Seaweed Aquaculture Lease, Disaster Bay - Eden 1

It is a pristine environment and we don’t want a factory in our bay.

I have visited Disaster Bay for over 40 years staying at our Wonboyn family house. Disaster Bay is widely regarded as the most pristine marine environment in the region and abuts the Nadgee Nature Reserve, the only coastal wilderness in NSW. It is the wrong location for a large commercial enterprise. My deep concerns include inadequate Indigenous consultation; animal and bird entanglement; undersea noise; changes to the benthic environment; micro-plastics; visual and noise disruption; effects on wilderness; negative impacts on eco-tourism. 1 Inadequate Indigenous consultation: Ongoing consultation with Traditional Owners is claimed throughout the EIS. In A5 ASCHA final it’s stated that 19 RAP groups were invited to an on-site meeting to discuss the cultural significance of the area and proposed works. However, none of the RAP groups were able to attend. In 2023 RAP groups given information packs and 28 days to respond. Feedback was received from only one person, Wendy Morgan of Guntawang Aboriginal Resources, a woman’s group based in Sydney. This does not constitute a valid Aboriginal consultation. The next step to formal contact is relationship building and face to face contact, as recommended in guides for working with Indigenous Australians. Some Indigenous people may regard formal approaches with suspicion due to the history of the stolen generation, or may lack confidence in reading and writing. They may be busy with community matters. Approaching organisations personally, if there’s no or little response from formal approaches, is recommended practice. Also the relevant Elders for the Greenglades site were not contacted. Their names do not appear on the list of Aboriginal people in the report. The views and insights of Traditional Owners should have been included in the EIS. The Independent Planning Commission should review the consultation. 2 Animal entanglement: During the whale migration season I have watched whales in Disaster Bay from the hill behind Wonboyn village. AusKelp’s risk assessment template states the location must avoid known whale migration routes Table 5; Eden1 Ann. Rep. FY24. Whales are common in the bay. The EIS admits it may be part of a whale resting place, p 211. The NPWS website informs that whales can be observed in the bay during the migration season from the Disaster Bay lookout. Scientific studies find that whales are known to play with kelp as a social activity and use it as a skin balm. Killer whales, Humpbacks and Southern Right whales are among the species observed doing this, and the latter two are common in the area. Cases of whale entanglement in kelp have been recorded by NOAA in the USA. Its report states the mariculture of seaweeds is on the rise which could put whales in increased proximity to infrastructure. The kelp farm could potentially attract whales and put them at risk. Whale watching, a growing Eden industry, should not be risked. The EIS states there’s been no known cases of whale entanglement within a kelp farm. But lack of evidence of whale entanglement does not equate to the absence of risk. Whale expert Dr Michael Moore of the WHOI research org. says ‘Whenever there’s a rope in the water column, there’s an entanglement risk.’ Dolphins, seals and other marine animals, including endangered animals and birds frequent the bay. Fairy Penguins are seen. The EIS says dolphins are irregular visitors, yet dolphins frequently ride the surf at Greenglades. AusKelp admits that seabirds are potentially vulnerable to accidental collision with longline infrastructure when diving for schooling fish and may ingest marine debris. There’s no evidence AusKelp’s mitigation measures will prevent entanglements. The size of the proposal, at 200 ha, is unprecedented in Australia and apart from China, in the rest of the world, eg a 40 ha limit in Maine, a 10 ha limit in Norway in clean waters. AusKelp’s longlines and infrastructure are untested (the small test site does not equate to infrastructure of this scale) yet the proposed site is within an environmentally sensitive area.
3 Undersea noise: Baleen whale communication can cross hundreds of km. UniMelb research found that human made noise is affecting whale behaviour and migration, reducing whales’ ability to hear acoustic communication, generating an avoidance response and lowering the detection of environmental cues that some whales use to inform navigation. Noise pollution increases whales’ stress levels, which has been linked to strandings. Given the close proximity of the whale migration route, there is a significant risk that noise pollution during AusKelp’s activities, via motors and tools, will affect whale behaviours.
4 Changes to the undersea environment: Aus Kelp’s community consultation in Wonboyn described the ocean floor of the farm site as ocean desert, as though it’s a denuded, lifeless area. I believe the term was misleading to the audience. Also, on p22 of the EIS, the site is described as unvegetated sandy substrate with no biological assemblages. AusKelp’s benthic snapshot, a single survey during winter, revealed communities of organisms (74 fauna and two algae) inhabiting the unpolluted waters and sea floor of the site. These communities included fish, sharks, rays, squid, shellfish, crustaceans, algae, seastars and worms. A Big Bellied seahorse (protected species) was present. AusKelp’s Benthic assessment admits that a valid assessment of infauna composition would be based on multiple replica samples collected from various sites over summer as well as winter seasons to capture natural variation. ‘Benthic infauna communities can be extremely variable over different sites and during different seasons’ p 44. The site’s natural communities play a vital ecological role. Infrastructure, shading, anchors and a seaweed not normally occurring will alter the kind of nutrient cycling normally present. A novel habitat will be created, disrupting the current ecological balance. The AusKelp benthic assessment points out that an increase in prey items may occur during routine maintenance, when lines of fouling organisms such as mussel shells are cleaned. The resulting shell-fall to the sea-bed could provide ‘prey items’ for seastars and predators such as Port Jackson sharks p. 35 Benthic assessment. It is scientifically evidenced that kelp farms typically support habitats and distinct communities which are not equivalent to natural kelp forests. https://doi.org/10.1007/s10811-022-02822-y
5 micro-plastics: AusKelp admits its use of synthetic rope will introduce microplastics into the sea, and therefore into the food chain. This is waved away in the EIS, stating that other aquaculture industries such as oyster farms use plastics. If the kelp farm goes ahead, microplastics will be introduced into an unpolluted marine environment. The bay’s strong wave action will increase rope abrasion. The current use of plastics in aquaculture is not a license for use. 6 Visual change, noise: Up to six daily return boat trips during the construction phase, and up to three return trips daily thereafter for inspections, harvesting and other activities, weather permitting, will occur. Few boats currently navigate the very rough bay. Drones will be used for inspections and to check for animal entanglements if seas are too rough. However, the Nadgee is an exclusion area for drones. The NPWS website says that flying drones in parks can impact visitors and disturb native animals. Formal approval has to be applied for. Strict guidelines apply. Sea and Wedgetail eagles are a common sight at Greenglades. Raptors have been injured by drones, and white-bellied Sea eagles are stressed by drones, and highly sensitive to disturbance during the breeding season. In a UNSW study aggressive behaviour was observed. In one instance a raptor attacked and took down a fixed-wing drone. The presence of drones, boating activities, increased human presence and the visual disruption of the seascape will alter the nature of this wilderness place, making it less desirable for visitors who wish to enjoy the peace of an untouched environment. Dark Sky places are increasingly rare around the world. Greenglades at night, with the moon-glow on waves and vast starscape, is majestic. The kelp farm with its lights and buoys will degrade the nocturnal ambiance, depriving people and children of a unique experience. 7 Encroach on and affect wilderness areas: The sea and coast are part of the same environment and interact. Indigenous people of the Nadgee call themselves saltwater people, A5 ASCHA Final, yet the EIS discusses land and sea as separate entities. The kelp farm location is close to the Merrica river mouth in the Nadgee. The river could be affected by in-washing seaweed, erosion, and changes in wave patterns. Several creeks adjacent to the kelp farm site are frequented by wildlife and birds, including the endangered Hooded Plover. Both creeks experience intermittent tidal interaction. I have seen baby eels washed in, climbing the rocky bed of the creek at Greenglades cliff. On p 30 of the EIS these creeks are referred to as ephemeral and dry, apart from during heavy rain. Neither creek runs dry except in extreme drought. Aquatic life is plentiful at Snake creek. The long-term impacts of the farm on the shoreline, estuarine creeks and on pristine Nadgee beaches are unknown. 8 Negatively affect eco-tourism: The EIS down plays the area, describing it as remote, difficult to access. Disaster Bay is the most accessible part of the Nadgee (NPWS). Greenglades beach road is accessible via normal car. Wonboyn village’s small population swells during holidays and weekends. Wonboyn is only a 28 minute drive from Eden. Disaster Bay is enjoyed by those who wish to experience a wild, pristine environment untouched by industry. The construction of a large commercial kelp farm puts the environmental value of this unique place at risk.

Protect our beach! Wonboyn is not an industrial marine zone. It is a quiet, environmentally significant community where people come specifically to enjoy nature, wildlife, and the unspoiled landscape.
Once developments of this nature are introduced into sensitive coastal areas, the character of the region can be permanently altered.
I strongly believe that alternative locations better suited to commercial marine farming should be considered, particularly areas that are already industrialised or less environmentally and visually sensitive.
Wonboyn is a unique coastal community that relies heavily on its natural beauty, healthy waterways, and peaceful lifestyle. Many residents chose to live here because of its unspoiled environment. Developments of this scale risk permanently changing the identity and ecological balance of the area.

One of our major concerns is the proposed use of lighting at night associated with the kelp farm operations. Our property looks directly over the proposed site, and we strongly object to the introduction of flashing or industrial style lighting across what is currently a peaceful and natural ocean environment. Wonboyn is valued for its dark skies, quiet atmosphere, and untouched beauty, and this proposal would significantly alter the character of the area.

Three generations of our family and have been coming to Wonboyn to enjoy the pristine environment. We have owned a property in Wonboyn for over twenty five years. We don’t want to see this unspoilt area relatively untouched by man exploited by this huge kelp farm. This pristine environment should be left alone. At night it will be an eyesore with all the lights flashing at sea. Who knows what the environmental impact will be with storms. We have concerns with this wealthy mans folly as he has a history of setting up businesses and moving them on making huge profits. Who knows down the track what will happen to this farm if it goes ahead. Will he be personally responsible for any environmental damage to our pristine area.

I have been coming to Wonboyn Lake with my family for fifty odd years. The reason we come here and love it so much is that the land and the sea are pristine relatively untouched by man. We don’t want to see the area spoilt by this huge kelp farm proposal that will impact this beautiful place. The area will be impacted by this proposal and should be left as it is for many more generations to enjoy .

This project is inappropriate over a lot of categories. The 1st category is navigation hazard the lease as proposed crosses directly in front of Merrica river entrance this is a waterway travelled by power boat visited frequently by locals and holiday makers in the area. To travel and navigate around the proposed lease as it has been set-out would make the trip much harder far more dangerous and for night navigation impossible.
The area over the proposed lease is a fishing ground for local recreational fishermen and offers protection though winter from a southerly wind. To think it does no get used by the community is completely wrong, locals and tourists use this area and the pristine environment that it is, The value as a pristine area should not be understated . Even though this farm is passive industrial, it is still industrialisation of a area that is not industrialised, the back drop of a major recovering National Park frequented with dolphins, whales sharks, sea birds it would be shameful to change this.

I am visiting Disaster Bay for the first time in my 71 years. I am incredibly moved by the most pristine environment, comparable only to the Overland Track in Tasmania.

This history of whale migration with the ability of whales to rest with their calves on both northward and south bound journeys is a major environmental consideration.

Protection of access, quality of water and preservation of fish habitats and beach wave patterns is fundamental.

I am dismayed and outraged at this planned kelp development which is nothing short of extreme environmental vandalism for profit. It is poorly disguised as environmentally beneficial, where it is clearly the opposite. This disgraceful capitulation to private interests is clearly flawed. Not only will there be immediate pollution from the massive project from the kelp from the barges and boats necessary to maintain the farm from the industrial noise, smoke, oil leaks and flashing lights. The immediate hazards to migrating whales with the potential to disrupt their natural 1000 year established migration patterns is potentially life threatening to the whales and disgraceful. There is potential for the kelp to dislodge with 100s tonnes of kelp to be dumped on the shores of Nadgee Nature Reserve and potentially obstruct the entrance to the pristine waters of Wonboyn Lake and River. This would have disastrous consequences for marine life within that ecosystem. I object in the strongest terms. A public enquiry must be held at the highest levels and the Minister held to account.

This project disrupts the local ecosystem close to a National Park and can create more debris and rubbish in a remote area. It can change the nutrient balance of the nearby water system which will have a negative impact on businesses down the river.
Wonboyn is a rare place of wild natural coexistence and the kelp farm will be a visual eyesore against a backdrop of wilderness. There is the chance of this kelp farm to expand even further, altering the waterways and beauty of the area. Surely there’s somewhere else further out and not near a delicate estuary and river system for the kelp farm to be developed. It is the beginning of industrialising the area and the national park should not be used to allow the infrastructure equipment needed to build such a large kelp farm, which I assume is a commercial venture. I object strenuously to this project. For me personally for sixty years, this place has been a place of quiet, untouched nature. There are so few of these untouched and wild places left for everyone and anyone to enjoy.

I'am not convinced that conducting research in a pristine environment is the bet environmental practice for scientific research even if funded from university and backed by regional development government funding.
Surely smaller trial sites in less pristine environments would be a better option at this stage. The south coast of NSW is world renown for its environment and clean air and water. Many locals choose to live in this area whilst tourist are drawn to this area bringing tourist funds that support the local economy.
BECRC that are joint funding the project stand to make economic gain at the expense of the environment.
Whilst safeguards of anchoring points ect quote to 1 in a hundred storms there are many instances where these climatic conditions have been exceeded. Our whole coastline therefore can be affected by debris, loss of habitat, and the introduction of plastics into the ocean.
The migratory patterns of marine mammals is of concern for the species and once again the tourism and social benefits that they have along the entire East Coast of Australia.
"Kelp farming has been observed to reduce the levels of nutrients within the water column, which can result in improvements in water quality, especially when located in areas where high nutrient loads are associated with issues like algal blooms and eutrophication (Hasselström et al 2018, Campbell et al 2019). Shellfish aquaculture can put extra nitrogen into the ecosystem and can change local ecology, however when located in areas where tidal movements allow for regular flushing of water, the impacts of this is minimal (Würsig and Gailey, 2002). Co-locating shellfish farms with seaweed aquaculture is a growing area of scientific interest, as this might also assist in maintaining water quality (Buck et al 2017, Stenton-Dozey et al 2021)."

One of these studies are over 2 decades old and the co-locating shellfish is of major concern. I have seen the spread of mussels and the degradation of Jervis Bay and do not wish for this to happen at disaster Bay.
Again the literature provided does not convince me that the economic benefits of the few outweigh the degradation and destruction of millennial old pristine environment. Until further information explaing and exploring community concerns this is a NO from me.
Appreciate your time

Disaster Bay will take on a new meaning if this dangerous project gets approved . A terrible idea for this pristine wilderness area . I travel to Wonboyne each year to visit friends and family , this is a remarkable place and should not be commercialised in this way .

The RCC actively supports the Auskelp proposal to establish a seaweed farm off the coast of Disaster Bay, creating an industry that will produce healthy food and other products (such as an additive to fertilser), is good for the environment and will create jobs in this regional community.

The Regional Circularity Cooperative (RCC) has been established by Bega Group and Rabobank, national leaders in food production, to drive the transition to a circular economy within the Bega region and beyond through its Bega Circular Valley (BCV) program. Central to supporting the BCV program is the promotion and support of sustainable businesses and practices which are demonstrating leadership in circularity, regenerative agriculture / aquaculture, diversification, local value adding and regional economic development. Auskelp is an excellent example of such a business and should be supported in its innovative and ground-breaking approach.

We see kelp farming as a key contributor to the Bega Valley delivering a truly circular and regenerative future. The RCC recognises the critical need for investment in innovative, future-focused businesses in the Bega Valley that will both drive economic development and support the transition to a circular economy. The establishment of a kelp business in the Bega Valley will complement other local businesses, creating an opportunity to drive industrial symbiosis and substantial business synergies and value-adding, such as in the local biological fertiliser industry being championed by Ocean2Earth. This is likely to have substantial benefit to local farmers through local production of low emissions, biological fertiliser, incorporating marine waste and by-products from the other primary high value uses of seaweed.

My husband has made a submission on his behalf I would like to add my own comments
Sharon Fraser
I strenuously object to placing a commercial venture adjacent to a pristine wilderness area, this bay is resting and feeding point for migratory humpback whales, up to 50000 whales use this waterway on their annual migration. The risk of entanglement far outweighs the potential benefits of this project. These figures from DCCEEW. We have a house overlooking Disaster Bay and every migratory season watch whales swim along the beach of Disaster Bay right through the planned mass of ropes and seaweed. If a whale entanglement occurs what has the proponent put in place for such a disaster, there is no vehicle access to this beach, as previously stated a wilderness area.
I believe that this development is an environmental disaster waiting to happen.
This coastline has in the past experienced east coast lows and there is no way that in the event of severe east coast lows and the storm surge and the massive seas that occur can be accounted for.

I spent alot of my childhood growing up in Wonboyn, and I formally object to the kelp farm going ahead in Disaster Bay, due to its significant environmental and economic risks. The project threatens a critical migratory refuge for whales; despite proposed mitigations, the installation of infrastructure creates an unacceptable danger of fauna entanglement in a high-energy marine environment. Furthermore, the industrialisation of these waters jeopardises the pristine wilderness value of the area adjacent to the Nadgee Nature Reserve, potentially replacing a unique natural asset with commercial debris and equipment.
Beyond environmental concerns, the farm poses a direct threat to the local oyster industry and community amenity. Significant anxiety exists regarding the potential for storm events to wash excessive kelp and sand into the Wonboyn Lake entrance, which would disrupt the hydrological balance essential for oyster cultivation. Given the lack of comprehensive community consultation and the risk of biological waste accumulating on local beaches, I urge the Department to reject this application to protect the ecological integrity and established livelihoods of the region.

As a regular visitor to Wonboyn Lake/ Twofold Bay for the past 15-20 years, I would like to comment on the proposed aquaculture lease proposal.
It would seem logical to me to locate the kelp farm in Twofold bay which has an already established aquaculture ( Mussel farming) industry and fishing industry. Twofold Bay also has all of the marine industrial infrastructure in the form of jetties, piers, refueling, labour resources , etc necessary to support such a proposal rather than spoil a pristine part of the NSW Coast adjacent to a Nature Reserve. Surely this would impact the conservation values of the nature reserve.
Also it's called Disaster Bay for a reason due to the significant storm events and seas that have wrecked many a ship in days gone by. I am skeptical a kelp farm would withstand some of the expected storm events , given their increasing frequency. No doubt the proponent will argue that Twofold bay is not optimal for the particular species of kelp ( doesn't kelp already flourish inside Twofold Bay?), however there will certainly be species of kelp that could be farmed inside the Bay and be commercially viable .
Thank you for the opportunity to comment on this proposal.

I am83years old. I first came to Wonboyn Lake as a guest of Doug Hemingway senior in 1952. As a result of a large bush fire which burnt the south side of the lake, this land was divided into 3x properties, one of which I am now the owner. I have had the privilage to enjoy one of natures dream, places. In my younger days I spent most of my time at the beach as my family are doing now. First place I woud take visitors to the beach to show them, paradice. Last time I went to the beach by boat and had to walk on a path to the south side of the headland, only to be confronted by approx 12-20tonne of silver grey kelp washed in and against the rocks. This was unique as all I had ever seen very small pieces of shatted red kelp from time to time. I beleve this Kelp Farm will be just another Disaster in Disaster Bay. As an ex pilot, there are many many uninhabited bays between Disaster Bay and Gabo Island that would be less offensive forr this project. I plead that you will listen, otherwise you leave me no option to take the matter to court. Don R oss

Subject: Formal Objection to Proposed Industrial Kelp Farm in Disaster Bay

To Whom It May Concern,
I am writing to formally object to the proposed 200-hectare industrial scale kelp farming development in Disaster Bay, near Wonboyn Lake.
This proposal raises serious environmental, ecological, and community concerns that I believe have not been adequately addressed.
Disaster Bay is one of the last remaining unspoilt marine environments on the east coast of Australia. Its ecological value is significant, not only for its pristine waters but also as a known resting and migration area for several species of whales. The introduction of a large-scale industrial operation in this sensitive marine habitat risks disrupting these natural patterns and could have long-term impacts on marine biodiversity.
The proximity of the proposed development to the Nadgee Nature Reserve further heightens concern. This reserve is widely recognised for its unique and largely untouched coastal wilderness. Establishing an industrial facility of this scale adjacent to such an area is inconsistent with the intent to preserve and protect these rare natural environments.
While I acknowledge the potential economic benefits of aquaculture, the scale and location of this proposal appear to prioritise financial return over environmental protection. There are more appropriate locations for such developments that would not compromise areas of high ecological and conservation value.
Additionally, there is concern about the cumulative and unknown impacts of a project of this size, including:
Disruption to marine ecosystems.
Potential impacts on whale migration and resting behaviour.
Visual and environmental degradation of a pristine coastline.
Long-term consequences that may not yet be fully understood.
Given the significance of Disaster Bay as a natural asset, I strongly urge decision-makers to reject this proposal in its current form and prioritise the protection of this unique marine environment for future generations.
Thank you for considering this submission.
Yours sincerely,
Kerry Young.

I object to this project due to:-

1) a lack of public consultation with local people including the Aboriginal community
2) the location in a pristine, wild area.

For a long term positive outcome there needs to be strong support from the local people who care about environmental and social consequences and not just reflecting the industrial interests. I am sure there would be plenty of support for growing kelp sustainably in the best place, perhaps where similar activities are already taking place.

A total environmental disaster, like the name suggests.
Why jeopardise our coastal beauty and its importance for future survival.
You will be sorry if you approve this. Be it on your own head and explain why?? Greed. Leave it alone.

SUBMISSION
Objection to SSD-41680467, Eden-1 Kelp Aquaculture Lease

I have had the privilege to spend almost every summer, and some winter break of my life at Wonboyn, surrounded by the extraordinary natural beauty of Disaster Bay and the Nadgee wilderness. Fishing, exploring and seeing whales offshore are some of the most heartfelt memories that I have in my heart, and cannot be quantified by a dollar amount or a claim in an environmental impact statement. I hope one day that my children will also have the ability to enjoy one of Australia’s last untouched wildernesses, as I did growing up. However, this joy is at risk for future generations, due to the proposed Eden-1 project for the following reasons.
Reading through Auskelp’s Environmental Impact Statement is much like watching a whale in disaster bay. While less enjoyable, it contains a similar degree of backflipping. In it, it states on page 231 that the project “lies outside of primary migratory corridors” but earlier in the piece on page 211 it admits that no “formal surveys have not been undertaken in Disaster Bay”. Another similar misrepresentation appears on page 211 where they mention that “there is no documented evidence of whale entanglement in kelp farming operations” and then goes onto say that “The only known fatality was in August 1996, a Bryde’s whale”.
The fundamental issue with this proposal is that it seeks to industrialise a marine environment that remains largely pristine. Disaster Bay and the surrounding Nadgee coastline are valued precisely because they are undeveloped, wild and ecologically intact. Once industrial infrastructure is introduced into such an environment, the character of the area is irreversibly changed. The visual impact of longline aquaculture infrastructure, vessel activity and associated operations is incompatible with the wilderness values that attract visitors, sustain local tourism and define the identity of the region.
There is also a broader principle at stake. Environmental assessments should not operate on the assumption that a project should proceed unless absolute harm can be proven. In fragile and unique environments such as Disaster Bay, the precautionary principle must apply. Where there is uncertainty regarding whale interactions, marine ecosystem impacts, navigational risks or cumulative environmental consequences, the burden should rest on the proponent to conclusively demonstrate safety. In this case, they have not done so.
Future generations deserve the opportunity to experience Disaster Bay as it exists today, unspoilt, undeveloped and abundant with wildlife. Not every coastline must be commercialised, and not every natural asset should be treated as an economic opportunity. Some places are valuable precisely because they have been left alone. For these reasons, I strongly object to the approval of SSD-41680467, Eden-1 Kelp Aquaculture Lease.

Sincerely,
Leonard Shepherd

I believe this project will adversely affect the environment of Disaster Bay and the adjacent national park during the initial construction stage and final operation.