FOI 161108 - Document 1
Submission
no:
2
Ack: 3/8/06
DRAFT VARIATION TO THE NATIONAL ENVIRONMENT PROTECTION
(NATIONAL POLLUTANT INVENTORY) MEASURE
SUBMISSION
Title: S.47F
Name: S.47F
Position: Environment Officer
Company: Horizon Power
Postal Address: PO Box 79
Suburb: Cloverdale
State: WA
Postcode: 6985
Telephone: 08 9441 S.47F
Facsimile: 08 9441 3409
Email address: S.47F
@horizonpower.com.au
DRAFT VARIATION
GENERAL COMMENTS
Part 1 - Preliminary
Part 2 – National Environment Protection Goals
Part 3 – National Environment Protection Protocols
Part 4 – National Environment Protection Guidelines
IMPACT STATEMENT
GENERAL COMMENTS
1.
Introduction
Page 1
S.47F
- Horizon Power,
2.
Statement of the problem
3. Transfers
S.22
4. Greenhouse
gases
S.22
5.
Other proposed NEPM amendments
All sound reasonable. I would especially like to comment on the inclusion of particulate matter
2.5 (pm2.5) and aquaculture. With recent research into the detrimental health effects of
smaller particals, it would be irresponsible to exclude this new substance. The sensitive
nature of marine, estuarine and freshwater ecosystems is recognised by erasing the
exemption of aquaculture farms from NPI reporting.
6. NEPM
implementation
7. Consultation
Page 2
Submission
FOI 161108 - Document 2
no:
6
Ack 31/8
DRAFT VARIATION TO THE NATIONAL ENVIRONMENT PROTECTION
(NATIONAL POLLUTANT INVENTORY) MEASURE
SUBMISSION
Title: S.47F
Name: S.47F
Position: Director
Company: EECO P/L
Postal Address: PO Box 257
Suburb: Indooroopilly
State: Q
Postcode: 4068
Telephone: 073700S.47F
Facsimile: 0733743703
Email address: x.xxx@xxxx.xxx.xx
DRAFT VARIATION
GENERAL COMMENTS
S.22
Part 1 - Preliminary
Part 2 – National Environment Protection Goals
Part 3 – National Environment Protection Protocols
Part 4 – National Environment Protection Guidelines
Page 1
S.47F
- EECO P/L,
Part 4 – National Environment Protection Guidelines IMPACT STATEMENT
GENERAL COMMENTS 1. Introduction
2.
Statement of the problem
3. Transfers
S.22
4. Greenhouse
gases
5.
Other proposed NEPM amendments
s 22
Include aquaculture - agree.
6. NEPM
implementation
S.22
7. Consultation
Page 2
Submission
FOI 161108 - Document 3
no:
15
12/9/06
DRAFT VARIATION TO THE NATIONAL ENVIRONMENT PROTECTION
(NATIONAL POLLUTANT INVENTORY) MEASURE
SUBMISSION
Title: S.47F
Name: S.47F
Position: Coast and Marine Facilitator
Company: Conservation Council of SA
Postal Address: 120 Wakefield St
Suburb: Adelaide
State: SA
Postcode: 5000
Telephone: (08) 8223 S.47F
Facsimile: (08) 8232 4782
Email address: S.47F
@ccsa.asn.au
DRAFT VARIATION
GENERAL COMMENTS
Part 1 - Preliminary
Part 2 – National Environment Protection Goals
Part 3 – National Environment Protection Protocols
Clause 9(7)(e)(iii) I fully support this clause that removes the exemption for Aquaculture
reporting
Part 4 – National Environment Protection Guidelines
IMPACT STATEMENT
GENERAL COMMENTS
1.
Introduction
Page 1
S.47F
- Conservation Council of SA,
2.
Statement of the problem
3.
Transfers
4.
Greenhouse
gases
5.
Other proposed NEPM amendments
6.
NEPM
implementation
7.
Consultation
Page 2
FOI 161108 - Document 4
Submission
no:
16
14/9/06
DRAFT VARIATION TO THE NATIONAL ENVIRONMENT PROTECTION
(NATIONAL POLLUTANT INVENTORY) MEASURE
SUBMISSION
Title:S.47F
Name: S.47F
Position: Conservation & Education Officer
Company: Whale and Dolphin Conservation Society
Postal Address: P.O. Box 720 Port Adelaide Business Centre
Suburb: Port Adelaide
State: SA
Postcode: 5015
Telephone: 08 8440 S.47F
Facsimile: 08 8447 4211
Email address: S.47F
@wdcs.org
DRAFT VARIATION
GENERAL COMMENTS
Part 1 - Preliminary
Part 2 – National Environment Protection Goals
Part 3 – National Environment Protection Protocols
Clause 9(7)(e)(iii) I fully support this clause that removes the exemption for Aquaculture
reporting
Part 4 – National Environment Protection Guidelines
IMPACT STATEMENT
GENERAL COMMENTS
1.
Introduction
Page 1
S.47F
- Whale and Dolphin Conservation Society,
2.
Statement of the problem
3. Transfers
4. Greenhouse
gases
5.
Other proposed NEPM amendments
6. NEPM
implementation
7. Consultation
Page 2
FOI 161108 - Document 5
Submission
no:
18
14/9/06
DRAFT VARIATION TO THE NATIONAL ENVIRONMENT PROTECTION
(NATIONAL POLLUTANT INVENTORY) MEASURE
SUBMISSION
Title: S.47F
Name: S.47F
Position: President
Company: Clean Air Society of Australia and New Zealand - Victoria / Tasmania Branch
Postal Address: C/O EML Air Pty Ltd, 425 Canterbury Road,
Suburb: Surrey Hills
State: Vic
Postcode: 3127
Telephone: (03) 9836S.47F
Facsimile: (03) 9836 0517
Email address: S.47F
@eml.com.au
DRAFT VARIATION
GENERAL COMMENTS
S.22
Part 1 - Preliminary
Part 2 – National Environment Protection Goals
S.22
Part 3 – National Environment Protection Protocols
S.22
Part 4 – National Environment Protection Guidelines
Page 1
S.47F
- Clean Air Society of Australia and New Zealand - Victoria / Tasmania Branch ,
IMPACT STATEMENT
GENERAL COMMENTS
S.22
1.
Introduction
2.
Statement of the problem
3.
Transfers
S.22
4.
Greenhouse gases
S.22
Page 2
S.47F
Clean Air Society of Australia and New Zealand - Victoria / Tasmania Branch ,
4.
Greenhouse gases
S.22
5.
Other proposed NEPM amendments
S.22
S.22
S.22
Page 3
S.47F
Clean Air Society of Australia and New Zealand - Victoria / Tasmania Branch ,
5.
Other proposed NEPM amendments
S.22
Removal of the Aquaculture Exemption: This is supported on the grounds of leading to water
quality problems and impacts on water supplies and on aquatic species and organisms
gaining a more complete understanding of the nutrient loads being emitted into receiving
water by this industry and the potential to harm waterway health CASANZ supports the
removal of the exemption or aquaculture.
S.22
6.
NEPM implementation
S.22
S.22
S.22
S.22
S.22
Page 4
S.47F
Clean Air Society of Australia and New Zealand - Victoria / Tasmania Branch ,
6.
NEPM implementation
S.22
7.
Consultation
Page 5
FOI 161108 - Document 6
Submission
no:
21
14.9.06
DRAFT VARIATION TO THE NATIONAL ENVIRONMENT PROTECTION
(NATIONAL POLLUTANT INVENTORY) MEASURE
SUBMISSION
Title:S.47F
Name: S.47F
Position: Marine Biologist
Company: Aluna, Marine Education and Experience
Postal Address: PO Box 282
Suburb: American River
State: SA
Postcode: 5221
Telephone: 08 8553 S.47F
Facsimile:
*Email address S.47F @kin.net.au
DRAFT VARIATION
GENERAL COMMENTS
Part 1 - Preliminary
Part 2 – National Environment Protection Goals
Part 3 – National Environment Protection Protocols
Clause 9(7)(e)(iii) I fully support this clause that removes the exemption for Aquaculture
reporting
Part 4 – National Environment Protection Guidelines
IMPACT STATEMENT
GENERAL COMMENTS
1.
Introduction
Page 1
Error! Reference source not found.-
Error! Reference source not found.,
2.
Statement of the problem
3. Transfers
4. Greenhouse
gases
5.
Other proposed NEPM amendments
6. NEPM
implementation
7. Consultation
Page 2
FOI 161108 - Document 7
Submission
no:
28
15/9/06
DRAFT VARIATION TO THE NATIONAL ENVIRONMENT PROTECTION
(NATIONAL POLLUTANT INVENTORY) MEASURE
SUBMISSION
Title: s 22
Name: s 22
Position: Senior Adviser, Environment Policy
Company: Chamber of Commerce and Industry WA
Postal Address: 6209
Suburb: EAST PERTH
State: WA
Postcode: 6892
Telephone: 08 9365 s 22
Facsimile: 08 9365 7550
Email address: s 22
@cciwa.com
DRAFT VARIATION
GENERAL COMMENTS
s 22
s 22
Part 1 - Preliminary
Page 1
s 22
- Chamber of Commerce and Industry WA,
Part 2 – National Environment Protection Goals
s 22
Part 3 – National Environment Protection Protocols Part 4 – National Environment Protection Guidelines IMPACT STATEMENT
GENERAL COMMENTS 1. Introduction
2.
Statement of the problem
3. Transfers
s 22
4. Greenhouse
gases
Page 2
s 22
- Chamber of Commerce and Industry WA,
4. Greenhouse
gases
s 22
5.
Other proposed NEPM amendments
CCI does not object in principle to other substantial amendments proposed in the draft variation:
s 22
- removing exemption for aquaculture reporting
s 22
6. NEPM
implementation
s 22
7. Consultation
s 22
Page 3
FOI 161108 - Document 8
Submission
no:
33
Aquaculture Licensee Ack 15/9/06
Committee
15 September 2006
s 22
Dear s 22
,
Draft Variation to the National Environment Protection (National Pollutant
Inventory) Measure: Removal of Exemption for Aquaculture Reporting
The Aquaculture Committee of the Northern Territory Seafood Council has a number
of objections to the inclusion of aquaculture in the National Pollutant Inventory. These
are as follows;
1.
Aquaculture in the Northern Territory is an industry in the very early stages of its
development. Businesses wishing to establish aquaculture operations undergo
severe scrutiny by various government departments and by the public to ensure
that the proposed venture is environmentally sound. After passing over this
expensive and time consuming series of hurdles, aquaculture enterprises are also
obliged to provide updated environmental management plans on a regular basis.
Further checks on environmental performance include various licences such as
waste discharge licences which must be applied for on a regular basis (usually
annually). These licences also carry obligations, including regular monitoring and
analysis of a large range of water quality parameters, the costs of which are borne
by the businesses.
2.
A further time impost in the form of yet another set of reporting requirements as
proposed under the draft variation to the National Environment Protection
(National Pollutant Inventory) Measure is seen as counterproductive for an
industry whose businesses quite frankly have almost no capacity to comply with
much more regulation.
3.
It is commonly recognised within the aquaculture industry that we are highly
regulated and under the continuing spotlight of public and government scrutiny.
Much of this scrutiny is a result of bad publicity from the rapid expansion of
aquaculture in developing countries such as Thailand, Indonesia, Venezuela and
so on.
Supported by the
ABN 85 918 271 276
Located on Fishermans Wharf, Frances Bay, Darwin
GPO Box 618 Darwin NT 0801~ Telephone 08 8981 S.47F ~ Facsimile 08 8981 5063 ~ Email S.47F
@ntsc.com.au
There is almost nothing in common between the aquaculture industries in these
countries and in Australia. Ever since Australia began its modern aquaculture in
the 1980's there have been stringent controls a world away from the laissez faire
development in many other countries.
4.
The proposed annual discharge level of 15 tonnes of nitrogen and/or 4 tonnes
phosphorous into the environment would be reached by a farm whose size would
require the employment of as few as two or three people to operate it. This is a
small business enterprise which does not have the resources of larger businesses to
be able to comply with further regulatory imposts. Before imposing further
regulation on and scrutiny of the aquaculture industry in the Northern Territory,
we believe that the Environmental Protection Heritage Council should consult
with industry to gain a greater appreciation of the effects on these small businesses
of the proposed regulation.
5.
There is very little information about the fate of nitrogen and phosphorus released
from farms. From a scientific perspective, the fate of nitrogen and phosphorus in
the receiving waters in tropical estuaries is unknown. For this reason alone,
inclusion of aquaculture would seem premature and inappropriate.
Committee members are adamant in their conviction that the degree of monitoring,
scrutiny and regulation imposed on the aquaculture industry generally is often totally
disproportionate to the reality of aquaculture in Australia. The proposed regulation
governing nitrogen discharge into the environment is one such example and we
strongly recommend that it is not proceeded with.
Kind Regards,
Adam Body
Chairman
FOI 161108 - Document 9
Submission
no:
46
15/9/06
A. P. F. A.
15th September 2006
To whom it may concern:
SUBMISSION ON THE PROPOSAL TO REMOVE THE REPORTING
EXEMPTION OF AQUACULTURE FROM THE NPI
Recently the Association attended a meeting held in Brisbane on the NPI proposal to
remove aquaculture from exemption from reporting. This has been the only
consultation we have received. We believe that with such a serious, and what appears
to be misinformed proposal, direct consultation with the Association should occur.
We endorse the submission of the National Aquaculture Council, and share the
concerns raised within it.
Most importantly we are concerned that this proposal is in direct conflict with the
Australian Governments commitment to reduce the currently costly red tape imposed
on the aquaculture industry as outlined in the Aquaculture Action Agenda.
The Australian prawn farming industry already undertakes a detailed reporting
process on our emissions to the relevant State and Territory Governments and in some
cases the Great Barrier Reef Marine Park Authority. Adding the NPI to this is just
unnecessary duplication.
Justification for the removal of the current exemption has also been of concern. “Why
not?” is not good enough. Reporting in Government documents that aquaculture
facilities are similar to sewerage treatment plants is completely unjustified and
potentially damaging to our industries reputation.
The Association has a very strong relationship with the Department through our eco-
efficiency agreement, and has had extremely successful outcomes in the project we
are undertaking as a part of that agreement. One prawn farm is undertaking
accreditation for their EMS to ISO14001 next week, with another four to follow. The
industry is also currently exploring the possibilities of rolling this level of EMS out
across the entire industry.
This proposal has the potential to undo much of the good work that has been achieved
by both industry and the Australian Government and the Australian Prawn Farmers
Association strongly opposes it. We request that the current exemption be maintained.
Yours Faithfully,
Scott Walter
EXECUTIVE OFFICER
AUSTRALIAN
PRAWN
FARMERS
ASSOCIATION
PO Box 12009, George Street, BRISBANE QLD 4003
Phone: 07 3837 4777
Facsimile: (07) 3236 4100
Submission
FOI 161108 - Document 10
no:
47
15/9/06
14th September 2006
s 22
Senior Project Officer
National Pollution Inventory
DEH
GPO Box 787
Canberra ACT 2601
xxxx@xxxx.xxx.xx
s 22
@dddeh.gov.au
xxx@xxx.xxx.xx
To whom it may concern
The National Aquaculture Council is the peak body representing the industry in Australia. It
represents at least 98% of the gross value of production.
The comments below follow broad consultation with the aquaculture industry and some government
agencies across Australia.
Consultation
At no stage has the industry been consulted in understanding the implications of transfers especially
the costs. It is very clear that those responsible for the documentation have absolutely no idea how
the various production systems operate in their respective sectors and environments and associated
cost structure in measuring transfers and other parameters.
Not only have they miscalculated the cost structure but hey have no understanding of the variability
within the industry and this is also reflected in their quoted figure of around 60 aquaculture licences
that will be affected by this process.
It has been made clear by the NPI panel members at the public meetings that there is no onus on the
NPI to demonstrate why the aquaculture industry should not be exempt. In fact it is up to industry to
demonstrate why it should be excluded. This letter provides that rationale. It should also be
remembered that through the Aquaculture Industry Action Agenda and the Prime Ministers Science
Engineering and Innovation Council on aquaculture there was an imperative to reduce the
regulative burden and red tape that was imposed on the aquaculture industry. The industry is one of
the most regulated in Australia and this has been identified as a serious financial impost on
producers and also a deterrent to investment in the industry.
The Federal and State Governments and industry produced the
Best Practice Framework of
Regulatory Arrangements for Aquaculture in Australia (Primary Industries Ministerial Council)
February 2005 that highlighted the need to refine reporting processes and reduce the cost to
industry.
The Productivity Commission in their inquiry into the Australian aquaculture industry also
emphasized the need to reduce red tape and reporting burdens on the industry.
The comment by members of the NPI road show that prawn farms in Australia are similar to
sewerage farms is nothing short of showing a complete lack of understanding of Australian prawn
farming production technology and aquaculture in general. To actually put these types of references
to print without qualifying such statements demonstrates the level of arrogance by this group and
their lack of credibility. No distinction is made between Australian practices and those of some
international counterparts.
It is clear there will be significant duplication in industry having to report to various agencies as
well as the NPI. Industry is of the view that access to any data must be through the relevant state
agency to which industry must report and comply concerning appropriate agreed key environmental
indicators as per their licences.
There is a strong view from industry that it would not be too long before the list was expanded to
incorporate other parameters that need to be measured. Such creep is being observed in other
sectors.
It is a pity that the TAP of this process has used one or two submissions from the 2005 review to
push the inclusion of aquaculture in the NPI. These submissions have demonstrated their lack of
understanding of the industry and consequently the process has adopted misinformation on which to
base its decision of inclusion.
Data Interpretation
People accessing data will not be able to understand the context in which it is provided. This will
lead to certain groups using their own interpretation that in turn could easily misrepresent the
industry and its sustainable approach to production of seafood.
The industry is seriously concerned that the Government is now going back on its commitment of
reducing the impost of these bureaucratic processes on industry and does not fit with the spirit and
intent of the Action Agenda and its key outcomes.
The industry has in good faith and in partnership with Government developed an EMS based
reporting process to State agencies based on the Fisheries Research and Development Corporation
ESD framework for aquaculture. This is a cost effective mechanism to industry and Government.
Transfers
Estimating and reporting transfers is a complicated and expensive exercise when dealing with an
aquatic environment as there are numerous influences concerning seasonal change and natural
organic and inorganic loadings in the various aquatic systems. It must be understood that nitrogen
and phosphorous reactions in salt and freshwater environments are quite different.
It is clear to the industry that there is lack of any science or risk assessment that underpins decisions
and this is completely unprofessional given the circumstances. Decisions to include aquaculture
have been based on anecdotal information and an attitude from the NPI of “why not include it?”
Compliance
There is limited detail available from those jurisdictions that will be responsible for enforcement
costs or processes. To believe you have an understanding of impacts on industry without taking this
into consideration is ludicrous. What is even more unbelievable is the expectation that local
jurisdictions will enforce compliance at the rates calculated. A number of the State jurisdictions
consulted have indicated that they have no intention of following through on this duplicated
process.
At the public forums the panel has argued that:
x
this information will lead to better Government decisions. As it applies to aquaculture,
particularly the prawn and finfish sectors, this is nonsense and is not demonstrated.
x
the public have a right to know. Again without understanding the circumstances, knowing
the context in which data is collected and how it should be interpreted, this information will
be meaningless to the public.
The industry has developed other public reporting processes. These are done in conjunction with
State and Federal jurisdictions. Compliance with the EPBC guidelines for aquaculture through the
Department of Environment and Heritage is a case in point.
The industry is vehemently opposed to the inclusion of aquaculture into the NPI process and
requests continued exemption.
Thank you for your assistance in this matter.
Yours faithfully
Simon Bennison
Chief Executive Officer
CC
Senator the Hon. Eric Abetz,
Senator the Hon. Ian Macdonald
Senator the Hon. Nigel Scullion
Senator the Hon Ron Boswell
Joanna Hewitt
FOI 161108 - Document 11
Submission
54
18/9/06
15 September 2006
National Environmental Protection Council
Level 5
81 Flinders Street
Adelaide SA 5000
Australia
To whom it may concern
Re: Submission on the draft variation to the National Environmental Protection Measure.
The Aquaculture Council of Western Australia (ACWA), the State’s peak industry body, would like to thank
National Environmental Protection Council on its invitation to comment on the
draft variation to the National
Environmental Protection Measure
It is ACWA position that the aquaculture industry should remain exempt. The rationale for this position is as
follows:
x
All the risks, reporting methods and the community benefits are managed already by the State agencies;
as such there is no need to duplicate these processes. Business exists to make a profit; part of this
process is ensuring costs are controlled through minimizing duplication. The proposed NPI duplicates
reporting requirements of the states (both to DEC & Fisheries),
x
There have been no breaches of the current arrangements.
x
All of the industry environmental monitoring reporting is publicly available.
x
The reporting of gross N & P has no value, as it has no regional context to make an informed evaluation.
This is what the State regulations provided.
x
Aquaculture is fundamentally different to other intensive industries, in that its business objectives cannot
be achieved without maintaining high water and environmental quality. Given this innate connection with
the environment evolves a deep commitment to developing the industry responsibly.
Added to the above specific comments, ACWA would like to make a general comment of quality of the public
policy. The document, as promulgated, constitutes one of the laziest pieces of public policy that ACWA has
dealt with, and does reflect the standing the National Environmental Protection Council. The claims made
against aquaculture are unsubstantiated. If the council had bothered to undertake some basic research it would
had proved the statements untrue eg. Sewage equivalence of aquaculture discharge. It is on this basis, the
document needs to be retracted, revised, and an apology made to the aquaculture industry.
We look forward to your earliest favorable response.
Yours sincerely
Dan Machin
CEO
PO Box 55, Mt Hawthorn WA 6915
Suite 7 41 Walters Drive Osborne Park WA 6016
t 9492 S.47F f 9244 2934 e xxxx@xxxxx.xxx.xx
www.AquacultureCouncilWA.com
FOI 161108 - Document 12
Submission
no:
55
18/9/06
DRAFT VARIATION TO THE NATIONAL ENVIRONMENT PROTECTION
(NATIONAL POLLUTANT INVENTORY) MEASURE
SUBMISSION
Title: Ms
Name: Megan Kessler
Position: Fisheries and Marine Networker
Company: Nature Conservation Council of NSW
Postal Address: Level 2, 301 Kent St
Suburb: Sydney
State: NSW
Postcode: 2000
Telephone: 02 9279 S.47F
Facsimile: 02 9279 2499
Email address: S.47F
@nccnsw.org.au
DRAFT VARIATION
GENERAL COMMENTS
Part 1 - Preliminary
Part 2 – National Environment Protection Goals
Part 3 – National Environment Protection Protocols
Clause 9(7)(e)(iii) I fully support this clause that removes the exemption for Aquaculture
reporting
Part 4 – National Environment Protection Guidelines
IMPACT STATEMENT
GENERAL COMMENTS
1.
Introduction
Page 1
Megan Kessler- Nature Conservation Council of NSW,
2.
Statement of the problem
3. Transfers
4. Greenhouse
gases
5.
Other proposed NEPM amendments
6. NEPM
implementation
7. Consultation
Page 2
FOI 161108 - Document 13
Submission
no:
59
19/9/06
s 22
Project Officer
NEPC Service Corporation
Level 5, 81 Flinders Street
ADELAIDE SA 5000
Dear s 22
I refer to the draft variation to the National Pollutant Inventory (NPI) National Environment
Protection Measure that has been released for public consultation. I am writing in relation to the
variation proposal to remove the NPI reporting exemption for aquaculture.
The Department of Agriculture, Fisheries and Forestry (DAFF) stresses that a variation to the NPI
relating to aquaculture must be pursued consistent with the Government’s existing policy on
aquaculture industry development and regulation. It should be commensurate with the level of
environmental risk posed by the aquaculture industry and not impose additional, overlapping
regulatory burden.
The Australian aquaculture industry is diverse and each sector has different potential environmental
impacts of varying degrees of significance. The industry is subject to a comprehensive regulatory
framework to ensure sustainable development and sound environment management across the
industry.
The Australian Government has legislation and regulations to protect matters of national
environmental significance, promote ecologically sustainable development and ensure standards are
maintained in food safety, aquatic animal health, quarantine, trade and taxation. Aquaculture
activities that are likely to have a significant impact on matters of national significance are assessed
and subject to approval under the
Environment Protection and Biodiversity Conservation Act 1999.
State and territory governments are responsible for the day-to-day management of aquaculture.
They have legislation and controls in place covering environment management, marine and coastal
management, land use planning, land tenure, native title and quarantine and translocation. The
states and territories attach strict regulations and reporting requirements to aquaculture licenses,
including reporting on emissions from aquaculture operations. It is my understanding that data on
emissions from aquaculture operations is already available from state and territory agencies at an
aggregated level.
This regulation comes at a cost to industry and the Productivity Commission has suggested it has
gone too far. The Commission reviewed regulatory arrangements for aquaculture in 2004. A copy
of its research paper on
Assessing Environmental Regulatory Arrangements for Aquaculture is
available online at www.pc.gov.au/research/crp/aquaculture/aquaculture.pdf. The research covered
both marine and land-based aquaculture production in Australia.
Edmund Barton Building Barton ACT
GPO Box 858 Canberra ACT 2601
ph +61 2 6272 3933
www.daff.gov.au
ABN 24 113 085 695
D E P A R T M E N T O F A G R I C U L T U R E , F I S H E R I E S A N D F O R E S T R Y
The Productivity Commission review concluded that aquaculture production is subject to an
unnecessarily complex array of legislation and agencies. On environmental regulation in particular,
the Commission agreed that some environmental regulation is clearly required given the potential
for significant environmental impacts from some aquaculture operations. However, the report also
stresses that environmental regulatory arrangements that are unwarranted or poorly developed and
implemented can impose unnecessary costs on aquaculture producers, consumers and the
community, and adversely affect competitiveness and the environment. The Commission suggested
that more efficient and effective regulation of the aquaculture industry could be achieved through
greater use of environmental risk assessments.
The Productivity Commission also noted problems with comparing aquaculture with other
agricultural operations. It found that point source water pollution from land-based aquaculture, such
as prawn or trout farms, is often more heavily regulated than diffuse sources of pollution from other
land uses, such as pastoral or horticultural farming. This has implications for the efficient and
effective management of environmental impacts and the development of the aquaculture industry.
The Commission concluded there is a need for further research to assess if the level of regulation
and control is consistent with the environmental risk posed.
The Australian Government has made a number of commitments to help streamline and reduce
regulation of the aquaculture industry and encourage its development.
In 2002, the Aquaculture Industry Action Agenda (AIAA) was launched in partnership between
industry and governments to increase the growth prospects of the industry. The Australian
Government provided $3.5 million to support its implementation. The AIAA includes a
commitment to promote a regulatory and business environment that supports aquaculture. In
particular, DAFF and the Department of the Environment and Heritage (DEH) agreed to work with
state and territory governments to streamline aquaculture regulation and management in Australia
with the aim of ensuring an efficient and certain regulatory and planning environment for investors
and industry.
The AIAA led to the development of a National Aquaculture Policy Statement in 2003. The Policy
includes a commitment to develop an investment, policy and regulatory framework that encourages
industry growth. Australian governments also worked together to develop a
Best Practice
Framework of Regulatory Arrangements for Aquaculture in Australia in 2005 to reduce and
harmonise regulation of the aquaculture industry. The best practice framework captures the findings
of the Productivity Commission review and is currently being implemented.
I strongly encourage the National Environment Protection Council to consider these issues and
existing government commitments in finalising the NPI variation. Of particular concern is creating
additional and potentially unnecessary regulatory burden for the industry.
I suggest working closely with the state and territory aquaculture managers, who best understand
the industry and are the most likely to utilise NPI-type data. It may be possible to establish an
agreed standard or protocol for reporting with the states and territories to meet NPI needs without
indiscriminately imposing another layer of reporting and regulation. There is a precedent for this
between DEH, the Great Barrier Reef Marine Mark Authority and the Queensland government
where an accreditation arrangement was developed to ensure environmental risks of Queensland-
based aquaculture operations are managed consistent with national objectives.
The Australian aquaculture industry through its peak body the National Aquaculture Council should
also be closely engaged. Mr Simon Bennison, Chief Executive Officer, can be contacted on mobile
S.47F
or email xxx@xxxxxxxxxxx.xxx.xx.
The draft NPI variation relating to aquaculture represents new regulation for the industry, not just a
minor variation or amendment. Such a change calls for more rigorous consultation than has been
conducted to date. While I understand there have been public meetings, this consultation is largely
passive and not suitable in these circumstances. Many state and territory aquaculture agencies were
not aware of the proposed variation or public meetings until contacted by DAFF. The meetings
covered all stakeholders potentially affected by the NPI variation, from farmers through to the
manufacturing sector. Further discussions are required with states and territory agencies and the
aquaculture industry that is specifically about the potential impacts of the NPI variation for the
aquaculture industry and alternative arrangements.
Given the potential impacts for the Australian aquaculture industry, DAFF would like to remain
involved and informed of the NPI variation process. The Departmental contact for aquaculture
issues is s 22
, telephone 02 6272 s 22 , email s 22
@daff.gov.au. We would
be pleased to discuss these issues further.
Thank you for your consideration of this submission.
Yours sincerely
Glenn Hurry
Executive Manager
Fisheries and Forestry
15 September 2006
FOI 161108 - Document 14
Submission
no:
60
21/9/06
australian network of
environmental defender’s offices
Submission on the
National Pollutant Inventory
NEPM Variation
15th September 2006
The Australian Network of Environmental
EDO ACT (tel. 02 6247 9420)
xxxxxx@xxx.xxx.xx
Defender’s Offices (ANEDO) consists of nine
independently constituted and managed community
EDO NSW (tel. 02 9262 6989)
xxxxxx@xxx.xxx.xx
environmental law centres located in each State and
Territory of Australia.
EDO NQ (tel. 07 4031 4766)
xxxxx@xxx.xxx.xx
Each EDO is dedicated to protecting the
environment in the public interest. EDOs provide
EDO NT (tel. 08 8982 1182)
xxxxx@xxx.xxx.xx
legal representation and advice, take an active role in
environmental law reform and policy formulation,
EDO QLD (tel. 07 3210 0275)
xxxxxx@xxx.xxx.xx
and offer a significant education program designed to
facilitate public participation in environmental
EDO SA (tel. 08 8410 3833)
xxxxx@xxx.xxx.xx
decision making.
EDO TAS (tel. 03 6223 2770)
xxxxxx@xxxxx.xxx.xx
EDOVIC (tel. 03 9328 4811)
xxxxxx@xxx.xxx.xx
EDO WA (tel. 08 9221 3030)
xxxxx@xxx.xxx.xx
1
This submission is on behalf of the Australian Network of Environmental Defender’s
Offices (ANEDO).
For further information on this submission, please contact Rachel Walmsley, Policy
Director at EDO (NSW) on 02 9262 6989 or xxxxxx.xxxxxxxx@xxx.xxx.xx.
Submitted to:
s 22
Project Officer
NEPC Service Corporation
Level 5, 81 Flinders Street
Adelaide SA 5000
Telephone (08) 8419 s 22
Facsimile (08) 8224 0912
Email s 22
@ephc.gov.au
15th September 2006
2
s 22
1.
3
Introduction
s 22
Major changes to the NPI proposed in the documentation include:
x
s 22
x
removing the exemption for aquaculture reporting; and
x
s 22
s 22
s 22
s 22
s 22
s 22
s 22
4
s 22
5
s 22
6
s 22
7
s 22
8
s 22
9
s 22
10
s 22
11
s 22
12
s 22
13
s 22
6.
Reporting of aquaculture activities
ANEDO is fully supportive of the proposal to include aquaculture in the list of reporting
industries. The known environmental impacts of aquaculture and the resultant emissions
from aquaculture operations do not justify its continuing exclusion as a reporting
industry.
The potential impacts of aquaculture are wide-ranging, from aesthetic aspects to direct
pollution problems.40 The National Oceans Office has recognised these potential
environmental consequences.41 In particular, aquaculture operations lead to the release of
nutrients into the water column and the accumulation of waste. This additional input
leads to an accumulation of organic matter, which has a marked effect on water quality
and benthic biota.42 Furthermore, there are concerns about the use of
s 22
.
40 Fernandes, Eleftheriou, Ackefors, Eleftheriou, Ervik, Sanchez Mata, Scanlon, White, Cochrane,
Pearson, Read (2001), ‘The scientific principles underlying the monitoring of the environmental impacts of
aquaculture’.
Journal of Applied Ichthyology 17.
41 National Oceans Office, ‘
Impact of aquaculture’
http://www.oceans.gov.au/impacts aquaculture/page 004.jsp (23 August 2006).
42 State of the Environment Report, South Australia 2003 at 64.
14
chemotherapeutants, the outbreak of disease, the impact of marine mammals and genetic
disturbance from exotic species.
Table 4 Current environmental concerns arising from marine aquaculture operations
(Fernandes et al.,
2001)
As indicated in the NPI Review Report, a diffuse source manual already exists for
aquaculture. Therefore, the practical implications stemming from the inclusion of
aquaculture as a reporting industry are straightforward and do not impose an onerous
regulatory burden. It is a small price to pay when the environmental consequences of
aquaculture operations can be quite significant. Requiring the aquaculture industry to
report its emissions enables the public and government to quantify the environmental
impact of these emissions. This is in line with the environmental management and public
participation goals of the NEPM.
s 22
15
s 22
16
s 22
17
s 22
9.
Conclusion: Do these amendments further the goals of NEPM?
s 22
s 22
Moreover, the addition of
aquaculture as a reporting industry, the inclusion of transfers, the attempts to improve
data quality and the updating and consolidation of the diffuse source register will also
provide the potential to further realise the goals of the NPI. s 22
s 22
18
FOI 161108 - Document 15
Submission
no:
66
21/9/06
WA DEPARTMENT OF ENVIRONMENT AND CONSERVATION
(DEC)
Draft Variation to National Environment Protection (National Pollutant
Inventory) Measure
SUBMISSION
s 22
T:\NEPM\NPI Variation 2005\Submissions\Sub 66_s 22
_CED WA.doc 22/09/2006 2:41:34 PM
1
s 22
T:\NEPM\NPI Variation 2005\Submissions\Sub 66_s 22
_CED WA.doc 22/09/2006 2:41:34 PM
2
s 22
T:\NEPM\NPI Variation 2005\Submissions\Sub 66_s 22
_CED WA.doc 22/09/2006 2:41:34 PM
3
s 22
6.
Removal of exemption for aquaculture
DEC supports the removal of the exemption from reporting for aquaculture, as this
industry is capable of contributing significant nutrient loads to the environment. WA
has a growing aquaculture industry.
s 22
T:\NEPM\NPI Variation 2005\Submissions\Sub 66_s 22
_CED WA.doc 22/09/2006 2:41:34 PM
4
s 22
T:\NEPM\NPI Variation 2005\Submissions\Sub 66_s 22
CED WA.doc 22/09/2006 2:41:34 PM
5
s 22
T:\NEPM\NPI Variation 2005\Submissions\Sub 66_s 22
_CED WA.doc 22/09/2006 2:41:34 PM
6
s 22
T:\NEPM\NPI Variation 2005\Submissions\Sub 66_s 22
_CED WA.doc 22/09/2006 2:41:34 PM
7
s 22
T:\NEPM\NPI Variation 2005\Submissions\Sub 66_s 22
CED WA.doc 22/09/2006 2:41:34 PM
8
s 22
T:\NEPM\NPI Variation 2005\Submissions\Sub 66_s 22
CED WA.doc 22/09/2006 2:41:34 PM
9
s 22
T:\NEPM\NPI Variation 2005\Submissions\Sub 66_s 22
CED WA.doc 22/09/2006 2:41:34 PM
10
s 22
T:\NEPM\NPI Variation 2005\Submissions\Sub 66_s 22
CED WA.doc 22/09/2006 2:41:34 PM
11
s 22
T:\NEPM\NPI Variation 2005\Submissions\Sub 66_s 22
CED WA.doc 22/09/2006 2:41:34 PM
12
FOI 161108 - Document 16
Submission
no:
67
21/9/06
19 September 2006
s 22
Project Officer
NEPC Service Corporation
Level 5, 81 Flinders Street
ADELAIDE SA 5000
Dear s 22
s 22
Of the main issues covered in the NPI variation including:
s 22
x
removing the exemption for aquaculture reporting
s 22
s 22
We have not made comment on the substance and threshold changes,
removing the exemption for aquaculture reporting and changes to publication
requirements. s 22
s 22
AEBN’s Submission on the National Pollutant Inventory NEPM Variation, September 2006
page 1
s 22
AEBN’s Submission on the National Pollutant Inventory NEPM Variation, September 2006
page 2
s 22
AEBN’s Submission on the National Pollutant Inventory NEPM Variation, September 2006
page 3
s 22
Yours Sincerely
ANDREW DOIG
Director
AUSTRALIAN ENVIRONMENT BUSINESS NETWORK
AEBN’s Submission on the National Pollutant Inventory NEPM Variation, September 2006
page 4
Submission:
FOI 161108 - Document 17
72
25/9/06
ACN 44 000 292 713
21 September, 2006
HEAD OFFICE
GPO BOX 2201
CANBERRA ACT 2601
s 22
Project Officer
LEVEL 3
NEPC Service Corporation
24 MARCUS CLARKE STREET
Level 5, 81 Flinders Street
CANBERRA ACT 2600
PHONE 61 2 6247 0960
Adelaide SA 5000
FAX 61 2 6247 0548
Dear s 22
,
PERTH OFFICE
PO BOX 7039
Draft Variation to the National Environmental Protection
CLOISTERS SQUARE
PERTH WA 6850
(National Pollutant Inventory) Measure
LEVEL 1
s 22
190 ST GEORGES TERRACE
PERTH WA 6000
PHONE 61 8 9321 9775
FAX 61 8 9321 9778
INTERNET
http://www.appea.com.au
EMAIL
xxxxx@xxxxx.xxx.xx
s 22
APPEA
also supports the inclusion of aquaculture reporting on the basis that all
significant sources of emissions, whether natural, diffuse or industrial should
be included to ensure the integrity of reporting system, and provide the
most accurate information and context to the community. To this end,
APPEA would encourage further measures to provide the community and
regulators with a full picture of emissions to the environment and ensure
emissions beyond those of industry are accurately reflected in the NPI.
s 22
s 22
2
s 22
Yours sincerely,
BELINDA ROBINSON
CHIEF EXECUTIVE
3
FOI 161108 - Document 18
Submission:
74
25/9/06
s 22
s 22
s 22
FOI 161108 - Document 19
Submission
no:
ExxonMobil Australia Submission to the EPHC re the Draft NPI NEPM - September 2006
75
E
26/9/06
XXONMOBIL SUBMISSION RE THE DRAFT VARIATION TO THE NATIONAL ENVIRONMENT
PROTECTION (NATIONAL POLLUTANT INVENTORY) MEASURE
OVERVIEW:
s 22
ExxonMobil's responses to the key issues raised in the June 26th Regulatory Impact Statement (RIS)
and Draft Variation to the National Environment Protection (National Pollutant Inventory) Measure
can be summarised as follows.
s 22
i ExxonMobil supports the removal of the exemption for aquaculture reporting, on the basis that all
significant sources of emissions should be included to ensure the integrity of reporting system.
s 22
Sub 75 Geoff Davis Exxon Mobil
22 September 2006
1
s 22
ExxonMobil Contact:
Geoff Davis
Global Environmental Advisor
ExxonMobil Australia Pty Ltd
PO Box 484
Altona
Victoria 3018
Telephone: 03
9286S.47F
Fax:
03 9286 5233
Email:
S.47F
@exxonmobil.com
Sub 75 s 22, S.47F
Exxon Mobil
22 September 2006
2
ExxonMobil Australia Submission to the EPHC re the Draft NPI NEPM - September 2006
s 22
Sub 75 S.47F
Exxon Mobil
22 September 2006
3
ExxonMobil Australia Submission to the EPHC re the Draft NPI NEPM - September 2006
s 22
Sub 75 S.47F
Exxon Mobil
22 September 2006
4
