I object to the project because of its location which is an environmentally sensitive area. The project would be more suited to an area closer to where other aquaculture activities are already happening.

I object to this large commercially sized development being in a wilderness area - the last remaining pristine coastal wilderness area in NSW. Once there is development, it can never be returned to its pristine condition. And sets a precedent for further expansion of commercial development where there should be none.
We must continue to protect what is remaining of our unique natural waterways, oceans, forests and all the wildlife that rely on us to shield them from allowing any commercial development here. The highest protection should be accorded to the terrestrial and marine environments of Nadgee Nature Reserve, a sanctuary we are so very lucky to have protected adequately until now.

The grounds for my objection are quite simple. There is a logical consequence on the environment with the installation of any type of aqua farming. The environmental impacts of kelp farming are well documented across Australia. Habitat modification with risks associated with shading and light reduction. Impact with multiple screws and anchors into the seabed. Entanglement risks from the associated infrastructure on local marine life. Risks can include the introduction of non-native species to the immediate area. and the potential impact on local plankton communities.
Disaster Bay is surrounded by National Parks and Nature Reserves. Whilst Disaster Bay is not yet a Marine National Park, it is difficult to imagine a Kelp Farm be located in this remote and pristine region of NSW.
I have had the privilege of visiting this beautiful part of NSW for over 50 years. I want to ensure that it remains a pristine part of our Australian coastline.
I am also aware of the improving Whale Population in the immediate area. Specifically, in recent times, we are seeing increased numbers of Killer Whales native to the area. Humpback Whales migrating past Green Cape continues to grow, and even recent sightings of Blue Whales further demonstrate the improving state of Whale Population. What impact will a Kelp farm have on these marine species?
Thanks for the opportunity for this submission.
Regards Rob

OBJECTION SUBMISSION – EDEN 1 KELP FARM DEVELOPMENT
From: Shirley Young, Wonboyn NSW


To whom it may concern,
I write this submission in strong objection to the proposed “Eden 1” industrial scale kelp farming development in Disaster Bay.
I am the wife of a third generation member of a family that has lived in Wonboyn, and I speak not only for myself, but for six generations of our family past, present, and future who are deeply connected to this place. Today, we have two further generations living in Wonboyn, with another on the way. This is not just where we live; it is our history, our identity, and our legacy.
For generations, our family has known Disaster Bay and Wonboyn as a place of rare and enduring purity. It has remained largely untouched, one of the most pristine and unspoiled coastal environments not only in New South Wales, but in all of Australia. Few places in the world can claim such ecological integrity across centuries of human presence that has respected, rather than altered, the natural balance.
This coastline is more than scenery. It is sanctuary.
Disaster Bay and Wonboyn provide critical refuge for an extraordinary diversity of marine and terrestrial life. Migrating whales pass through these waters along ancient routes that have existed long before us. These waters are not just a transit corridor they are a place of rest, feeding, and protection. Mothers bring their calves into the calmer areas of the bay to recover during their long migration, particularly in rough seas. This is something my family has witnessed for generations. It is a privilege and an honour that cannot be quantified.
We must also acknowledge a darker chapter in our history. Eden and the surrounding region were once central to the whaling industry. Whales were hunted relentlessly, driven to the brink of extinction for profit and survival. Entire communities were built on this trade. The migration paths that are now a source of wonder were once routes of pursuit and destruction.
Over time, through significant effort, awareness, and regulation, humanity chose a different path. We protected these animals. We preserved their habitats. Slowly, their populations began to recover. Today, we are fortunate to see whales return along the very same migration routes that were once so heavily exploited.
It is because of this history that we must tread carefully.
Disaster Bay sits directly within this migration path and serves as a natural refuge. The area is well known for frequent visits by humpback whales and killer whales, alongside dolphins, seals and other endangered bird life that also rely on these waters. To introduce an industrial scale kelp farm, comprised of artificial structures, lines, anchors, and lighting into this environment raises serious concerns.
I am deeply concerned about the risk of entanglement. A mother whale or calf becoming caught in these lines could result in stress, injury, or drowning. This is not a theoretical risk it is a very real possibility when artificial structures intersect with migratory marine mammals and birds. In addition, the introduction of lighting across the bay is visually intrusive and may be disorienting to whales, dolphins, and seals that rely on natural cues for navigation and behaviour.
This is not naturally occurring kelp in its organic formation. It is a constructed, dense, monoculture system that risks disrupting natural feeding patterns, predator - prey relationships, and the broader ecological balance. What currently exists is a finely tuned, natural ecosystem. Replacing part of it with an industrial model introduces uncertainty that cannot simply be mitigated away.
I am also deeply concerned about the lack of genuine community consultation. Local residents were not meaningfully informed or engaged until after initial stages had already progressed, including the approval of a test patch. Many in our community feel this development has been thrust upon us without proper transparency, consultation, or consent. For a project of this scale and consequence, this is unacceptable.
The adjoining Nadgee Nature Reserve is protected for its environmental significance. It stands as recognition that some places are too valuable, too rare, and too important to compromise. I ask: if we acknowledge the need to protect the land, why would we not extend that same protection to the ocean it borders?
Equally important is the human connection to this place. For our family and many others, this coastline holds memories, traditions, and a deep sense of belonging. It is where children grow up learning respect for nature, where families gather, and where generations find peace, healing, and continuity.
The proposed Eden 1 development represents an industrialisation of a landscape that has, until now, remained fundamentally wild. Once this change occurs, it cannot be undone.
My legacy to my children, grandchildren and great grandchildren is that I stood up to protect this place to ensure that they, and their children after them, can experience the same untouched beauty, the same thriving ecosystem, and the same sense of peace that we have been privileged to know.
I urge decision makers to recognise the irreplaceable value of Disaster Bay and to reject this proposal. At the very least, I strongly support the call for officials to visit and experience this environment first hand before making any determination. Only by standing on this shoreline can one truly understand what is at stake.
Disaster Bay is not just a location. It is a living legacy.
Please protect it.
Sincerely,
Shirley Young
Wonboyn, NSW

Please see attached submission.

As a passionate explorer of natural environments (hiking, running and ocean swimming) and someone that works in the built environment I understand the complexities and need for development as well as when protection of natural environments and systems are needed. Disaster Bay is unique in its beauty and ecological function and must be protected from industrial development. This project and any decision to allow a project of this scale and intent in Disaster Bay will set a precedent and is in conflict with the site’s landscape and community values, and current ecological system (does not currently support kelp) even if a seemingly eco- product. Changes to the natural systems, and impacts from a monoculture of kelp and the proposed scale can not be fully understood through modelling or assessments, whilst impacts beyond the bay will need to include the necessary logistics and infrastructure to support the scale of the project.
This site is the wrong site for a project of this scale. A new site should be explored with existing infrastructure and less pristine conditions where it can have a real positive impact.

Submission objecting to SSD-41680467 — Seaweed Aquaculture Lease, Disaster Bay (Eden 1)
I am writing to object to the proposed 200 hectare seaweed aquaculture lease in Disaster Bay.
Disaster Bay is one of the last stretches of the NSW coast that remains genuinely pristine. The bay supports healthy marine ecosystems, draws visitors who come specifically for unspoiled coast, and gives small operators in Eden and Wonboyn something durable to build on. A 200 hectare industrial aquaculture site would diminish all of these.
I visit the area frequently and base trips around it. Pristine coastal environments are now rare, their value compounds over time when left intact, and decisions made in 2026 to industrialise them are very difficult to reverse.
The assumption that a kelp farm delivers ecological benefit comparable to a natural kelp forest is not supported by the current evidence. A recent review in the Journal of Applied Phycology (Forbes et al., 2022) found that kelp farms create novel habitats with distinct communities rather than equivalents of natural kelp forests, that biodiversity outcomes are highly variable and operation-specific, and that commercial harvest cycles work directly against the habitat values the industry claims to provide.
Disaster Bay already has functioning marine ecosystems. Trading those for a farmed substitute, on the assumption the substitute will perform the same ecological role, is not a defensible trade.
A development of this scale also brings a significant and ongoing plastic load into clean coastal waters. Two hundred hectares of surface lines, floats, ropes and anchoring gear sit exposed to constant wave action, UV and abrasion for the life of the lease. We are well past the point where new industrial-scale sources of marine plastics and microplastics should be permitted into pristine environments. Approving this in 2026 runs against every other policy direction on plastic pollution.
I want the Eden and Wonboyn area to do well, and the region needs a different and more sustainable economic outlook than this proposal offers. An industrial aquaculture lease of this kind employs relatively few people for the area of coast it occupies.
Tourism, hospitality, charter operations, marine science, conservation work, cultural tourism and small-scale sustainable fishing all draw their value from the same source: a coastline that is intact. Those industries can employ many people for generations, and they can grow without consuming the asset they depend on.
The pristine condition of the bay is what makes that economy possible. Once 200 hectares of the bay is given over to working infrastructure, the asset is reduced from day one and the visitation it currently supports goes with it. Degrading the environment in this way reduces the long-term economic potential of the region rather than growing it. Whatever this farm produces in revenue and jobs should be weighed against what is permanently lost across the wider regional economy.
Disaster Bay should not carry this development. I ask that the application be refused.

Whom It May Concern,

I write to formally object to the proposed Auskelp Seaweed Aquaculture Project in Disaster Bay.
I grew up in Wonboyn Lake and have very strong feelings towards this matter, it isn’t just my home it is a piece of me. 

The proposed development represents a significant industrial use of a largely untouched marine environment. Located approximately 1.1 km offshore from Greenglades Beach and adjacent to the Nadgee Nature Reserve and Beowa National Park, the project sits within one of the most ecologically significant and least disturbed coastal systems in New South Wales. These areas are protected for their wilderness values, biodiversity, and minimal human interference. Introducing a 200-hectare aquaculture operation, including up to 100 kelp rigs and associated infrastructure, is fundamentally inconsistent with these values.
The scale and nature of the proposal would introduce permanent industrial elements—buoys, ropes, navigation markers, and vessel activity—into a currently pristine coastal setting. Even if described as low visibility, such infrastructure would alter the visual character and environmental integrity of the coastline. Once established, this impact cannot be reversed.
There are also unresolved environmental risks. Disaster Bay is an important habitat and migration pathway for marine species, including whales. While the proposal suggests minimal risk, the absence of recorded entanglement in other contexts does not constitute evidence of safety, particularly in a high-energy, open ocean environment such as this. The precautionary principle should apply.
Further concerns arise from the use of synthetic materials, including ropes and floats, which have the potential to degrade over time and contribute to marine pollution, including microplastics. This is incompatible with the protection of a near-pristine marine ecosystem.
The area is also of cultural significance to Traditional Custodians, with longstanding connections to the coastal and marine environment. The introduction of offshore industrial infrastructure risks impacting these cultural values and connections.
In addition, community consultation to date appears insufficient for a project of this scale. Meaningful engagement requires broad, accessible, and ongoing communication with local communities, which does not appear to have been adequately achieved.
This proposal is not a minor or reversible change; it represents the industrialisation of a highly sensitive and largely undisturbed coastal environment. Approval would set a concerning precedent for similar developments in protected or near-pristine areas.
For these reasons, the proposal should be rejected in favour of preserving the long-term environmental, cultural, and social values of Disaster Bay.

Formal Objection to Proposed Seaweed Aquaculture Lease – Disaster Bay (Eden, NSW)
Submitted by: Drew Kelly
Wildlife Filmmaker | Whale Behaviour Observer | Award-Winning Documentary Producer

1. Statement of Position
I formally object to the proposed seaweed aquaculture lease in Disaster Bay, on the basis that it presents a clear, foreseeable, and unacceptable risk to migrating whales, particularly humpback whales that traverse this coastline in high densities.
This objection is grounded in:
• Long-term, direct field observation of whale behaviour along the Sapphire Coast
• Documented experience filming and tracking entangled whales
• Established scientific understanding of whale migration, navigation, and entanglement risk
• The ecological significance of this coastal corridor as a primary migratory pathway

2. The Sapphire Coast Is Not a Neutral Site - It Is a Migration Corridor
The coastline between Eden and the Victorian border is not simply “coastal water”-it is a biological highway used annually by thousands of humpback whales (Megaptera novaeangliae).

This region is characterised by:
• Nearshore migration patterns (often within a few hundred metres of the coastline)
• High-density movement during peak migration windows
• Behavioural states including resting, socialising, and mother–calf interaction
From extensive time on the water filming whales in this region, I can state unequivocally:
Whales do not simply “pass through” this area - they actively use it, linger in it, and interact within it.
Placing fixed or semi-fixed aquaculture infrastructure within this corridor introduces persistent physical hazards into a space that whales rely on for safe passage.

3. Entanglement Risk Is Real, Ongoing, and Often Fatal
I have personally filmed and tracked whales that have become entangled in marine infrastructure and debris. These are not rare or hypothetical events.

Key realities:
• Entanglement leads to prolonged suffering, not immediate death
• Whales may carry gear for weeks or months, leading to:
o Infection
o Restricted movement
o Starvation or exhaustion
• Even “minor” entanglements can become fatal over time
• Disentanglement is dangerous, resource-intensive, and often unsuccessful
Scientific literature consistently identifies:
• Ropes, lines, and tensioned structures as primary entanglement hazards
• Increasing entanglement rates globally as ocean use intensifies

4. Seaweed Aquaculture Infrastructure Is Not Benign
While seaweed farming is often presented as “low impact,” this characterization fails when applied to whale migration corridors.
Typical infrastructure includes:
• Horizontal longlines
• Vertical drop lines
• Anchoring systems
• Surface and subsurface floats
These create a three-dimensional web of tensioned lines in the water column.
From a whale’s perspective:
• These structures are not acoustically obvious
• They may be encountered during:
o Feeding lunges
o Social behaviour
o Surface breathing cycles
This is particularly critical for:
• Mother–calf pairs, where calves are less aware and more vulnerable
• Social groups, where attention is on interaction, not obstacle avoidance

5. Behavioural Reality: Whales Cannot Reliably Avoid These Structures
It is incorrect to assume whales will simply “detect and avoid” aquaculture installations.
Based on both observation and research:
• Whales frequently:
o Travel at speed
o Surface unpredictably
o Engage in rolling, breaching, and tail-slapping behaviours
• Calves often:
o Move erratically
o Separate briefly from mothers
• Visibility underwater is often limited
Even highly intelligent, sentient animals are not adapted to navigate artificial, tensioned line fields.

6. Cumulative Impact and Precedent Risk
Approving this lease sets a dangerous precedent:
• It normalises aquaculture development within migration corridors
• It opens the door to:
o Expansion of similar leases
o Increased density of marine infrastructure
• It contributes to cumulative risk, which is rarely adequately modelled
The question is not just:
“Will this single lease cause harm?”
But:
“What happens when this becomes standard practice along the coast?”

7. Ethical Consideration: Foreseeable Harm to Sentient Wildlife
Humpback whales are:
• Highly intelligent
• Socially complex
• Long-lived mammals
We now understand them as sentient beings, not simply “marine resources.”
To knowingly install structures that:
• Have a documented history of causing entanglement
• In a known migration corridor
is to accept foreseeable harm.
A more accurate framing is:
This is not a neutral development - it introduces a persistent risk of suffering and death to animals that are simply passing through their natural route.

8. Economic and Environmental Trade-Offs
While seaweed aquaculture may offer:
• Carbon sequestration benefits
• Economic opportunities
These benefits do not justify:
• Placing infrastructure in high-risk ecological zones
• Compromising the safety of protected migratory species
There are alternative locations that:
• Do not intersect directly with migration pathways
• Present lower ecological risk
Site selection is a choice, not a necessity.

9. Request
I respectfully request that the proposed lease be:
Rejected in its current form, or at minimum:
• Relocated outside known whale migration corridors
• Subject to independent, whale-specific risk assessment
• Evaluated using real-world entanglement data, not theoretical modelling

10. Closing Statement
From years spent observing, filming, and documenting whales along this coastline, I can say with confidence:
Introducing fixed aquaculture infrastructure into this corridor is incompatible with the safe passage of migrating whales.
We are not dealing with an abstract environmental concern.
We are dealing with predictable, preventable harm.
This coastline is one of the great migration routes of the natural world.
It should be protected accordingly.