jaybee
06-10-2003, 09:42 AM
Leaked Healthy Waterways submission full of holes
In yet another example of abuse of process, the Healthy Waterways submission to the SunAqua EIS has been leaked to the media before SunAqua has even had a chance to read it.
What makes it worse are the erroneous and unscientific assertions it makes, which do the members of the panel little credit. For example:
The Healthy Waterways SEP has conveniently failed to recognise that the EIS is limited to two sites with development over a prolonged period, which will be subject to the most rigorous environmental monitoring possible – in fact, Healthy Waterways would be invited to be part of this ongoing monitoring and assessment.
It is critical to recognise the EIS is NOT for four sites, which their figures erroneously relate to, and this is a BASIC AND FUNDAMENTAL FACTUAL OVERSIGHT by a panel chosen for its scientific qualifications.
The SEP has ignored the fact that the EIS has argued for input controls to ensure nutrient outflows are constrained.
It is quite bizarre that in order to attack SunAqua, Healthy Waterways are promoting an attack on its own model. The model is owned by Healthy Waterways, and the custodian of the model, the EPA, specifically requested that SunAqua use it as it is the best available tool to assess impacts. If Healthy Waterways don’t like the result, that is not our problem.
By missing these fundamental points, the SEP has placed at risk the integrity of their submission.
Further, it is important to note that there are obvious differences of opinion among the SEP team. One SEP member, Rod Connolly, wrote,
“ The EIS contains a very thorough explanation of the biology behind fish farming practices…the proponents are aiming for a high standard of fish culturing, and the farming objectives planned for the site are well considered from a biological perspective.”
And one of the key members of the SEP team, Mr Tony McAlister, was part of the WBM Oceanics team that put the EIS together.
While others choose to continually abuse process, SunAqua will be dealing in extensive scientific detail with all submissions as part of the EIS supplementary report, which we are required to submit to the Coordinator General.
The EIS process has been one of the most rigorous and exhaustive of its type ever undertaken in Australia, and the authors, who are among Australia's leading marine environment consultants, have based their findings on the most relevant, current and authoritative information available.
Some specific claims refuted
1) Examples Inappropriate
The Healthy Waterways Taskforce claims SunAqua have used inappropriate (eg European) examples when estimating waste output and feed conversion rations.
But does that make the Taskforce’s own references to European examples inappropriate also? Or their grossly outdated references to historic feeding practices without the intelligent fish feeding system that SunAqua will be using?
Aquaculture in the northern hemisphere has been around a lot longer than in Australia, and it is perfectly appropriate to draw data and information from all over the world to assess the potential environmental, economic and social impacts of our proposal. After all, most of the best research and information on Aquaculture is funded and undertaken by industry, and much of it is unpublished.
SunAqua have based their proposal on world's best practice techniques.
2) Estimates Inaccurate
The taskforce claims that Sun Aqua's estimates of currents is 40% greater than other estimates and therefore its calculation of dilution is inaccurate.
The scale of the project will be entirely driven by input controls (Eg, the amount of nitrogen emitted) not the desired number of fish or cages. The EIS makes this clear, and it also makes clear that the facility will be subject to the most rigorous monitoring to ensure it does not exceed those levels.
3) Fish Escapes
The taskforce has said fish escapes have not been properly addressed.
The only escape they can be referring to is in South Australia, where media reports of escapes were grossly exaggerated, and the number and impact of the loss was overstated. The fact is that most of the fish were recovered, as they tend to become reliant on the shelter and feed and know no other way.
It is important to note that the South Australian example used nylon nets, and as a result of the escapes, they will move to steel cages, which render escapes virtually impossible.
SunAqua has explicitly stated in the EIS it will use steel cages. The risk of escape is almost zero, and even if fish were to be released into the wild, their genetic make-up will be impossible to distinguish from the wild stock, from which they were originally sourced as part of SunAqua’s proposed modification-free, disease free and vigorous policies on fingerlings.
In yet another example of abuse of process, the Healthy Waterways submission to the SunAqua EIS has been leaked to the media before SunAqua has even had a chance to read it.
What makes it worse are the erroneous and unscientific assertions it makes, which do the members of the panel little credit. For example:
The Healthy Waterways SEP has conveniently failed to recognise that the EIS is limited to two sites with development over a prolonged period, which will be subject to the most rigorous environmental monitoring possible – in fact, Healthy Waterways would be invited to be part of this ongoing monitoring and assessment.
It is critical to recognise the EIS is NOT for four sites, which their figures erroneously relate to, and this is a BASIC AND FUNDAMENTAL FACTUAL OVERSIGHT by a panel chosen for its scientific qualifications.
The SEP has ignored the fact that the EIS has argued for input controls to ensure nutrient outflows are constrained.
It is quite bizarre that in order to attack SunAqua, Healthy Waterways are promoting an attack on its own model. The model is owned by Healthy Waterways, and the custodian of the model, the EPA, specifically requested that SunAqua use it as it is the best available tool to assess impacts. If Healthy Waterways don’t like the result, that is not our problem.
By missing these fundamental points, the SEP has placed at risk the integrity of their submission.
Further, it is important to note that there are obvious differences of opinion among the SEP team. One SEP member, Rod Connolly, wrote,
“ The EIS contains a very thorough explanation of the biology behind fish farming practices…the proponents are aiming for a high standard of fish culturing, and the farming objectives planned for the site are well considered from a biological perspective.”
And one of the key members of the SEP team, Mr Tony McAlister, was part of the WBM Oceanics team that put the EIS together.
While others choose to continually abuse process, SunAqua will be dealing in extensive scientific detail with all submissions as part of the EIS supplementary report, which we are required to submit to the Coordinator General.
The EIS process has been one of the most rigorous and exhaustive of its type ever undertaken in Australia, and the authors, who are among Australia's leading marine environment consultants, have based their findings on the most relevant, current and authoritative information available.
Some specific claims refuted
1) Examples Inappropriate
The Healthy Waterways Taskforce claims SunAqua have used inappropriate (eg European) examples when estimating waste output and feed conversion rations.
But does that make the Taskforce’s own references to European examples inappropriate also? Or their grossly outdated references to historic feeding practices without the intelligent fish feeding system that SunAqua will be using?
Aquaculture in the northern hemisphere has been around a lot longer than in Australia, and it is perfectly appropriate to draw data and information from all over the world to assess the potential environmental, economic and social impacts of our proposal. After all, most of the best research and information on Aquaculture is funded and undertaken by industry, and much of it is unpublished.
SunAqua have based their proposal on world's best practice techniques.
2) Estimates Inaccurate
The taskforce claims that Sun Aqua's estimates of currents is 40% greater than other estimates and therefore its calculation of dilution is inaccurate.
The scale of the project will be entirely driven by input controls (Eg, the amount of nitrogen emitted) not the desired number of fish or cages. The EIS makes this clear, and it also makes clear that the facility will be subject to the most rigorous monitoring to ensure it does not exceed those levels.
3) Fish Escapes
The taskforce has said fish escapes have not been properly addressed.
The only escape they can be referring to is in South Australia, where media reports of escapes were grossly exaggerated, and the number and impact of the loss was overstated. The fact is that most of the fish were recovered, as they tend to become reliant on the shelter and feed and know no other way.
It is important to note that the South Australian example used nylon nets, and as a result of the escapes, they will move to steel cages, which render escapes virtually impossible.
SunAqua has explicitly stated in the EIS it will use steel cages. The risk of escape is almost zero, and even if fish were to be released into the wild, their genetic make-up will be impossible to distinguish from the wild stock, from which they were originally sourced as part of SunAqua’s proposed modification-free, disease free and vigorous policies on fingerlings.