A proposal by salmon farmer Tassal to increase the size of its Soldiers Point farm in the D'Entrecasteaux Channel renews concerns about the environmental impacts of fish farming, loss of access to publicly owned waterways and the planning process that regulates the Tasmanian aquaculture industry. A recent hearing of the Marine Farming Planning Review Panel highlighted these concerns.
Unease about new developments in the Tasmanian aquaculture industry is once again becoming obvious after several years of a more or less steady state situation. On the one hand, rumblings from within industry indicate that there is renewed interest in further significant expansion. On the other, people sensitised by the last round of expansions simply don't want any more fish farms taking over public waterways and causing environmental problems.
Public statements from some sections of the industry suggest an increase in production in the order of 50% is seriously being considered. Although it is not clear where this growth would actually occur, there is a clear expectation that a fair proportion of it would require more cages in the sea, more environmental impacts and the loss of more access to waterways.
These issues have recently been highlighted by a proposal by fish farming company Tassal to increase the area of one of its farm sites, at Soldiers Point in the D'Entrecasteaux Channel. After a period of public display and submission-taking from interested parties, a hearing of the Marine Farming Planning Review Panel was held on 21 February 2011. This demonstrated that, as far as amenity and environmental issues of public concern, nothing much has changed since the boom days of aquaculture expansion in the 1990s.
The aquaculture industry in Tasmania, along with the forestry and mining industry, is quarantined from the mainstream planning process. Planning for changes to farmed areas is carried out by the marine farming branch of DPIPWE, referred to as the ‘Planning Authority’ in the relevant documentation, and reviewed by the Marine Farming Planning Review Panel.
The TCT has long criticised this process, and we are not alone in our view that recreational and environmental stakeholders are inadequately represented by panel members. In the past it is clear that non-industry positions have not been given the consideration they deserve, and that the planning process has acted more as a rubber stamp for industry expansion than as a mechanism for balancing the needs of different members of the community.
Problems with the latest development proposal at Soldiers Point include the following:
A mapping anomaly in the documentation created some confusion in the public consultation process as to what was actually being proposed. Identifying an area under consideration for development is fundamental to any planning process, and it is incredible that such a basic mistake could have been permitted to occur. This error should at least mean that further opportunities for public consultation are provided, based on the corrected documentation.
Destruction of Seals by the Aquaculture Industry
The need for an option to destroy problem seals was reinforced by the documentation supporting this proposal. Experience in the USA indicates that there should be no need to destroy seals if proper technology is used. The desire to kill or translocate seals is simply a band-aid solution to a problem that only exists because the aquaculture industry is unwilling to invest in appropriate technologies and procedures.
Recently, the Global Aquaculture Alliance (a standards system backed by big US retailers, not conservation groups) stated in a draft salmonid farming practices document that there should be no need to kill predators and other strategies and technologies should be used to prevent unwanted interactions with animals such as seals.
Loss of Amenity
Loss of access for recreational users has been a longstanding complaint about the increasing area being given over to the aquaculture industry. For example, other water users such as sailors, fishers and divers are being excluded from traditionally important areas. Beachgoers, shore walkers and residents are being confronted by what is perceived by many as a noisy and unsightly industrial activity.
The Planning Authority is dismissive of such concerns, stating on page 26 of its assessment of written submissions that ‘... this proposed amendment will increase the visual impact of marine farming operations at Soldiers Point to surrounding residents. This is an unavoidable impact of this proposal’.
Lack of concern about noise, visual pollution and reduced access caused by the aquaculture industry has been a feature of DPIPWE in the past, and has been supported by previous decisions made by the Marine Farming Planning Review Panel. It highlights the failure of this planning process to take into account the legitimate concerns of the wider community.
For example, some years ago, an area just to the north of Ninepin Point in the D’Entrecasteaux Channel was being considered as a new aquaculture lease area. Opposition came from three Tasmanian government departments (Parks and Wildlife, Tourism and the coastal unit in the Primary Industries Department), along with one of Australia’s leading marine ecologists, local residents and the TCT. The only support for this proposal came from the marine farming branch of the Primary Industries Department and just one aquaculture company. The result was predictable, but never adequately explained or justified, and the new farming area was created.
In the wake of this decision, the TCT understands that there was a government direction that its departments no longer make critical public submissions in the aquaculture planning process. In a bizarre twist that highlights the bias of this process, the new area was never actually occupied since, on further consideration by the aquaculture company, it was considered to be unsuitable as a farm site.
While the TCT recognises that solid wastes are largely restricted to areas under cages, and the process of site recovery is relatively well researched and understood, it has recently come to our attention that there are proposals to physically remove anaerobic sediment from the vicinity of cages to reduce health risks for farmed fish (from toxic hydrogen sulphide emissions, for example). This raises the concern that polluted sediment will be much more widely distributed in the environment and become an unacceptable environmental impact.
In the 1990s, the TCT was informed that its concerns about nutrients from aquaculture were unfounded and that such inputs would be insignificant. In fact, a CSIRO study of the Huon system indicates that aquaculture contributes around 25% of total nutrient loading (human-related inputs make up about 50% of the total). The ecological consequences are not completely understood, particularly with regard to benthic communities but, in any case, present a threat to the aquaculture industry itself as raised nutrient levels can encourage blooms of toxic dynoflagellates, for example. A similar risk is associated with increasing nutrient loading in the D’Entrecasteaux Channel.
In its response to written submissions the Planning Authority actually acknowledged our concerns about nutrients. As far as this writer can remember, this is the first time DPIPWE has acknowledged our concerns about nutrients since the Marine Farming Planning Review Panel was created. The TCT has been raising this issue since the 1990s.
There has been some worthwhile work done in this area – by CSIRO’s Huon Estuary study etc, and more recently, apparently useful monitoring by the Broad Scale Environmental Monitoring Program (BEMP). In fact the Planning Authority states (on page 7) that ‘TAFI have been engaged by DPIPWE to evaluate and interpret the data from the BEMP. This work is expected to commence in mid 2011 and together with other relevant research will assess the monitoring site specific and regional data against the predictions of earlier system-wide modeling… This evaluation will inform the PAs future management strategies for the MFDP area.’
It seems irresponsible to allow any further expansion of the aquaculture industry in this region until at least after the proposed evaluation has been completed and more thorough assessment of nutrient impacts has been carried out.
One advance in aquaculture management has been the introduction of a cap on nitrogen inputs. This is a kind of de facto limit on nutrient loading. Unfortunately, this upper limit needs more justification, and there is an urgent need for an independent auditing process to ensure that the cap is actually being applied.
Because farmed salmonids need omega-3 fatty acids in their diet, their feed needs to contain marine organisms that have this nutrient. Generally, a high proportion of fish meal is made up of wild caught fish. As a general rule, it takes about 4 to 5kg of wild caught fish to produce 1kg of farmed Atlantic salmon. This is not a particularly efficient use of fish stocks, and is made worse by the fact that the small pelagics that are often used to make fish feed are not always fished sustainably. So, in effect, by eating farmed salmon you may be contributing to the overfishing of small fish that are ecologically important as they normally feed tuna, whales, seals, dolphins and other marine life, and are critical to the function of marine ecosystems.
Antibiotic residues have been found in wild fish caught near fish cages. In one instance it appears that contamination of flathead by antibiotics was five times the maximum permitted by Australian Standards. It is the view of the TCT that antibiotic use for animal husbandry is unethical. Apart from anything else, regular low level exposure of bacteria to antibiotics encourages the development of resistant strains. Antibiotic-resistant bacteria are becoming a major threat to human health. There should be no need to use large amounts of antibiotics to grow salmonids in Tasmania. One local company does not use antibiotics and manages to grow salmonids, probably because at their farms they use lower stocking densities.
Inadequate Assessment of Benthic Environment?
In its EIS, Tassal indicates that its initial survey did not identify the existence of an important reef in the proposed lease area. The failure to identify such a relatively large structure does not give confidence that other important features were identified, such as the presence of the critically endangered spotted handfish. Significant spotted handfish populations may be found in a relatively small area of seabed and at the moment this species can not afford to suffer any losses.
After the reef area was pointed out to the proponent by the Woodbridge Marine Discovery Centre, the proposed farm area was moved to avoid impacting the reef. This reef has an interesting and relatively rare assemblage of invertebrates that occur in shallow water because low light levels created by tannin-stained water prevent algae growing successfully. This reef is apparently used by the Marine Discovery Centre during some of its educational activities.
At the Marine Farming Planning Review Panel hearing of 21 February 2011, we heard from Assistant Professor Stewart Frusher from the Tasmanian Aquaculture and Fisheries Institute, who described the invertebrate community as being similar to those found in the Bathurst Harbour region in southwest Tasmania. These unusual communities are similar to those found in very deep water in the normal marine environment. The communities in the Bathurst Harbour region also seem to be there because of low nutrient levels. If the invertebrate community on the reef near this proposed aquaculture development really is similar to the ones found in the Bathurst Harbour region, then it does not seem like a good idea to place a big nutrient emitter such as a fish farm alongside, unless you want to make it disappear.
I am not sure how similar the invertebrate community is to the ones near Bathurst Harbour as it has been a long time since I have dived near Soldiers Point, but if the reef community is to be protected from expanding fish farm activities then this aspect needs further investigation.
Need for Expansion Unjustified
The stated justification for the expansion of the Soldiers Point fish farm is to allow more fish from a nearby lease to be held at the Soldiers Point farm, and therefore allow the separation of year classes of fish in the production cycle. The separation of year classes is used in industrial-scale animal farming to reduce the risk of diseases spreading from one year class to another.
It should be remembered that Tassal already has multiple areas being used for farming. It already has the capacity to separate year classes to reduce the risk of disease without the need for additional farm area, although it may perhaps be necessary to reduce stocking density.
What this proposed expansion is really about is making more of the D’Entrecasteaux Channel available to a marine farming company. That means that less area will be available to other users. At the end of the hearing, after listening to arguments and information from the company, the managers and opponents, it seemed clear to many that the proposal was a good commercial proposition for a company, but that there would be a clear cost to the rest of the community.
One of the main problems with aquaculture planning in Tasmania is that there is no clearly defined planning strategy for this industry. Planning is done on a piecemeal basis as each small area is assessed with no regard for the overall environmental impact or community concerns. For example, it would help if there was some indication about how much more of the D’Entrecasteaux Channel the aquaculture industry wants. From the point of view of many recreational fishers and other water users, there is already too much space taken up by fish farms.
Previous decisions by the Marine Farming Planning Review Panel have reinforced the TCT’s lack of confidence in the planning process, and the Planning Authority has almost always appeared to be insensitive to the concerns of anyone in the community apart from the aquaculture industry.
During the assessment process for the current proposal, a dismissive approach by DPIPWE to community concerns raised in written submissions and at the hearing indicates that it is business as usual in the government body that oversees the management of Tasmania’s aquaculture industry. However, membership of the Marine Farming Planning Review Panel has changed, providing some hope that community concerns will be taken more seriously. In fact, during the hearing panel members actually seemed interested and asked many very relevant questions. They certainly had access to enough information upon which to base a good decision.
Opposition to further aquaculture expansion was obvious at the hearing and in many of the written submissions. Well prepared representations were made by the Woodbridge Community Association, Environmental Defenders Office and others, as well as the TCT. While there were many good reasons given for not proceeding with this expansion, relating to loss of amenity and other environmental impacts, it seemed that the only justification for increasing the area used for aquaculture at Soldiers Point was increased profitability.
The Marine Farming Planning Review Panel decision on the Soldiers Point proposal will be particularly interesting as it should provide a good indication about how balanced the aquaculture planning is in its current incarnation. For a long time the TCT has pointed out that recreational and environmental stakeholders are not adequately represented in the planning process and by panel members, and that non-industry positions have not been given the consideration they deserve. Having new members on the Marine Farming Planning Review Panel provides some hope that this will change, but does not really solve the underlying problems associated with the planning process for the aquaculture industry in Tasmania. A planning process that depends on the individuals working in it for a successful outcome is completely unsatisfactory.
The current planning process associated with aquaculture development in Tasmania cannot be compared to the much more comprehensive and transparent process of the Tasmanian Planning Commission, or its predecessor the RPDC. It is interesting to note that many of the planning fiascos, such as the pulp mill, that have beleaguered the Tasmanian Government and community in recent times have occurred because the government has tried to short-circuit its own planning process. The Tasmanian aquaculture industry should be mature enough by now to survive exposure to normal planning processes in the same way as practically every other Tasmanian business.
TCT Marine Campaigner