Submission to NSW Dept of Urban Affairs and Planning
on the proposed prawn farm development at
Racecourse Headland (Crescent Head)

14 May 2001

Jo Haggerty
Department of Urban Affairs and Planning
Development and Infrastructure Assessment Branch
GPO Box 3927
Sydney NSW 2001

RE: South West Rocks Aquaculture Ltd Statement of Environmental Effects for the proposed prawn hatchery, growout and processing operation, Stage 1 (referred to as the Proposal).

Dear Ms Haggerty: 

Please find attached Surfrider Foundation Australia's response to the South West Rocks Aquaculture Ltd. Statement of Environmental Effects for the proposed prawn hatchery, growout and processing operation, Stage 1 (referred to as the Proposal). 

Please feel free to contact me regarding our response document at the office number supplied below. 

Sincerely, 

Greg Howell,
Executive Director, Surfrider Foundation Australia.

Public Submission

Proponent:
South West Rocks Aquaculture Ltd

Proposal:

Statement of Environmental Effects for the proposed prawn hatchery, growout and processing operation, Stage 1.

After examining the Proposal at length, Surfrider Foundation's submission will focus on the following three issues:

1. Environmental Issues
2. Health and Related Issues
3. Cultural and Social Issues and due process

ENVIRONMENTAL ISSUES:

The Surfrider Foundation consider the site chosen for the project to be environmentally inappropriate for the following reasons:

• The site's location on a coastal headland contravenes the criteria of Section 2.3 of the NSW Coastal Policy (DUAP 1997) that appropriate developments on such locations be of a "minor" nature and only for "essential public purposes." We consider the Proposal does not fit into either category.

• The potential degradation of listed and protected coastal wetlands located to the east of the proposed project site through run-off from the hatchery site during its construction or through overflow from the proposed biopond.

• The potential for contamination of surrounding marine systems through inadequate or non-existing water intake and disposal processes. In regards to the growout ponds, the Proposal's suggested use of a clean water intake pipe located less than 20 metres from the outflow pipe which is in an existing drainage channel appears to us to be unacceptably poor environmental practice.

• Surfrider Foundation members familiar with the local marine environment advise us that water eddies on the north side of the headland and creates a rip taking water out to sea along the headland, thus creating a situation in which the mixing of clean and contaminated waters from the adjacent wells is highly likely to take place. We believe that South West Rocks Aquaculture Ltd should aim for maximum environmental best practice and design a system such as those used at many land-based aquaculture facilities in which all wastewater is treated on site and reused.

• The Proposal does not adequately address the question of disposal of waste from the processing plant. Standard best environmental practice in such cases suggests AT A MINIMUM that discharge from such processing plants should be treated to secondary level and then transferred to a trade waste or sewerage system. However, since the Surfrider Foundation is opposed to the marine environment being used for waste disposal, we would not be satisfied with any waste disposal system that involved disposal into the ocean. A land-based waste disposal (or preferably waste re-use) system should be used.

• Growing national concern about the potential disaster for the spread of 'white spot' disease into marine environments and wild prawn populations from contaminated aquaculture stock is also another reason why we consider off-site disposal of wastewater and marine disposal of processing waste a totally unacceptable proposition.

• Surfrider Foundation is aware that the land area proposed for the growout ponds and processing facility is in an area of high acid sulphate soil (ASS) content and any disturbance of the soil here has the potential to contaminate surrounding marine areas through discharge from the growout pond or through soil runoff occurring from the site during construction of the project.

HEALTH AND RELATED ISSUES:

• The proposed effluent treatment system for the hatchery will dispose of the estimated 700 tons of effluent produced daily by the hatchery, into a discharge pit and then into the ocean at the Southern end of the beach adjoining Racecourse Headland. This is a high-impact surf zone used for fishing, surfing and swimming by locals and tourists alike, and a popular caravan park is located less than 400m from the discharge pit. The potential health risk posed by discharge of such high volumes of effluent into this highly-used recreation area is obvious, as is the potentially negative economic impact upon the region's growing tourism industry.

CULTURAL AND SOCIAL ISSUES AND DUE PROCESS:

• Surfrider Foundation is concerned about the potential for negative impact on existing and future recreational and tourist use in the Crescent Head region should South West Rock Aquaculture Ltd project go ahead in its current format. The Racecourse Beach/headland area, the areas north and south of the proposed project and the local township of Crescent Head currently attract fishing enthusiasts, surfers and swimmers from throughout Australia and, increasingly, abroad. The international trend towards eco-tourism is also beginning to be seen in both the number of tourists visiting the region to enjoy both its marine and coastal attractions. Any potential or proven threat to water quality and beach amenity in the region resulting from the Proposal will directly and negatively affect regional tourism.

• Surfrider Foundation also questions why, at the time of writing, consultations have not taken place between the Proponent and the local Indigenous Land Council or with the Dunghutti tribe, given that the Goolawah Reserve Plan of Management states that the Racecourse Headland and surrounding area contain significant aboriginal artefacts such as middens, a burial site and an earth circle.

• Surfrider Foundation would like to express its deep concern at the manner in which the Proposal has been released without regard to due process and with apparent ignorance of and disregard for the guidelines of The North Coast Sustainable Aquaculture Strategy (August 2000). Page 167 of the Strategy notes that there is a requirement for the proponent of a sustainable aquaculture project to "consult with the local community" during the preparation of the development application.

• At the time of writing, this process of consultation has not occurred, despite South West Rocks Aquaculture Ltd committing themselves on page 18, Section 10.5 of their own SOEE to "consultation with the community regarding the establishment of the project and the Company's proposed construction of amenities, and its beneficial impact to the community, will be undertaken prior to the start of project construction."

CONCLUSION

The Australian coastline, and particularly the North Coast region of NSW, is infested with ill-designed and hastily-built testimonies to poor planning, lack of community consultation and disregard for the environment. We understand the Department is currently reviewing its planning regime and look forward to commenting on the Plan First initiative. Aquaculture is a relatively new industry, with few safeguards currently available to guide against wrong decisions being taken by its proponents. For these, and the above-listed reasons, the Surfrider Foundation urges that DUAP swiftly and completely reject the South West Rocks Aquaculture Ltd Proposal.