reserve and Wilderness Area. I do not oppose seaweed aquaculture as an industry. My objection is to the siting of this specific operation in waters of exceptional ecological sensitivity, on the basis of an Environmental Impact Statement that on its own terms does not constitute an adequate ecological assessment. Siting matters.
1. The waters off Disaster Bay are exceptional and largely unprotected
Disaster Bay sits south of the Batemans Marine Park, which terminates at Murunna Point. It is not within any declared NSW marine park. It is, however, classified as environmentally sensitive coastal waters under State planning instruments. The EPBC Protected Matters Search (A7) identifies the area as overlapping the Commonwealth-recognised Key Ecological Feature, the Upwelling East of Eden. The proponent's own benthic ecology consultants (A9) describe this as an important feeding area for blue and humpback whales when krill aggregations form.
The Protected Matters Search and the Protected Species Register (A13) acknowledge the potential presence of Southern Right Whale (Endangered), Blue Whale (Endangered), Humpback Whale, Loggerhead Turtle (Endangered, breeding likely), Leatherback Turtle (Endangered), Grey Nurse Shark east coast population (Critically Endangered), six seahorse species, nineteen pipefish species, the Weedy Seadragon, and fourteen albatross species. The Indo-Pacific Bottlenose Dolphin is identified as likely to breed in the area. The absence of marine park protection over waters of this calibre places a heightened obligation on the State assessment to apply the precautionary principle.
2. The benthic baseline is inadequate by the consultants' own admission
Document A9 is the principal source of information on seabed and water column conditions. Fieldwork was conducted over four days in late winter and early spring 2025, at 14°C, with single infauna samples at each of eleven sites and a single calm-winter water quality snapshot. The consultants explicitly state that an improved assessment would require multiple replicate samples across summer and winter seasons, and that water quality sampling would need to cover all seasons and weather events including catchment flood flows, large storm events and upwelling events.
None of the fieldwork was conducted during the upwelling season. Upwelling on the Twofold Shelf occurs in spring, summer and autumn. These are the periods when blue whales, humpback whales, krill aggregations and the productive food chain are present and feeding. The baseline captures the lease at the most ecologically quiescent time of year and is silent on conditions of greatest ecological significance.
Despite this limited survey, a single big-belly seahorse — protected under both the FM Act and EPBC Act — was recorded incidentally. The presence of even one protected species during a four-day winter snapshot indicates a properly designed multi-season assessment would identify more. A9 does not constitute an adequate baseline for a permanent 200-hectare lease.
3. The nutrient assessment uses a 50-kilometre grid for a 2-kilometre lease
The Nutrient Modelling Overview (A4) is an eight-page document, approximately four pages of which are technical content. A4 states that modelling relied on the Copernicus Marine Service Global Ocean Physics Reanalysis at a resolution of approximately 50 by 50 kilometres. The lease itself is approximately two kilometres by one kilometre. The model cannot resolve the local hydrodynamics of Disaster Bay or the lease.
The proponent acknowledges this. Section 1.5 of A4 states that the appropriate next-step modelling, combining a Macroalgae Growth Model with the regional MACMODS system, has not been undertaken because of compute costs and is contingent on future funding. The biological and physical model parameter tables list variables but do not contain populated values. The biomass estimate carries a 50 percent uncertainty range.
I anticipate the proponent will rely on bay-scale flushing rates of 5 to 8 days, and frame kelp nitrogen uptake as net-positive water remediation. Bay-scale flushing does not answer whether localised nutrient depletion zones form within and downstream of a 200-hectare permanent infrastructure during low-flushing or pre-upwelling conditions. The water-remediation framing is appropriate for nutrient-polluted estuaries. Disaster Bay is not such an environment. It is an upwelling-influenced ocean embayment where pulsed nitrate delivery drives the seasonal productivity that supports baleen whale feeding. The downstream ecological effect of nutrient drawdown across 200 hectares on this system has not been modelled.
4. The metocean baseline does not include hydrodynamic modelling of the bay
The BMT report (A3) describes itself as an initial desktop assessment for baseline metocean data. It is now over three years out of date at public exhibition. BMT states explicitly that current data presented is representative of currents offshore of Disaster Bay and is likely greater than speeds inside the bay, and that estimation of local current speeds requires a hydrodynamic model. That hydrodynamic modelling has not been commissioned.
Table 1.1 of A3, the Location of Interest table, records the lease coordinates as 153°15'E, 27°15'S — coordinates in Queensland, north of Fraser Island. The correct location is approximately 149°57'E, 37°16'S. The foundational location table in the proponent's primary metocean document is wrong by ten degrees of latitude. This is a quality-control failure in a document submitted as part of a State Significant Development assessment. The Upwelling East of Eden is not addressed by name anywhere in A3, and farm-induced changes to the local current and wave field are not modelled.
5. The Marine Fauna Interaction Plan is reactive, not precautionary
The Marine Fauna Interaction Plan (B1) sets out post-incident notification protocols. It is not a risk prevention plan. It contains no quantitative entanglement risk assessment, no modelling of cetacean migration tracks through the lease area, no reference to comparable kelp aquaculture incident histories, no trigger thresholds for operational suspension, and no requirement for independent observation. The nominated observer is a crew member of the proponent. The 100m and 300m vessel approach distances cited apply to vessels approaching fauna; they do not address fauna approaching a 200-hectare permanent surface infrastructure that cannot move out of the way.
The Humpback Whale migration is identified in the EPBC Protected Matters Report as a Biologically Important Area passing through these waters. B1 does not assess whether the lease sits within or adjacent to the migration corridor.
6. Visual amenity and the Nadgee Wilderness setting
Greenglades Beach and the wilderness coast south of the lease are among the most visually intact coastal landscapes remaining in NSW. The proponent's own ACHA assesses the aesthetic significance of the broader study area as High. The cumulative visual and experiential impact of a 200-hectare working industrial seascape on the wilderness setting has not been adequately addressed.
7. Request
For these reasons, I respectfully request that the Department:
1. Refuse the application as presented; or in the alternative,
2. Defer determination until the proponent has provided a full twelve-month, multi-season ecological baseline study covering benthic ecology, water quality, marine fauna and the upwelling season; site-specific hydrodynamic modelling of Disaster Bay including farm-induced changes to local currents and adjacent beach processes; and a quantitative entanglement risk assessment with provision for independent observation, public reporting, and trigger-based operational suspension.

Submission on the Auskelp Eden 1 Kelp Aquaculture Farm
SSD-41680467 — Legal, governance and consultation objection
To: NSW Department of Planning, Housing and Infrastructure
Application: SSD-41680467 — Seaweed Aquaculture Lease, Disaster Bay – Eden 1
Proponent: Auskelp Pty Ltd

Introduction
I object to the proposed Auskelp Eden 1 Kelp Aquaculture Farm. My objection focuses on the legal, governance and consultation framework around the assessment. The proposed 200-hectare lease sits in waters supporting NSW-protected species, on Yuin and/or Bidawal sea Country with an unresolved Native Title position, in a community where the engagement record contains material inconsistencies, and is described in the proponent's own materials as 'Eden 1' — implying an industry rollout that has not been the subject of cumulative impact assessment. I ask the Department to weigh these governance issues seriously.
1. The Commonwealth EPBC decision and the limits of its scope
I note the federal EPBC delegate's decision (A1) that the project is not a controlled action. A 'not controlled action' decision under section 75 of the EPBC Act is a determination that the project does not reach the threshold of 'significant impact' on Matters of National Environmental Significance. It is a jurisdictional gateway finding, not an environmental clearance, and it is not a finding that there is no risk to listed species.
Critically, the Commonwealth NCA decision relates only to species protected under the EPBC Act. The Commonwealth had no legal mandate to assess the project's impacts on species protected exclusively under NSW law. Under the NSW Fisheries Management Act 1994, all species of the family Syngnathidae — seahorses, seadragons, pipefish and pipehorses — are fully protected throughout NSW waters since 1 July 2004, with offences attracting penalties of up to $55,000 for corporations. The Weedy Seadragon, recorded by A9 in adjacent reef habitat, is a poor swimmer dependent on macroalgal habitat. The Protected Species Register (A13) identifies six seahorse species and nineteen pipefish species in the region. None of these populations have been quantified by population density survey because A9 was not designed to do so.
Under section 220ZW of the FM Act, a licence may be required for actions likely to harm threatened fish species or their habitat. The State assessor cannot rely on the Commonwealth NCA decision for this assessment because the Commonwealth did not assess these species. The same gap applies to species protected under the NSW Biodiversity Conservation Act 2016, including the Indo-Pacific Bottlenose Dolphin and Australian Fur Seal, neither of which is EPBC-listed.
I note that the C1 Community Engagement Strategy describes the Commonwealth decision as DCCEEW approval of a risk management plan. That representation is incorrect. An NCA decision is not Commonwealth approval of any management plan.
2. Aboriginal cultural heritage and Native Title
The proposed lease sits on Yuin and/or Bidawal sea Country. The proponent's own Aboriginal Cultural Heritage Assessment (A5) acknowledges the area has been a place of coastal cultural occupation for at least 3,000 years and assesses its cultural significance as High. That assessment was not derived from Traditional Custodians. It was derived from the consultants' own assumption. Nineteen Aboriginal groups registered their interest. None attended the proposed site meetings. Only one provided a substantive written response. The consultants themselves stated, in their own words, that an outcome to the consultation process could not be rendered. The High cultural significance rating was self-assessed by non-Indigenous consultants in the absence of confirmation from the people whose culture it is.
The C1 Community Engagement Strategy presents a different account. C1 states cultural mapping, oral histories and site consultation have been completed and integrated into design, and refers to 13 Registered Aboriginal Parties. A5 records 19 RAPs, no site meetings attended, and no consultation outcome rendered. The two documents do not say the same thing about the same process.
The South Coast Peoples claimant application (NC2017/008) is unregistered but overlaps with the project area. A5 records the claim but does not resolve it. The Crown Lands advice (A2) expressly notes that the absence of a determined Native Title area does not mean native title does not exist or is extinguished, and that any future act affecting native title rights must comply with the Native Title Act. C1's footnote stating that Disaster Bay is not located within the registered 2017 Yuin claim is technically correct but is misleading on the broader Native Title position acknowledged by the proponent's own Crown Lands advice.
The Operational Policy: Protecting Aboriginal Cultural Heritage, which A5 cites at length, requires application of the precautionary principle where the proposal involves a risk of serious or irreversible harm. The lease is permanent. The cultural significance is acknowledged as High. The consultation outcome was not delivered. The Native Title position is unresolved. The precautionary principle counsels against approval in these circumstances.
3. Community engagement contains material inconsistencies
The proponent has submitted two engagement documents. Document A11 is a generic March 2024 academic report that does not mention Auskelp, Disaster Bay, Wonboyn or the Eden 1 lease anywhere. It is industry research, not site consultation.
Document C1 is the proponent's project-specific strategy. It records genuine engagement: design changes including moving the offshore boundary from 656 metres to 1.1 kilometres, public sessions, an Interested Parties List of 503 contacts, and meetings with the Federal Member, State Member and Bega Valley Shire Mayor. The proponent should be credited for these. However, C1 contains material weaknesses. Wonboyn-specific engagement is thin: one Wonboyn community session with 10 attendees and one Wonboyn Fire Shed session with 65 in-person and 57 online attendees, for a permanent 200-hectare commercial development directly off Wonboyn's southern beach. C1 lists a Facebook group called 'Protect Disaster Bay' with five members in its stakeholder map, while implying balanced representation.
C1's Issues Raised log makes representations not supported by the rest of the EIS. Item 5 describes the EPBC delegate's decision as DCCEEW approval, which it is not. Item 8 asserts expected water quality improvements without site-specific modelling. Item 12 refers to mammal risk modelling not present in the EIS document list. Where a community engagement strategy makes claims to the public that the underlying technical documents do not substantiate, that is itself a community engagement issue.
Notably, the proponent's own attached A11 research found that on average 65 percent of NSW South Coast survey respondents did not believe all relevant people were being adequately consulted. The companion Croft et al. 2024 research, cited in A5 at section 1.3, found inadequate support for site selection is creating unacceptable risk to communities and proponents. The proponent has placed both findings in its own EIS while following a process those findings recommend against.
4. Cumulative impact and precedent
The proponent's documents describe this as 'Eden 1' — implying an Eden 2, 3 and beyond. The annual reports refer to industry-scale projections. The EIS treats this as a single 200-hectare lease and contains no cumulative impact assessment. If this lease is approved, it becomes the template for further commercial aquaculture leases in similar wilderness-adjacent waters along the NSW south coast. The decision before the Department is therefore not only about a single 200-hectare lease. It is about whether commercial aquaculture, at scale, may be established in waters that are environmentally sensitive, immediately adjacent to a declared wilderness area, and presently unprotected by marine park zoning. That is a significant policy question deserving a State-level position, not the cumulative effect of individual approvals.
5. Request
For these reasons, I respectfully request that the Department:
1. Refuse the application as presented; or in the alternative,
2. Restrict any approval to a 10-hectare staged pilot for an initial 24 months, with expansion contingent on independent ecological audit and on satisfactory completion of State-level assessments under the FM Act and BC Act for State-protected species not assessed under the EPBC Act process;
3. Require renewed and meaningful consultation with the Yuin and Bidawal peoples, including resolution of the South Coast Peoples Native Title claimant application as it relates to the project area;
4. Refer the question of marine park or equivalent statutory protection for the waters of Disaster Bay and the Nadgee-adjacent coast to the Marine Estate Management Authority before any further commercial aquaculture is approved in these waters.

The scientific evidence and the Nadgee Nature Reserve Plan of Management together compel one clear outcome: Auskelp’s Eden 1 proposal must be revoked and industrial kelp aquaculture permanently prohibited in Disaster Bay. Climate driven warming, more frequent marine heatwaves and more energetic storms are already destabilising temperate kelp systems (Oliver et al. 2018; Wernberg et al. 2016). Large longline farms are materially and energetically intensive, do not help natural kelp forests but rather introduce persistent marine infrastructure, and create ecological risks — entanglement, marine debris, pest spread and transient habitat effects — that are amplified under a changing climate (Thomas et al. 2021; Forbes et al. 2022). Analysed against Nadgee’s PoM obligations to protect threatened fauna, dune and estuary integrity, and wilderness character, Eden 1 fails. For the public interest and the Reserve’s integrity, the lease AL21/004 must be cancelled due to:
1. Climate hazards undermine kelp resilience
Sustained warming and acute marine heatwaves are driving widespread kelp declines by impairing photosynthesis and recruitment and enabling range expanding grazers that create urchin barrens (Oliver et al. 2018; Vergés et al. 2016). Industrial plantations constructed in remote and separate contexts cannot replicate decades of ecological function lost from intact wild kelp forests (Krumhansl et al. 2016; Forbes et al. 2022). Instead, they introduce new pressures to untouched sites and disrupt valuable natural systems.
2. Intensifying storms raise gear loss and entanglement risks
Climate change increases the frequency and intensity of extreme weather events. This heightens the probability of mooring failures and mass gear loss from exposed farms producing long lasting debris and entanglement hazards for whales, dolphins, seals and seabirds, disproportionately impacting ecological systems where biodiversity is susceptible to introduced stress (Benjamins et al. 2014; Grebe et al. 2019).
3. Life cycle burdens can outweigh local benefits
Robust life cycle assessments show that material production (ropes, chains, anchors), vessel fuel, and processing energy (freezing, heated drying) often dominate environmental impacts of seaweed supply chains. Without independently verified Life Cycle Assessment, excessively large farms like the proposed Eden-1 which boasts exorbitant journeys (from Eden) by 1-3 vessels per day (more during construction) may increase net greenhouse emissions and abiotic depletion (Thomas et al. 2021; Visch et al. 2020; Duarte et al. 2017).
4. Novel communities, pests and ecological traps
Cultivated kelp arrays typically support fouling dominated, transient assemblages distinct from natural forests; harvest cycles remove habitat, producing ecological traps and enabling pest or pathogen stepping stones (Forbes et al. 2022; Stentiford et al. 2017; Campbell et al. 2019).
Below is an analysis of the EIS’s claims as measured against the PoM’s management priorities and an identification of ‘gaps’ in the EIS’s mitigation strategies.
1. Entanglement of marine fauna (whales, dolphins, seals, turtles)
• EIS: “low” risk via tensioned lines, no nets, observers (EIS 9.4.4).
• PoM: mandates protection of threatened fauna and avoidance of human caused injury (objectives 3.1–3.3; policies 4.1.3).
• Gap: PoM expects binding, funded rapid response capability and seasonal no work buffers. A single entanglement adjacent to the reserve would breach the Plan’s precautionary duty. Auskelp admitted concerns over marine entanglement at their Wonboyn Information Session (22.10.2025) thus AusKelp is risking exposing dangers to the renown mammal populations of the region.
2. Vessel strike & acoustic disturbance
• EIS: limited daily trips, daylight operation, speed protocols.
• PoM: protects wilderness and minimises disturbance to migrating whales and solitude (3.2–3.4).
• Gap: PoM requires stricter seasonal exclusions, enforceable conservative vessel speeds and tighter acoustic thresholds than the EIS proposes. Strict seasonal exclusions would inhibit Auskelp’s necessary daily operations thus rendering Eden-1’s siting and location dangerously impractical.
3. Marine debris, gear loss and ingestion risk
• EIS: monitoring, strong anchors, bond, waste plan.
• PoM: dunes, beaches and estuaries are highly sensitive (4.1.1–4.1.2); demands pollution prevention and rapid removal.
• Gap: PoM requires guaranteed, time bound retrieval with funded contingencies and explicit microplastic mitigation for long term rope wear. Auskelp’s claim that microplastic release is only minor within global concentrations is a distraction from the fact that Eden-1 will impact the local environment.
4. Beach cast kelp, wrack and shorebird/dune impacts
• EIS: expects minimal extra wrack; will log deposits.
• PoM: prioritises dune and shorebird protection; requires active management.
• Gap: EIS must define thresholds, funded clean up protocols and community notification procedures tied to access restrictions. Detailed long-term marine ecological surveys of adjacent rocky shores have not been provided yet these shorelines are in direct pathway of farm debris and changed ecological conditions that Eden-1 will precipitate.
5. Visual intrusion and wilderness character
• EIS: infrastructure >1.1 km offshore, low profile.
• PoM: Nadgee is NSW’s only declared coastal wilderness; preservation of naturalness and solitude is central (3.2–3.4).
• Gap: PoM demands minimisation beyond standard maritime practices; visual assessments from key reserve vantage points are absent from the EIS. Auskelp has disregarded tourist and recreational benefits that Disaster Bay provides to the local community and visitors from afar – the impacts are immeasurable.
6. Biosecurity, disease and genetic integrity
• EIS: local sorus sourcing, hatchery protocols.
• PoM: forbids introductions; prioritises protection of rare taxa (4.1.2–4.1.3).
• Gap: PoM requires independent third party biosecurity audits, strict limits on any reserve landings and absolute prohibition on routine reserve track use. Given Eden-1 is accessible only by boat from Eden this disables Auskelp’s ability to abide under all circumstances or conditions.
7. Benthic shading, habitat modification and coastal processes
• EIS: deep site with >10 m clearance; Type 3 soft sediment.
• PoM: protects estuaries and dune stability (4.1.1).
• Gap: PoM requires independent NPWS coastal geomorphology review, conservative buffers and contingency triggers; EIS lacks long term geomorphological analysis for adequate risk assessment. The risk is not ‘low’ especially given Eden-1’s unprecedented scale and untested infrastructure.
9. Access and emergency reserve track use
• EIS: reserve access “only in extreme inspection circumstances.”
• PoM: restricts vehicle access to preserve wilderness (4.3.3).
• Gap: PoM requires absolute, legally binding prohibition on routine or contingency vehicle use of reserve tracks. There must be no exceptions for drone use or emergency – if this is impossible for Auskelp to abide by, then it is self-evident that the farm is being proposed for the wrong place and instead should be developed in Twofold Bay where a kelp lease and aquaculture are already established. The EIS does not present laboratory-style experiment that isolates single causal effect for why Twofold Bay cannot succeed.
10. Cumulative, climate and uncertainty obligations
• EIS: monitoring and acknowledgement of climate variability.
• PoM: demands long term funded monitoring and adaptive triggers (3.4; 4.3.2).
• Gap: EIS offers no NPWS approved, funded monitoring program with defined adaptive thresholds for species and geomorphic indicators. There is inadequate site-specific data (the EIS uses off-shore wave data) concerning natural processes affecting seasonal sand erosion and deposition yet Eden-1’s infrastructure when only half-full – in excess of 550km of synthetic rope, 2,200 screw anchors, and 12,200 black floats suspending lines of 40 x 8-10 metre-long dropper lines of kelp – can alter geomorphological & marine processes. Auskelp know wave attenuation is a factor: late in 2025 their lease was moved seaward an extra 500 metres offshore and the EIS states that aligning rope lines ‘east-west’ as mitigation attempt. Wave and current directions shift seasonally (even daily), yet the kelp lines are fixed. Impacts of kelp farm infrastructure combined with currents and wave action are the subject of a Blue Economy CRC investigation presently underway by Ryan Lowe of UWA, see: https://blueeconomycrc.com.au/project/hydrodynamic-energy-attenuation-by-seaweed-aquaculture/ These uncertainties of wave attenuation due to Eden-1 present unacceptable risks in destabilising Nadgee’s & Disaster Bay’s ecosystems, beaches and estuaries.
Given escalating climate hazards, ecological/geomorphological uncertainty, material and energy lifecycle burdens, and Nadgee’s protective standards, Disaster Bay is inappropriate for Eden 1. The sole defensible environmental and public interest action is immediate revocation of AL21/004 lease and the permanent prohibition of industrial aquaculture in Disaster Bay — redirecting public funds to evidence based wild kelp restoration, dune protection and NPWS led monitoring. I urge independent assessors to undertake a site inspection of Disaster Bay, Greenglades and Merrica River as part of their deliberations in order to fully appreciate the gravity of these issues.
Select bibliography (selected)

Benjamins et al (2014); Bird, (1984); Campbell et al (2019); Duarte et al (2017); Forbes et al (2022); Grebe et al (2019); IPCC (2021); Krumhansl et al (2016); Laist et al (2001); NPWS (2003); Oliver et al (2018); Seghetta et al (2016); Stentiford et al (2017); Theuerkauf et al (2021); Thomas et al (2021); Visch et al (2020); Wernberg et al (2013); Woods et al (2017).

1st this box should autosave contents before timing me out . Or at least advise of the time out. it isn't a bank for gods sake.
second my objections are based on the performance of other industrialised farming and extraction activities that privilege profit over other life phenomena. Also the stated lack of precedent and research to address issues of scaling up and sustainable maintenance of a system within an ecosystem already threatened by climate change; the evidence of which is named as contributing to a global reduction of kelp supply. What makes this proposal profitable?
All the words are there in this description of the proposed farm. Business plan, supply need, risk assessment and management. All written by the proponent or associates. The regulatory requirements are named. However as with salmon industry and forestry, the regulatory bodies are not standing up to the corporations proactively, and fall behind irreparable damage when responding to breaches - either climate or human systems induced. This proposal has not shown convincingly that the priority is ecosystem safety over profit. The relationship of this industry to the EPBC Act is not articulated in the context of its proximity to a world biosphere reserve and the ripples of healthy ecosystem around it. The mechanical interventions to minimise impact on wildlife do not account for the effects of the presence of the introduced food system (kelp habitat) on neighbouring life communities. If there is increased species presence as happens with artificial reefs designed to attract species, what is the impact of mitigating this on profit margins and protective decision making.
I am aware this is not a scientific response, but an individual organic response to the proposed disruption. It is the ineffable and priceless parts of our brief individual and ongoing collective existence that are being disrupted for poorly articulated benefit to any other life system. It is flimsily justified referring the global need for food. It is not articulating the costs at all and claiming to eliminate risks. I believe more evidence of its sustainability financially and environmentally is needed to assess the disturbance it could create before creating it. Not during and definitely not after. Again I refer to the so called regulated salmon industry harms to surrounding species and the reckless cruelty of the forestry industry’s impact on endangered habitat occupants and water tables.
I object to this proposal as described in the application.

Sheridan Hunt
18 Adelaide Ave
Wonboyn Lake 2551 NSW

To Whom It May Concern,
I am writing to object to the proposed Auskelp seaweed aquaculture project in Disaster Bay.
My daughter and son were both born in Wonboyn, We have a family home in Wonboyn for more than 40 years our family has a deep and long-standing connection to this area. Greenglades, Disaster Bay, and the surrounding coastline are not just places to us — they are part of our family history, memories, and way of life.
Greenglades and Disaster Bay are among the last truly untouched and pristine coastal environments in New South Wales. The natural beauty, clean beaches, untouched waters, and sense of isolation are what make this area so special to both locals and visitors. The proposal to industrialise part of this coastline with offshore infrastructure, marker buoys, ropes, and farming equipment is deeply concerning. 200 hectare is so big and I find it very offensive.
While the project information states the infrastructure may be “hard to see,” the reality is that this development would permanently change the character of this unique landscape. Once industrial infrastructure is introduced into a wilderness coastline, that natural feeling cannot be restored.
I am also concerned about the broader environmental impacts and the unknown long-term effects on marine life, whales, local ecosystems, fishing, tourism, and the overall health of Disaster Bay. This coastline borders significant natural areas including Nadgee Nature Reserve and Beowa National Park, which should be protected for future generations.
Another concern is the level of community consultation. This is a small, close-knit community, and many residents feel they were not properly informed or genuinely consulted before the project progressed to this stage. A project of this scale in such a sensitive environment deserves extensive and transparent engagement with the local community. I am aware that we did have a community meeting although this was after the project was underway
Disaster Bay and Greenglades are special because they remain largely untouched. Not every natural place should become a commercial venture. Once developments like this begin, it opens the door for further industrialisation of an area that many people value specifically for its wild and unspoiled nature.
I respectfully ask that the NSW Government carefully consider the long-term environmental, social, and visual impacts of this proposal and prioritise the protection of this unique coastline.
Regards Sheridan Hunt

To Whom It May Concern,

I write to formally object to the proposed intensive kelp farming development at Disaster Bay.

My objection is based on both personal historical connections to the area and broader environmental concerns regarding the introduction of this new and insufficiently researched industry into a highly sensitive coastal ecosystem.

My family were among the early settlers and the major landholders in during the late nineteenth century building Wonboyn House in 1890. Unlike many landowners of that era, my ancestors chose not to extensively clear or exploit the surrounding land for intensive agriculture. Their stewardship reflected a long-term respect for the natural environment and contributed to the preservation of the unique ecological character of the area that exists today.

The proposed kelp farm is to be situated only metres offshore from where 640 acres was compulsorily acquired from my family under the National Park and Wild Life Act 1974 for the Nadgee Reserve. This history adds a deeply personal dimension to my objection. Land and waters that were once carefully protected and managed by local families are now at risk of industrialisation without adequate understanding of the long-term consequences.

I am also concerned about the environmental impacts associated with intensive kelp aquaculture in a relatively enclosed and ecologically sensitive waterway such as Wonboyn Lake. In particular, I believe there is insufficient independent scientific research regarding:

Potential impacts on native marine ecosystems and biodiversity;

Changes to water quality, nutrient cycling, and hydrodynamics;

Effects on seagrass beds, fish habitats, birdlife, and other existing ecological communities;

Risks associated with disease, invasive species, or ecological imbalance;

Visual and amenity impacts on the natural coastal landscape;

Long-term cumulative impacts of establishing a new industrial marine activity in the region.

Wonboyn Lake is valued for its relatively untouched natural condition, scenic beauty, recreational use, and environmental significance. Developments of this nature should be approached with extreme caution and only proceed where there is clear, comprehensive, and independently verified scientific evidence demonstrating that there will be no significant environmental harm.

At present, I do not believe that sufficient long-term research or environmental assessment has been undertaken to justify approval of an intensive kelp farming operation in this location.

I respectfully request that the proposal be refused, or at minimum deferred until far more rigorous environmental studies, community consultation, and independent scientific review have been completed.

Thank you for considering this submission.

Yours faithfully,

Marcus Letcher

I wish to formally object to the proposed Kelp farm at Wonboyn Beach Disaster.Bay
I have been visiting Wonboyn for over 40 years having married into the Gleeson family of the former major landowners and who built Wonboyn House. We have often commented that the absence of intensive farming and commercial clearing has kept the whole environment pristine making the area culturally significant with Nadgee being the only untouched coastal wilderness in NSW.
I am concerned that the proposed industrial-scale kelp farming may cause permanent environmental damage. From my research, this industry is new and lacks sufficient studies to guarantee safety.
My objections are as follows:
1. Ecological Sensitivity of the Site Wonboyn stands out for its largely undisturbed ecosystem, which relies on delicate, self-regulating relationships. Intensive aquaculture could disrupt unseen and potentially irrecoverable ecological patterns.
2. Risks Associated with Monoculture Systems
Kelp farms create uniformity in diverse environments, and their dense structures can change light, current, and nutrient patterns, affecting seagrass, sediment, and marine life. These changes are interconnected and may alter long-standing ecological relationships.
3. Physical Infrastructure and Wildlife Impacts The proposed many hundreds of kms of ropes, anchors, and buoys create a persistent artificial layer in the water. This presence poses entanglement risks for marine mammals, turtles, and birds, and can disrupt movement, feeding, and habitat use. Over time, such interference may alter wildlife patterns in subtle but lasting ways.
4. Microplastic Pollution and Material Degradation Synthetic materials like nylon degrade in marine environments, releasing fibres and breaking down into persistent microplastics. This accumulation threatens water clarity and ecological health.
5. Biosecurity While the plan involves using native species, intensive farming can disrupt balanced environments and pose unforeseen threats to local habitats. Regular planting and harvesting increase boat traffic, which could unintentionally introduce diseases and impact intact ecosystems.
6. Visual and Experiential Impact Wonboyn is appreciated not just for what exists, but also for what is absent—such as industrial buildings, noise, and visual distractions. Introducing a kelp farm changes how people experience this area. The addition of lines, buoys, and maintenance activities brings a new pace and feel, altering the space from mostly untouched nature to more managed and industrialised surroundings. This affects visitors who seek peace, contemplation, and a connection with an unspoiled landscape.
7. Navigation and Public Access The development may limit movement in the waterway, create hazards for smaller boats and recreational users, and reduce access to areas currently open to the public.
8. Precedent and Cumulative Impacts Approving this proposal sets a precedent that could encourage further developments, gradually changing the area’s character. The assessment of a single project may not reflect the cumulative impact of multiple installations.
9. Lack of Comprehensive Baseline Data There is currently a lack of extensive long-term data necessary to thoroughly comprehend the present dynamics of this environment. In the absence of such data, evaluating the resilience of the system or predicting its response to prolonged intervention remains challenging.
10. Climate and Operational Risks Greater climate variability increases the risk of storm damage and infrastructure failure, with debris potentially spreading offsite and worsening environmental effects.
Conclusion
While kelp farming may have a role in appropriate locations, this proposal does not adequately account for the specific qualities of Disaster Bay and Nadgee Wilderness. This is a place where ecological integrity and lived experience are closely intertwined. Introducing an industrial aquaculture system risk diminishing both.
For these reasons, I respectfully request that the proposal be refused, and that priority be given to preserving the long-term integrity of this unique coastal environment.
Sincerely,
Libby Letcher

We have been coming to Wonboyn for the last 50 years and we chose this area as it was one of the last pristine areas on the South Coast of NSW and wish it to remain so for our children and grandchildren. My husband and family enjoy boating and fishing in Disaster Bay and are concerned that the structure for the kelp farm may inhibit them fishing in their favourite fishing locations. In other words we don’t won’t it in our backyard. Also later on this project could expand to a much greater area.

I wish to formally object to the proposed kelp farm development at Nadgee.

I have been visiting this area for over 20 years, and what makes it so special is how untouched and peaceful it still feels. Places like this are becoming increasingly rare. Nadgee has always felt wild, quiet and protected from the kind of large-scale commercial development that has changed so many other coastal areas. That is why this proposal feels so deeply wrong for this location.

My biggest concern is the sheer scale of what is being proposed. A small 50m x 50m trial site is completely different to a 200-hectare industrial marine farm. I do not believe the data gathered from such a small test area can simply be applied to a project of this size with confidence. The proposal feels far too large for such a sensitive and pristine environment, and there are too many unknowns about the long-term impacts.

I am also extremely concerned about the visual impact. One of the most powerful things about Nadgee is the feeling of open, uninterrupted coastline and ocean. The idea of large stretches of ropes, buoys, floats and ongoing marine infrastructure sitting in this landscape completely changes the character of the area. It would no longer feel untouched or tranquil. Instead, it introduces an industrial presence into a place valued for its natural beauty and sense of sanctuary.

The potential impacts on marine life are another major concern. This coastline is home to whales, dolphins, seals, penguins and seabirds, and I worry about the risk of entanglement from ropes and infrastructure spread across such a large area. Even if the risk is considered “low,” the consequences for wildlife could still be devastating. It feels irresponsible to introduce this kind of hazard into an area known for its rich marine life.

I am also worried about pollution, particularly microplastics from ropes, buoys and other synthetic materials breaking down over time in harsh ocean conditions. This is supposed to be one of the cleanest and most pristine coastal environments in the country, yet this development introduces the possibility of long-term plastic contamination entering the water and marine food chain.

The proposal would also bring increased light and noise pollution into an area currently defined by its quietness and natural darkness. Navigation lights, service vessels and harvesting operations would inevitably change the atmosphere of the coastline, especially at night. Underwater noise from boats, machinery and infrastructure movement is also known to impact marine life, particularly species that rely on sound for communication and navigation.

Another concern is the impact on the ocean floor and coastal systems. The seabed in this region is relatively undisturbed, and I do not believe enough is understood about how a development of this scale could affect fragile marine ecosystems. I am also worried about how a 1km by 2km network of ropes and floats may alter wave movement, currents and sediment flow over time. Nadgee’s beaches, rocky shorelines and estuaries are shaped by natural processes that have existed for generations, and once those systems are disrupted, the damage can be extremely difficult to reverse.

I also believe this development risks damaging the reputation of the region as a pristine ecotourism destination. People visit Nadgee because it feels remote, natural and untouched. That sense of wilderness is part of its identity. Introducing large-scale marine infrastructure into this environment changes how people experience the area and undermines what makes it so unique.

Perhaps most concerning of all is the precedent this sets. Approving a commercial marine development of this scale in such a pristine coastal environment opens the door for further industrialisation and commercial use in the future. Once development like this is allowed, it becomes much harder to protect these environments from ongoing expansion and additional proposals.

I strongly believe this proposal is in the wrong location and far too large for such an environmentally sensitive and treasured area. Nadgee’s value lies in the fact that it has remained largely untouched. Once that is lost, it cannot simply be restored.

To add to my subsequent submission the location of the proposed kelp farm is in the worst section of the bay. Where most people use the bay for the untouched environment it is. I would also like to comment on the process that has been brought to Wonboyn by nsw planning and the opinion that this process is not a fair process and the decision has been made that the kelp farm will go ahead regardless of the town’s people opinion. Otherwise why would the government award grants to this project prior to this body’s announcement?

I object to the proposed 200‑hectare kelp aquaculture development at Disaster Bay on the grounds that the location is inappropriate, inadequately justified, and inconsistent with NSW planning principles for development in environmentally sensitive areas.

1. Failure to demonstrate adequate site selection or alternatives (SEARs: Project Justification & Alternatives)

The proponent’s Scoping Report includes an “Analysis of Alternatives”, yet it does not identify or assess any alternative locations beyond the chosen Disaster Bay site. Instead, the document focuses on justifying the existing lease area. planningport...

For a State Significant Development in a highly sensitive marine environment, NSW Planning requires a robust alternatives assessment, including:
• consideration of less sensitive coastal locations
• evaluation of environmental constraints
• justification that impacts cannot be avoided
This requirement has not been met. The absence of a genuine alternatives analysis is a fundamental flaw in the proposal.

2. Incompatibility with the Nadgee Wilderness Area (SEARs: Biodiversity, Marine Environment, Visual Impact)

The proposed site lies immediately offshore from the Nadgee Wilderness Area, the only declared coastal wilderness in NSW. This area is protected for its pristine condition, absence of development, and uninterrupted natural vistas.

A 200‑hectare industrial aquaculture installation would:
• introduce permanent visual structures into a wilderness seascape
• increase vessel traffic in an otherwise quiet marine zone
• undermine the statutory wilderness values protected under the NPW Act

These impacts arise solely because of the chosen location.
3. Risks to marine mammals, benthic habitat, and coastal integrity (SEARs: Biodiversity, Hydrodynamics, Waste & Hazards)

Bega Valley Shire Council has already identified key risks requiring assessment:
• whale entanglement from long‑line infrastructure
• marine pest colonisation due to creation of artificial habitat
• debris washing ashore on Wonboyn, Greenglades, and Nadgee beaches
These concerns are documented in Council’s response to the SEARs request. planningport...
The scale of infrastructure proposed is incompatible with the low‑impact, high‑conservation‑value nature of Disaster Bay.

4. Strategic context and cumulative impact (SEARs: Strategic Planning & Cumulative Impacts)
The proponent has not demonstrated how placing a large aquaculture facility adjacent to a wilderness coastline aligns with:
• NSW Marine Estate Management objectives
• conservation zoning
• the precautionary principle
• cumulative impact obligations for sensitive coastal environments

Given the pristine condition of the Nadgee coast, any industrial‑scale development represents a significant cumulative shift in character and ecological risk.

Conclusion
The proposal fails to satisfy NSW Planning’s requirements for alternatives analysis, environmental protection, visual impact, and strategic justification. The chosen location — immediately offshore from a declared wilderness area — is fundamentally unsuitable.

I request that the proposal not be approved in this location, and that the proponent be required to undertake a genuine assessment of alternative sites outside wilderness‑adjacent waters.

To whom it may concern,

I wish to object to the proposed Eden-1 offshore kelp farm development proposed for waters off Disaster Bay.

While I support sustainable industry in principle, I do not believe sufficient independent evidence has been provided to justify a 200-hectare industrial marine development in one of the most ecologically and visually significant coastal environments in NSW.

Disaster Bay and the surrounding Far South Coast are valued for their wild, undeveloped character, adjacent national parks, whale migration routes, sensitive marine ecosystems and internationally recognised coastal scenery. This proposal represents the industrialisation of open coastal waters directly adjoining these natural landscapes.

Although described as environmentally responsible, the proposal still involves extensive offshore infrastructure, servicing activity, vessels, monitoring operations, surface markers and ongoing visual presence visible from the coastline, including from Greenglades Beach.

There appears to be limited long-term Australian research into the cumulative impacts of large-scale offshore kelp farming, including:

* whale, dolphin and seal interactions,
* entanglement risks,
* seabird impacts,
* marine debris and infrastructure failure,
* storm damage in high-energy ocean conditions,
* impacts on reef ecology,
* biofouling and disease,
* and broader ecosystem changes associated with intensive kelp biomass production.

The proposal relies heavily on future monitoring and adaptive management after establishment rather than demonstrating long-term environmental certainty before approval. A precautionary approach should apply in an area of such high environmental value.

The Far South Coast economy already depends heavily on tourism, recreation, fishing and the region’s reputation for unspoiled natural beauty. The long-term visual and industrial impacts on this identity do not appear to have been adequately assessed.

I am also concerned about the precedent this proposal sets. Once industrial aquaculture infrastructure is approved in these waters, it becomes increasingly difficult to resist future expansion and further industrialisation of the NSW coastline.

Given offshore commercial kelp farming remains a new and largely untested industry in Australian waters, I do not believe the environmental risks, cumulative impacts and community concerns have yet been sufficiently understood to justify approval through the State Significant Development pathway.

For these reasons, I respectfully request that the proposal be refused unless substantially greater independent scientific assessment, long-term ecological research and broader community consultation are undertaken.

Yours faithfully,

I support the project

Submission on the Auskelp Eden 1 Kelp Aquaculture Farm
SSD-41680467 — Commercial viability and decommissioning risk
To: NSW Department of Planning, Housing and Infrastructure
Application: SSD-41680467 — Seaweed Aquaculture Lease, Disaster Bay – Eden 1
Proponent: Auskelp Pty Ltd

Introduction
I object to the proposed Auskelp Eden 1 Kelp Aquaculture Farm on grounds of commercial viability and decommissioning risk. NSW planning law requires the consent authority to consider whether a proposed development can be operated, maintained and ultimately decommissioned without unacceptable residual risk to the environment or to the public purse. On the materials before the Department, neither the proponent's commercial track record nor the proponent's draft Decommissioning Management Plan (B10) provides adequate assurance on these points.
1. The proposed scale is unprecedented for the proponent
The proponent's annual reports for FY23, FY24 and FY25 (documents C5, C6, C7) record a six-year research and development program since 2019, two-location ocean testing in Twofold Bay and Disaster Bay, hatchery and propagation work at the Co-Labs Melbourne facility, and successful direct seeding trials in high-energy waters. These reports demonstrate genuine technical capability. The proponent is not a hobbyist.
However, the reports also disclose what is not present. The proponent operates a 2-hectare test lease in Twofold Bay. The proposed Eden 1 lease is 200 hectares. This is a 100-fold scale increase in a single step. The annual reports contain no harvest tonnage data, no revenue figures, no operational cost data, no financial position reporting, and no commercial product on shelves, in market or under contract. For an annual report of a private company, the absence of any financial information across three consecutive years is unusual. The reports are R&D progress reports presented in annual report format.
The proponent describes the project in its own FY24 report as Australia's 'first registered commercial scale open-ocean seaweed farm in NSW marine waters.' By the proponent's own account this is therefore the first commercial-scale operation of its kind in NSW, by an operator with no commercial-scale operating history. The leap from a 2-hectare R&D footprint to a 200-hectare commercial operation is large. NSW planning policy generally treats unprecedented scale and unproven operational track record as relevant considerations in conditioning consent.
2. The Decommissioning Management Plan is inadequate
Document B10, the Decommissioning Management Plan, is dated 14 February 2026 and is marked DRAFT, version 1.0 (with version 1.1 also referenced inconsistently in the document properties). It is internally classified 'Commercial in Confidence — Internal Use Only' on its closing page, despite being submitted to a State Significant Development public exhibition. Either the classification is incorrect, or the document was prepared as an internal document and submitted without proper review.
The plan discloses several matters that warrant attention.
First, the plan acknowledges that screw anchors may be left in situ at the discretion of NSW DPI Fisheries, citing a Jervis Bay mussel farm precedent. The plan's own indicative figures suggest 22 screw anchors per hectare — approximately 4,400 anchors across the full 200-hectare lease. The plan presents in-situ retention as environmentally preferable to removal at small scale, but does not assess the cumulative ecological consequence of leaving thousands of buried steel screw anchors permanently in the seabed of an environmentally sensitive coastal waters area adjacent to a wilderness reserve.
Second, the plan refers to an Aquaculture Lease Security Arrangement (Bond) under the Fisheries Management Act 1994 as the financial assurance mechanism, but does not specify the bond amount, the methodology for setting it, or whether it has been calculated for this lease at all. The plan does not contain any quantitative cost estimate for decommissioning. There is no figure for total infrastructure removal, no estimate of vessel days required, no labour cost, and no waste disposal cost. The Schedule section indicates 3 vessel trips per hectare, 44 hours of anchor removal per hectare, and 2 days of waste transport per hectare. Extrapolated to 200 hectares this is approximately 600 vessel trips and 8,800 hours of anchor removal. No cost is attached to any of this in the plan.
Third, the plan relies on Scandinavian and European studies (Visch et al. 2020, Hancke et al. 2021, Carranza et al. 2024) to support claims of rapid ecosystem recovery following decommissioning. These studies are from much smaller-scale farms in different ecosystems. No site-specific recovery study has been commissioned for Disaster Bay.
Fourth, the plan is dated less than three months before the close of public exhibition. The proponent has had over three years since the BMT coastal processes report in October 2022 to prepare a substantive decommissioning plan. What is on exhibition is a draft.
3. The financial surety question
The combination of these two factors — a proponent with no reported commercial revenue across three consecutive annual reports, and a draft decommissioning plan with no quantified cost or specified bond amount — raises a financial surety question that the Department should answer before consent is granted.
If Auskelp Pty Ltd were to fail commercially after deploying 200 hectares of marine infrastructure, who pays for decommissioning? The plan refers to the FM Act bond, but the bond amount is not in the public exhibition materials. If the bond is set at a level appropriate to a 2-hectare test lease, it will be inadequate for a 200-hectare commercial operation. If the bond has not been quantified, it cannot be relied upon to cover the cost the plan does not estimate.
This is a real risk, not a theoretical one. The proponent's own documents describe a six-year R&D program with no reported commercial revenue. The proponent's commercial viability depends on successfully scaling from 2 hectares to 200 hectares as the first commercial-scale open-ocean kelp operation in NSW, against a background of contested international experience with offshore aquaculture permits in similar habitats (the Gulf of Maine kelp permitting freeze is one example). If commercial viability does not materialise, the financial residual risk falls on the State.
4. Request
For these reasons, I respectfully request that the Department:
1. Refuse the application as presented; or in the alternative,
2. Restrict any approval to a staged pilot of no more than 10 hectares for an initial 24 months, with expansion to any larger footprint contingent on the proponent demonstrating commercial-scale operating capacity and on independent ecological audit;
3. Require, as a condition of any consent, a quantified Decommissioning Management Plan including a costed estimate of full infrastructure removal, a corresponding financial bond or surety set at that quantified amount, and an annual review of the bond amount against actual deployed infrastructure;
4. Require the Decommissioning Management Plan to specify the maximum acceptable proportion of screw anchors that may be left in situ, with the default being full removal and any exception requiring case-by-case regulator approval and public reporting.

Eden Local Aboriginal Land Council (Eden LALC) formally expresses its strong opposition to the AusKelp proposal in its current form due to the ongoing lack of meaningful consultation, genuine engagement, transparency, and inclusion of the local Aboriginal community and Traditional Custodians throughout the development and progression of the project.

Eden LALC acknowledges that preliminary engagement activities and research discussions occurred in earlier years through initiatives associated with the University of Wollongong’s Blue Futures program and broader Blue Economy CRC research. These organisations and researchers have maintained stakeholder relationships with Eden LALC and, at various points, engaged with our community regarding broader concepts surrounding Aboriginal-led aquaculture, marine restoration, and regenerative Sea Country opportunities.

However, it is critical to clarify that these earlier interactions were baseline, exploratory, and time-limited research activities intended to gather broad regional input and examine emerging opportunities. They were not designed to substitute for genuine, ongoing consultation with Aboriginal communities, nor do they represent endorsement, partnership, consent, or continuing support for the AusKelp proposal by Eden LALC or the broader Yuin/Thaua Aboriginal community.

Eden LALC is increasingly concerned that historic engagement processes, stakeholder discussions, and research outcomes associated with the University of Wollongong and Blue Economy CRC initiatives continue to be referenced in support of the AusKelp project and broader industry narratives despite those engagements now being outdated and no longer reflective of current community priorities, expectations, concerns, or aspirations.

Importantly, the research itself identified that any future aquaculture development within the region must be co-designed alongside First Nations peoples and local communities in order to maintain trust, social licence, legitimacy, and long-term community support. Eden LALC does not believe this standard has been achieved through the current approach undertaken by AusKelp.

Meaningful consultation cannot rely on historic research discussions while projects continue to evolve independently of Traditional Custodian priorities, Aboriginal governance structures, and the cultural responsibilities attached to Sea Country. Consultation is not a one-off procedural exercise undertaken at the beginning of a project lifecycle. It is an ongoing relationship and governance obligation requiring transparency, accountability, collaboration, and active participation by Traditional Custodians throughout project planning, development, and delivery.

Despite AusKelp continuing to progress its project development, stakeholder relationships, commercial positioning, and broader business case, there has been no genuine incorporation of Aboriginal-led priorities, cultural governance structures, Traditional Custodian decision-making, or long-standing community aspirations into the direction of the proposal.

For many years, Eden LALC Elders and community members have advocated for Aboriginal-led restorative aquaculture and marine regeneration initiatives on Yuin/Thaua Sea Country. These priorities include:

• kelp and reef restoration;
• habitat and biodiversity recovery;
• culturally informed marine stewardship;
• protection and restoration of Sea Country values;
• Aboriginal-led environmental management;
• Aboriginal employment, training, and enterprise pathways;
• and long-term sustainable management led by Traditional Custodians.

These priorities are grounded in cultural responsibility, intergenerational stewardship, and protection of Country, and strongly align with broader environmental and regenerative objectives. However, Eden LALC has not seen these priorities meaningfully reflected within the AusKelp proposal, its governance structure, or its engagement approach.

Our concerns extend beyond the simple absence of consultation. Eden LALC considers that engagement with the Aboriginal community has lacked:

• transparency;
• continuity;
• accountability;
• co-design processes;
• Aboriginal governance involvement;
• meaningful relationship building;
• and demonstrated commitment to embedding local cultural and environmental priorities into project planning and delivery.

The lack of ongoing communication and meaningful engagement also raises serious concerns regarding future Aboriginal participation within the project itself. Eden LALC considers that where Aboriginal communities are excluded or marginalised during the planning and developmental stages of a project, it reflects a broader lack of commitment toward future Aboriginal workforce participation, local employment pathways, training opportunities, procurement inclusion, and long-term community benefit outcomes.

Meaningful Aboriginal participation begins at the earliest stages of project development through collaboration, relationship building, shared planning, and inclusion within governance and decision-making processes. The absence of this engagement provides little confidence that Aboriginal employment and participation outcomes will become a genuine priority as the project progresses.

Eden LALC remains supportive of regenerative aquaculture, marine restoration, and sustainable Blue Economy initiatives where they are genuinely developed in partnership with Aboriginal communities and where Sea Country priorities are embedded from the outset.

However, projects operating on Yuin/Thaua Sea Country must:

• genuinely involve Traditional Custodians in decision-making;
• recognise and respect Aboriginal cultural authority and governance;
• incorporate community priorities into project outcomes;
• respect long-standing cultural and environmental aspirations;
• provide genuine local Aboriginal employment, enterprise, and participation pathways;
• and demonstrate meaningful, ongoing engagement rather than relying on historic or one-off consultation activities.

As the AusKelp proposal currently does not reflect these principles, Eden LALC cannot support the project in its present form and strongly opposes the proposal progressing without genuine Aboriginal-led engagement, co-design, and meaningful inclusion of Traditional Custodians and local community priorities.

I am concerned on the basis of location. Disaster Bay is a pristine, non idustrialised area. It is home to many large aquatic mammal species including dolphins, sharks , seals and whales. It is part of their migration path and I don't believe that there has been adaquate studies down to say that their habitat won't be adversly affected by the proposed infrastructure. I also have concerns regarding the introduction of a monoculture in an area not known for its species. Historically whenever a species is introduced in mass numbers it lacks the genetic variations and fortitude to withstand disease. I don't think these concerns were addressed properly in the community consultation. The presenation only stated "this was not a concern" which was the response for the majority of the community questions. The location is also on the outflow of the Merrica River. During flood events there is a lot of debris the exits that system. Large trees, branches and driftwood all end up on Greenglade beach as a result from these floods. The concern for the infrastructure coming into shore at Greenglade and other beaches during East Coast Lows and Flood events (usually 2 or more per/ annum) hasn't been addressed as how it would be recovered and what they would do in the case of entaglement with wildlife. Also the lighting of the navigation buoys will be visible from Wonboyn, Green Cape and all associated beaches. With the projected number of lights (one for each corner of each quadrant) it will change the view, the landscape and overall aesthetics forever. There are so many more concerns I have regarding what we are proposing to do to the last declared wilderness coastline in NSW. Why here? Why not in Tasmania where the symbiotic nature of the industry can be combined with Salmon Farming to clean the water there? These industries never disappear after they are created. This will greatly affect tourism in the area, and the community who has moved as Far South as they can in NSW to get away from idustry. I believe the concept is sound- but its not worth sacrificing our wilderness coastline for. More study is needed, more location options need to be researched, more community consultation needs to be done. The impacts on tourism from the National Parks, Caravans Parks, whale watching industry and fishing all need to be weighed up against the benefits of Auskelp in this location. Please don't let this go ahead in Disaster Bay- We will never be able to reclaim our wilderness once it is industrialised. Our children need wild spaces for their future. Please reconsider the location.

To Whom it may concern
I am concerned about this project on the following because of the following 2 issues:
1. There seems to be a lack of consultation with the local Indigenous community.
&
2. On environmental grounds
1. Concerning lack of consultation with the local Indigenous Community.
After speaking to both the Chair, and also the CEO, of the Eden LALC, I am concerned that there has been little or no consultation with the local Indigenous community. It is totally unacceptable in 2026 that this consultation, and respect, has not been thoroughly afforded the Indigenous community. The fact that this consultation has been overlooked ,or avoided, is concerning as it indicates that due diligence has not been followed on this matter and raises the strong possibility that the project has not been thoroughly reviewed, nor adequate consultations made, on other matters. I am hence concerned that as this consultation has not been done then has the appropriate environmental study been undertaken ..... or has this also been lacking?
2. On Environmental grounds.
a. The impact of the Infrastructure - I have noted the imported infrastructure required for his project in terms of nylon ropes, moorings and floats. This infrastructure is extensive over a concentrated , yet nevertheless, significant portion of Disaster Bay. The impact of this infrastructure on marine life and flow cannot be overlooked. The impact on the marine floor is likewise compromised. No part of the natural environment is uninhabited space. Everything introduced has an impact which will invariably alter the ecosystem of that place. Any suggestion that there is nothing on the sea bed is a further indication of a disrespect for the environment. When one omission of impact, is added to other omissions of consultation, then concerns about the project must be taken seriously and proper consultation and research completed.
b. The proximity of the proposed farm with the Nadgee Nature Reserve. Over the last few years, I am in the habit of walking this pristine wilderness area. Of course, much of the reserve had suffered under pastoralists and logging prior to it being designated a reserve. Its recovery has been amazing but that recovery remains fragile due to the wider effects of Climate Change, seen especially with the prevalence of wild-fires, ocean warming and plastics washed up on the coastline. On one walk through the wilderness in December 2022 I sought to carry out as much of this man-made rubbish as I could (see attached Photo). Last year, as on previous years, I noticed that piles of rubbish are forming at several points. I am concerned that the Kelp project located so close to the Nadgee reserve 'cannot but' threaten and increase of this refuse. Of course, rubbish will result from the proposed Kelp Farm, there cannot be any guarantee to exclude this eventuality but the necessary inaccessibility of the Nadgee wilderness coast makes this reality a particular concern. Will the proposed managers of the Kelp farm commit to recovery of their waste products when they do wash up on the Nadgee coastline? (And what realistic proposal to recover this waste have they outlined, if any?) I have thus far concentrated on the plastics which will be involved in the project but the project is more than the set infrastructure. Has adequate modelling been done as to the impact from boating pollutants and noise pollution? As indicated above, when inadequacies exist in several areas then doubts build on the other assurances of the proposed Kelp farm.
I sincerely hope that the project will attract greater scrutiny by government officials so to ensure that this important national environment is protected.
Sincerely,
Michael palmer
0423 774 735
[email protected]

Disaster Bay, Nadgee Nature Reserve and Beowa National Park form a unique set of integrated coastal ecosystems, making Disaster Bay effectively a National Park/Marine Park. This objection to the proposed Eden-1 Kelp farm by AusKelp in Disaster Bay is based on an analysis of the EIS in terms of Disaster Bay’s (and Wonboyn’s) geomorphological processes which are essential to the link between the terrestrial integrity of formally protected lands and the proposed kelp farm. This analysis is based on the findings presented within a PhD Thesis prepared by Thomas S.N. Oliver titled Holocene depositional history of three coastal sand ridge plains, southeaster Australia, University of Wollongong (2016). In Oliver’s thesis he uses Wonboyn and Disaster Bay as a case study. This makes his investigation crucial to consider for its site specificity. However, the EIS does not cite or refer to Oliver’s 2016 thesis.

Below are concise, evidence‑based contradictions (EIS ⇒ claim; Wonboyn geomorphology ⇒ opposing evidence), with brief recommended actions.

1. The EIS states: “The kelp farm is hydrodynamically decoupled from surf‑zone/shoreline processes because it lies >1.1 km offshore and will not materially alter wave climate, currents or sediment transport” (EIS refs 4.7, 9.1.1).

Analysis based on findings by Oliver (2016): Wonboyn is a prograded barrier whose Holocene growth is explicitly controlled by offshore/alongshore sediment fluxes (Green Cape acts as a major northward sediment trap) and shows multi‑ka sensitivity to sediment supply and wave refraction (Oliver ref 4.2.1; ref 4.3.3; Figures 4.1–4.6). Even offshore changes that alter wave approach or local bedform dynamics can affect progradation and entrance behaviour. Conclusion: the blanket “decoupled” assertion is inconsistent with evidence that offshore processes strongly influence Wonboyn morphology.

2. The EIS states: “Longline anchors and moorings cause only local, negligible seabed disturbance; decommissioning will restore the site” (EIS refs 4.11, 9.2.5).

Analysis based on findings by Oliver (2016): The seabed at Wonboyn is mobile, with active beachface reflectors and migrating bedforms preserved in GPR and LiDAR (Oliver ref 4.4; Figures 4.8–4.12). Screw anchors and local scour can perturb sediment transport pathways in mobile sand environments; small, persistent changes in local scour/bedform can alter onshore sand supply and hence barrier/entrance stability. Conclusion: the EIS understates the potential for anchors to generate geomorphic change in this mobile‑sediment embayment.

3. The EIS states: “Shading, sedimentation and water‑quality impacts are negligible because rigs sit >20 m deep and infrastructure is low‑profile” (EIS refs 4.1, 9.4.1).

Analysis based on findings by Oliver (2016): Ridge and foredune growth at Wonboyn is driven by coupled nearshore wave‑beachface and aeolian processes; GPR shows diagnostic geometry changes at ~2.5 m AHD (swash ↔ aeolian transition) and LiDAR reveals foredune growth episodes and sensitive ridge accumulation (Oliver refs 4.4, 4.5, 4.7). Offshore alterations that change wave transformation or upwelling‑mediated nutrient flows can therefore influence nearshore sedimentation and ridge/foredune accretion. Conclusion: the EIS prediction of “no geomorphic effect” lacks demonstration that farm‑scale modifications cannot change nearshore process thresholds that control ridge/foredune evolution.

4. The EIS states: “Beach‑cast kelp from farms will be minimal/benign and may be beneficial” (EIS ref 4.9).

Analysis based on findings by Oliver (2016): Wonboyn / Wonboyn Lake is an intermittently‑closed lake (ICOLL) with a documented history of entrance closure and sensitivity to sand and wrack dynamics (ref 4.2.1; ref 4.2.2). Additional wrack delivered to a hydrodynamically marginal entrance can exacerbate closure and sedimentation problems. This problem could be extended to the intact estuarine system of Merrica River which is even closer to the lease and whose catchment is entirely contained with the Nadgee Nature Reserve making it one of the least disturbed in NSW. Conclusion: the EIS treatment of wrack as categorically benign contradicts the site history showing entrance sensitivity.

5. The EIS’s reliance on offshore buoy and broad hydrodynamic data rather than site‑scale morphodynamic modelling (EIS ref 7.6, Figures).

Analysis based on findings by Oliver (2016): GPR, OSL and LiDAR at Wonboyn reveal strongly site‑specific behaviour (distinct northern vs southern histories, recent foredune growth episodes: 70 yr vs ≈250–400 yr; refs 4.3–4.7). Conclusion: EIS lacks the nearshore, process‑level morphodynamic modelling that the depositional history demonstrates is necessary.

In summary, without site-scale wave transformation and sediment transport/morphodynamic modelling that could be linked to the proposed kelp lease configuration (anchors, long lines, etc) to nearshore gradients and Wonboyn’s estuary entrance dynamics, the proposed Eden-1 cannot be endorsed due to the risk it poses to the Nadgee Nature Reserve and Disaster Bay’s relatively pristine marine and terrestrial environments. AusKelp’s project and kelp lease as documented in the EIS must not go ahead, the lease needs to be cancelled, and an agreement set in place by the highest authorities that no aquacultural proposals for Disaster Bay be considered in the future.

I am writing to formally object to the proposed kelp farming development in our local marine area. While I understand that kelp farming is often promoted as a sustainable industry, I have several concerns regarding its potential environmental, social, and economic impacts on our community.

Firstly, I am concerned about the impact on the natural marine ecosystem. Large-scale kelp farms have the potential to alter water flow, reduce sunlight penetration, and disrupt existing habitats. These changes may negatively affect native species, including seagrass, fish populations, and other marine life that rely on stable and balanced conditions. There is also concern about the introduction or spread of non-native kelp species, which could outcompete local biodiversity.

Secondly, the proposed development may interfere with existing ocean users. Fishing, boating, and recreational activities are important to both locals and visitors. The installation of kelp farming infrastructure could restrict access to these areas, creating safety risks and limiting the use of shared marine spaces.

Additionally, there are concerns regarding visual and environmental impacts. Kelp farms require buoys, ropes, and other equipment that may affect the natural beauty of the coastline. If not properly maintained, this infrastructure also has the potential to contribute to marine debris, further harming the environment.

Finally, I believe there is still insufficient long-term research into the cumulative impacts of kelp farming in this specific area. Decisions of this scale should be made with a precautionary approach, ensuring that the environmental integrity and community values of the region are protected.

For these reasons, I respectfully oppose the proposed kelp farming development and urge decision-makers to carefully consider the potential risks and long-term consequences before proceeding.