I object to the proposal for Shell fish Aquaculture in Jervis Bay as proposed by NSW Fisheries. I sail, windsurf and fish in Jervis Bay in the exact location proposed for this Aquaculture site, as do a lot of other people from the area and outside the Shoal haven. The proposed system of buoys and rope would create a huge hazard to all those activities especially as they are done at times of high wind when Buoys are hard to see. I'm sure Fisheries have done their home work on these sites and have thought about all the hazards associated with this type of development. This issue has been going on for the 11 years I have been living on the south coast, and I has been strongly objected by the community each time the proposal raises its head. Can we finely put it to bed. No one wants this development in Jervis Bay.

VINCENTIA RATEPAYERS AND RESIDENTS
ASSOCIATION INC.

PO BOX 149, VINCENTIA, President : John Fergusson
N.S.W. 2540. Secretary: Elizabeth Tooley
Email: [email protected]
__________________________________________________________________________________


November 4, 2013
Department of Planning & Infrastructure,
GPO Box 39,
Sydney,
NSW 2001

Attention Kerry Hamann

Dear Sirs,
Jervis Bay Aquaculture Project (SSI 5657)

Thank you for your letter advising us of the Jervis Bay Aquaculture Project and inviting a submission.

We have studied the proposal and believe it MUST BE REJECTED by your Department. Our belief is based on the LACK OF THE FOLLOWING: -

1. An integrated coastal zone plan (ICZP) covering the operations, aspirations and limitations of the specific coastal zones stakeholders.
2. Detailed analysis of social impact of the project, particularly the risks to Tourism which is the lifeblood of the local community;
3. An understanding of the full effect of the proposal on recreation boating and other water based activities, particularly the safety factor;
4. Details of the land based activities and the impacts on the community;
5. Financial justification that this a viable project and will not become a burden on the community; and
6. An indication of the size to which this activity could grow if it proves financially viable.

On the other hand as laymen we accept the scientific work behind the proposal and congratulate staff on their comprehensive analysis of that part of the proposal. We discuss our concerns below.


Integrated Coastal Zone Planning (Management) - ICZP
ICZP originated in 1992 during the Earth Summit in Rio de Janeiro. The Summit also spawned several International Treaties incorporating ICZP principles, which Australia is a signatory to. The proposed Jervis Bay Aquaculture Project is exactly the type of proposal that ICZP is designed for. ICZP has not been used in this case creating many of the potentially serious problems raised in this Submission.
Consultation alone, with various established coastal zone stakeholders, is not Integrated Planning. ICZP requires a planning team that includes those expert and experienced in the operations, aspirations and limitations of the specific coastal zones stakeholders. There have been attempts, as shown in this document, of consultation and briefings to inform the numerous and diverse stakeholders in Jervis Bay coastal zone of the Aquaculture project, the responses are fractionalized, isolated and have only be assessed by a single stakeholder. The criteria for assessing other stakeholder contributions have been from the single perspective of aquaculture and not the holistic dimensions of present and proposed future economic and social activities in the zone. The sustainability and resilience of both the proposed Aquaculture project and the myriad of other ventures currently operating may be threatened by a single stakeholder making decisions independent of other interests.
Whether the failure to use an ICZP methodology is deliberate or based on misunderstandings of the bigger picture it is a breach of Australia's international obligations and a serious threat to the fragile nature of Jervis Bay's ecosystem and socio-economic system and their current mutual interdependence. Further, the consequences of not using ICZP opens the possibility of citizen unrest and economic dislocations similar to those being experienced in the Coal Seam Gas lease decisions in rural and urban situations in recent months.
No further action should be taken on this proposal until a properly constitutes ICZP methodology is implemented and the findings added those presented in the document.

Social Impacts

Tourism is the major industry of the Shoalhaven. According to Shoalhaven City Council tourist expenditure contributed $700 million to the economy of the City in the year to June 2013. Projections indicate a fast growth rate will continue. The City has a population of some 100,000 people that swells to over 300,000 in peak holiday periods.

In Jervis Bay villages and in the surrounding Bay and Basin region tourism is the ONLY industry. The area has a permanent population of some 24,000 and probable reaches over 100,000 in peak holiday periods and in addition has an influx of day visitors from far afield. Jervis Bay tourism is based on natural beauty of the area with clean beaches and the access to safe pristine waters for swimming, boating, fishing, sailing, kayaking, kite surfing, etc.

The local communities take great pride in maintaining the beauty of the Bay. The beaches regularly win prizes for the cleanest beach in NSW, but now will run the risk of shell and other debris in addition to suffering the visual pollution from the proposed mussel lease. The visual pollution will not only be seen from the beaches but in Vincentia, due to the cliffs and hills, it will be much more noticeable. Also of concern is the effect of the proposal on the whales, dolphins, seals and other sea creatures that are one of the Bay's great attractions. Their safety could be at risk and they will be discouraged from coming close to shore. The Bay is an open stretch of water which suffers severe storms from time to time and storm damage to the leases is inevitable with broken lines and buoys finishing up on the beach or floating free and a danger to watercraft.

Whist the proposal asserts it will be positive for tourism based on the attraction of fresh seafood, there is no data to show that the previous mussel farming operation contributed to the local tourism. Even if this was the case we doubt that the benefit would outweigh the negative effects of what is basically an industrial operation. Also there is nothing in the proposal to guarantee the mussels will be available locally. The nature of the processing could see the product packed and shipped out to Sydney or overseas.

No dollar numbers are given for the contribution to the Shoalhaven economy of this proposal but based on the staffing and capital expenditure we doubt it would be more than $2 million per year.

Is it worth risking a $700 million tourist industry for a contribution of $2 million? We say NO.


Recreational Boating and Water Based Activities

The present unimpeded nature of the Bay is one of its great attractions for water sports. Generally these activities are carried out within 2 kilometres of the shore and so will be in conflict with the proposed mussel leases and prove dangerous.

Particularly in the case of the Vincentia, the lease will be immediately in the path of small sailing boats, kayaks, windsurfers, kite surfers, paddle boarders, which are normally within one kilometre off the shore. These craft are at the mercy of changes in wind and wave strength and direction and could easily drift onto the buoys and mussel lines. Disentangling themselves could prove difficult and could be fatal. Barnacles on the ropes and buoys would also be a safety issue.

The Callala leases are further out from the shore but are located on existing yacht race courses, where races regularly start and finish. The leases are also in the path a recreational and tourists boats transiting from Huskisson to Callala Bay and the popular Long Reef and Honeymoon Bay beaches.

The Hobie 16 catamaran World Championships are to be held off Huskisson in February 2014 and will attractive participants and visitors from all over the world. This will be a major tourism event for the Bay, the Shoalhaven and New South Wales. We understand the organisers, the Vincentia Sailing Club, believe such an event would not be possible with mussel lease at Vincentia and Callala.

Both the Vincentia and Callala leases will be hazardous for all water craft including, larger yachts, motor boats and jet skis as the intention is to make the buoys and lines as inconspicuous as possible. Cardinal marks on each corner of leases will be insufficient particularly for many holiday makers who will be unaware of existence of the leases, or at night or times of poor visibility due to rain storms or fog. To use more markers will only increase the visual pollution. We request you refer the matter to the Minister for Roads and Maritime Services for comment on this important safety issue.

The mussel leases will be a danger to water based activities and will detract from attractiveness of such activities on the Bay to the detriment of tourism, tourist income and residents amenity.



Land Based Activities

The proposal only very briefly refers to the land based activities. Whilst it seems logical that these will be carried out at the Huskisson Industrial estate, there may be other alternatives. The nature of the processing facility is not described and the issues of effluent disposal, odours and rubbish removal are not discussed. These are important issues to the community.

The proposal suggests 0 - 3 trips per day to the Woollamia wharf which prima facie would not seem to be too disruptive to the normal operations of the wharf. However, this depends on the type of unloading proposed. If barges have to be unloaded into trucks for transport to the processing plant, this will occupy the wharf for a considerable time to the detriment of other users. In any case modifications to the wharf will most likely be required at a cost to Shoalhaven City Council i.e. the community. The alternative is for a purpose made wharf to be erected by the Department of Fisheries to handle the product.

Use of the wharf during the construction will be intense and its suitability to handle large items such as the anchors is questionable. The shallow draft of Currambene Creek will mean large vessels will not be suitable and necessitate many trips in small vessels during construction. The spin off to local industry during this phase is likely to be negligible with contractors being brought in from outside the area.

Financial Justification

The most important issue of financial viability of large scale mussel farming in Jervis Bay is not discussed in the proposal. Issues that arise include: -

1. Can the product when delivered to Sydney compete with imports?
2. With limited local support facilities would cost be higher than say, Port Stephens?
3. What income would the NSW Government require to justify their involvement in the regulatory supervisory duties involved?
4. What are the likely construction, operation and maintenance costs?
5. Would special financial arrangements be necessary to encourage participation of local aboriginal communities?
6. What level of production is required to make the project financially viable is 50 hectares enough?
7. What are the impacts of a lessee failing financially?

The proposal cites the success of the Twofold Bay operation, however although this has a leased area of 50 hectares only a small part is operational and the product is sold into a local market remote from Sydney. It is not comparable.

The only financial figure we can find in the report is an estimate of the capital expenditure on water infrastructure of $840,000. We can only guess at the gross revenue created by the project but it would seem to be less than $2,000,000 per annum.

It is important to establish the financial viability of the project and its contribution to the community before proceeding further with the Development Application in order to avoid wasting everyone's time.

Expansion Potential of Operations

If the project of 50 hectares can be shown to be financially viable there will be pressure from the existing operators or new participants to allow further leases to be granted.
Jervis Bay Plan of Management allocates 440 hectares to aquaculture - over 8 times the size of this proposal. So any expansion would completely change the Bay from a recreational haven to a major industrial operation.

Whether the 440 hectares can be achieved is unknown. Constraints on development include: -

1. Commonwealth waters;
2. The trace area for naval exercises;
3. The zoning of the JB Marine Park, particularly the sanctuary zones;
4. The need to protect sea grass beds;
5. Other ecological constraints; and
6. Wharf capacity.

The proposal states that the carrying capacity of the Bay is sufficient to allow the proposed 50 hectares of aquaculture. However, Fisheries Staff have admitted that they do not know the ultimate carrying capacity of the Bay. Is it 440 hectares as indicated in the Plan of Management or could it be a much larger number?

It will become a political judgement to be made by governments, State and Commonwealth as to whether mussel production should override the constraints listed above. For example, the justification for existing sanctuary zones has been raised by the NSW Government and whilst they remain in place for the moment the Government has indicated that future marine park management reviews will consider if particular sanctuary zones are appropriate to meet their objectives.


Conclusion

We have studied the proposal and believe it MUST BE REJECTED by your Department. Our belief is based on the LACK OF THE FOLLOWING: -

1. An integrated coastal zone plan (ICZP) covering the operations, aspirations and limitations of the specific coastal zones stakeholders.
2. Detailed analysis of social impact of the project, particularly the risks to Tourism which is the lifeblood of the local community;
3. An understanding of the full effect of the proposal on recreation boating and other water based activities, particularly the safety factor;
4. Details of the land based activities and the impacts on the community;
5. Financial justification that this is a viable project and will not become a burden on the community; and
6. An indication of the size to which this activity could grow if it proves financially viable.

We invite the Department to visit the Jervis Bay villages and discuss the issues with local stakeholders.


Yours sincerely,


Elizabeth Tooley
Secretary

I have grave concerns, which have not been addressed in any literature pertaining to the proposal, about the fate of our whales and dolphins in Jervis Bay.
I cannot believe that 1: 50 ha (122 acres) of submerged cable structure will not present a real danger to marine mammals (e.g. whales, dolphins).
There are no assurances as to their safety and until detailed reports are presented regarding the impact of these cables on the marine mammals, the project should not proceed.
We have a duty of protect the marine life in the Bay and the proposal shows no evidence of any concern for the whales and dolphins and their well being.
This project is ill-conceived and open-ended in many aspects and until more research is done, the project should be not be allowed to proceed.
Elizabeth Tooley,
Vincentia

I am writing to bring to your attention the proposal by NSW Fisheries for the development of commercial aquaculture leases in Jervis Bay (for blue mussels, scallops, Akoya pearl oysters, Sydney rock oysters, flat oysters & abalone). The proposal is for an initial 10 ha (approx. 24 acre) lease, 660m north of Orion Beach near Holden Street boat ramp, Vincentia, and 2 x 20 ha (approx. 98 acre) leases 1.5 km & 1.9 km southeast of Callala Beach (north of Currambene Creek entrance at Huskisson).

If this proposal goes ahead it will have a detrimental effect on Jervis Bay forever.

I strongly object to this proposal. The reasons are listed below:

1: 50 ha (122 acres) of submerged cable structure presents a real danger to recreational users of Jervis Bay. Entanglements of marine mammals (e.g. whales, dolphins) in aquaculture infrastructure are also known to occur.

2: There will be visual pollution presented by 50 ha (122 acres) of floating buoys.

3: NSW Fisheries indicated that commercial aquaculture on this scale was not financially viable. Therefore the developer, which will eventually hold these leases, will seek to maximise the leases to the full 440 ha (1087 acres). This is about 4 times the size of the whole Bayswood Vincentia development.

4: When Jervis Bay became a Marine Park, there was an allocation of 440 ha (1087 acres) for commercial aquacultureleases. It is obvious that any lease holder will seek to maximise their production. If we allow this 50 ha (122 acre) development, there is a real risk that we will end up with 440 ha (1087 acres) of aquaculture in the Bay within this decade.

5: Jervis Bay is a well known international sailing venue and has been for approx. 30 years. Sailing and other recreational water-based activities such as scuba diving and kayaking, contribute significantly to the local and regional economy. For instance in February 2014 it is estimated that sailing events alone, such as the Hobie World Titles, will contribute more than $1,000,000 to the local economy. The estimated gross turn over of the commercial aquaculture proposal of 50 ha, is a mere $173,000!!! Not only will the proposal contribute little to the local and regional economy, it may compromise attracting future national and international events such as the Hobie World Titles.

6: Jervis Bay has the "whitest sand in the world" and a number of the beaches have been recognised with "clean beach" awards. The Bay's beaches are one of our major tourism drawcards and the pride of all that have the opportunity to enjoy them. Foreshore and beach litter is known to occur as a result of aquaculture activities. Our clean and white beaches should be preserved.

7: Jervis Bay is the last body of water in proximity to Sydney that has no commercial aquaculture leases in place. The Bay is well known for its high water quality. The community, and governments, have fought for generations to protect Jervis Bay and keep it free from primary industry.
Please take the time to submit an objection to the proposal viathe link below. If you are time poor, use or copy & paste sections of the above which strike a cord with you.
Submissions are due by Wednesday 13th November 2013.

Jervis Bay is a well known international sailing venue and has been for approx. 30 years. Sailing and other recreational water-based activities such as scuba diving and kayaking, contribute significantly to the local and regional economy. For instance in February 2014 it is estimated that sailing events alone, such as the Hobie World Titles, will contribute more than $1,000,000 to the local economy. The estimated gross turn over of the commercial aquaculture proposal of 50 ha, is a mere $173,000!!! Not only will the proposal contribute little to the local and regional economy, it may compromise attracting future national and international events such as the Hobie World Titles.

I strongly oppose this development in the waters of Jervis Bay as I believe that this process can only be detrimental to the Shoalhaven and Jervis Bay which at the moment is a very pristine environment.

This type of activity has the potential to impact on the future sustainability of Tourism which is becoming more popular every year.
Jervis Bay has seen growth in many tourism orientated uses including dolphin watching, ever increasing numbers of whales making this area a mecca for whale watching, all kinds of personal activities including surfing, stand up paddle boards, diving the list goes on.

Fisheries seriously has to look at its agenda here (when liberal won state government this decisions that have been made by Fisheries have been almost atrocious to say the least and this seems like another blunder).

We do not need this aquaculture industry here in what is 1 of the most naturally beautiful bays on the East coast of Australia.

No one can guarantee that there will be no negative effects on Jervis Bay, please leave this beauty untouched.

I strongly oppose this development in the waters of Jervis Bay as I believe that this process can only be detrimental to the Shoalhaven and Jervis Bay which at the moment is a very pristine environment.

This type of activity has the potential to impact on the future sustainability of Tourism which is becoming more popular every year.
Jervis Bay has seen growth in many tourism orientated uses including dolphin watching, ever increasing numbers of whales making this area a mecca for whale watching, all kinds of personal activities including surfing, stand up paddle boards, diving the list goes on.

Fisheries seriously has to look at its agenda here (when liberal won state government this decisions that have been made by Fisheries have been almost atrocious to say the least and this seems like another blunder).

We do not need this aquaculture industry here in what is 1 of the most naturally beautiful bays on the East coast of Australia.

No one can guarantee that there will be no negative effects on Jervis Bay, please leave this beauty untouched.

I am concerned with several aspects of this proposal - the impact on recreational use given the economic value of tourism to the villages around Jervis Bay. Recreational use continues to increase with sailing, kyaking, snorkeling, swimming and fishing, not to mention large recattas and triathalon events. All of these rely on freedom of access and purity of the waters. Hazards must include inadvertent intrusion into buoy arrays, particularly that associated with the site off Orion Beach, by sailors and paddlers.
I feel the Bay as a Marine Park is well enough occupied with naval activities, regattas and recreational pursuits without another constraint.
I am concerned too with the land aspects of any aquaculture activity - the frequency of access and potential for debris.
I fear that any future expansion would only further increase perceived hazards and community detriment.

· The proposal is for a pilot project of 3 leases totalling 50 Ha. Impacts have been assessed for only that project. However, aquaculture is permitted to occupy up to 2% (440 Ha) of the marine park. Proposals of such a scale would have much more serious impacts. The pilot project should therefore be in areas away from human settlement, such as the north-eastern corner of the Bay, which may be able to withstand the greater impacts associated with future expansion in the event that the pilot is successful (which presumably is the intent).

· Being at the north western end of the Bay, Callala Beach experiences significant swells during southerly wind events, including swells generated across the longest fetch of the Bay and ocean swells coming in from the Heads. There is a risk that Callala Beach, which is directly to the northwest of the leases, will become fouled with any shells, weed, ropes etc dislodged from the leases during southerly weather events which are frequent occurrences, especially in winter. There is also a risk that the leases themselves will become entangled with weed which is blown into this part of the Bay in large quantities during those events, which may then rot and foul the beach over a more extended period than the weed which naturally occurs.

· Callala Beach is renowned for its pristine sand and water - as illustrated in Figure 53 of the EIS. The EIS does not consider the risk of the Beach being fouled byeffluent and detritus continually drifting from the leases onto the nearby Beach.

· The EIS states that the proposal is for only native shellfish species but other species "may be considered". If other species are introduced, there is a risk of them escaping and becoming a feral pest. Local experience with other exotic species (bitou bush, lantana, rabbits, foxes) indicates that once they are released into the pristine Jervis Bay environment, they can be impossible to control. Any aquaculture in Jervis Bay must therefore be confined exclusively to locally indigenous species.

· The visual impact on Callala Beach has been under-estimated. The natural appearance of the Bay is a major drawcard for tourists and residents and will be severely impacted by the leases. The photos used in the EIS appear to be a wider angle of vision than human sight and therefore may not accurately represent the visual impact, especially of a cluster of large yellow buoys of the type shown in Figure 45 of the EIS. This potential is very much greater if the trial is successful and further leases are established up to the 440 Ha permitted. This again highlights the need to establish the pilot in a remote part of the Bay ratherthan directly opposite some of the most popular beaches and beachside settlements.
For the above reasons i do not favour the Proposal proceeding in the proposed location.

Dear Sir/madam
I am a regular user of Jervis Bay, swimming frequently in its crystal clear waters. I have paddled a canoe, watched whales and dolphins, swim and play and was one of the early members of the Penguin Study group (Bowen Island). I have always appreciated the wonderful visual aspects from all the beaches around its shoreline. I value the `jewel in the crown' status of this wonderful Jervis Bay with its sandy beaches, crystal clear waters, dolphins, whales, fish and the surrounding national parks; it is definitely a `jewel'
There are some places/waterways that should be left alone for people to view and enjoy. Jervis Bay is one such place
Many people have worked tirelessly to ensure Jervis Bay maintains its wonderful environmental status, worked and won achievements to ensure this. Because of this work Jervis Bay is now a Marine Park, surrounded by National Parks that help to ensure no pollution or runoff from overdevelopment.
Now with one stroke a proposal for Shellfish Aquaculture Leases for Jervis Bay that could mean the degradation of our wonderful waterway.
The natural beauty of Jervis Bay will receive a chink in its armour, albeit they say with an Environmental Impact Statement that shows there will be no damage or measures taken to ensure there is no damage. .
Mussel Farm?
Please Note: The comments required for the proposal focus on provision of long line mussel farming on 50 hectares within Jervis Bay - but on pages 188/189 of the EIS the discussion is on oysters.
Two oyster species have been cultured or harvested in Jervis Bay are potential candidates for cultivation on the Commercial Shellfish Aquaculture Leases......The incidence of Winter Mortality is thought to increase under regimens of high and stable salinity (Wolf, 1976) and so rock oysters cultured in Jervis Bay should be carefully monitored.
Oyster farming is totally different to mussel farming. Oysters are an entirely different species with totally different requirements - visually and environmentally.
If the mussel farm proposal is approved it cannot be taken that an oyster farm will be permitted. There should be no oyster farms permitted in Jervis Bay.
Visual
I personally have always appreciated the natural beauty of Jervis Bay and have been particularly impressed with its beauty and lack of visual water pollution - no ugly oyster leases - no marina - NATURAL BEAUTY!
To be appreciated by the people.
Development of the mussel farm project will mean visual degradation/pollution!
Jervis Bay is for the thousands of Australians (and overseas visitors) to be enjoyed and loved for its natural beauty and I believe should be left alone without mussel or shell fish farms to fragment the waterway.
Thank you for this opportunity to comment and object to this proposal.



Pease Note: any Conditions given with approval of this proposal must be strictly monitored and adhered to. Too many times Development Application approval conditions are ignored. Jervis Bay waterway, seabeds, flora and fauna are too precious to sustain environmental degradation through poor management practices and non/and/or slack implementation of Consent Conditions
Note also: the statement (FAQs): The operator of the leases would be required to carry out a monitoring program for water quality and the sea floor to asses any impacts of farming activities.
Monitoring must be carried out by the leaseholders and the leaseholders must bear the financial costs