5.
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Flora and Fauna impacts (off-site)
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Impacts on marine life in the Harbour have barely
been considered in the PER. This is particularly inadequate given
the high conservation values in the Harbour and the presence
of threatened species such as the Irrawaddy Dolphin and the Indo-Pacific
dolphin. No attention has been given to the potential impacts
on other cetaceans, turtles, seagrass, corals and other important
marine habitat.
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The PER indicates that wastewater containing
phosphorous and nitrogen may be released into the Blackmore River
with potential downstream effects. The level of nitrogen which
may be released is calculated as 27kg per day in some circumstances.
This is equivalent to the nitrogen in human sewage from over
2000 people. (An average human produces around 11-12g of nitrogen
in bodily wastes per day [Folke et al (1994) The costs of eutrophication
from Salmon farming: Implications for policy. Journal of Environmental
management 40, 173-182]).
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Given that it is possible to operate zero nutrient
release prawn farms, any aquaculture developments in the Northern
Territory should be required to operate closed systems that do
not input nutrients to waterways. This is particularly important
given that the development of an aquaculture industry in the
Darwin region could result in high cumulative impacts on top
of other nutrient inputs. While the nutrient release from 1 operation
may be acceptable, cumulative impacts of a several operations
may not.
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6.
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The scale of the project
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If this project proceeds in full it would be
one of the largest aquaculture developments in Australia. Given
our inexperience with and lack of regulation of aquaculture in
the Northern Territory we should be laying the groundwork before
we rush into major aquaculture developments. Most of the impacts
associated with the development are related to its predicted
size. The staged approach to development does not alleviate concerns
about the impacts of the project given that there does not appear
to be any intention to undertake a comprehensive public environmental
impacts assessment and review process after several years of
operations of Stage 1 and prior to development of Stage 2.
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ECNT recommends that the Minister consider the
PER in the context of Stage 1 of the development, and require
further environmental impact assessment and review prior to any
development of Stage 2.
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7.
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Project monitoring and regulation
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Sections 5.4 & 5.5 of the PER dealing with monitoring
and decommissioning lacked detail. For example it is unclear
whether water quality results will be made public. Water quality
monitoring should be undertaken by an independent agency and
all results should be publicly available. Monitoring should be
undertaken on a continuous rather than intermittent basis.
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Decommissioning and rehabilitation- Whilst the
PER does acknowledge the responsibility of the developer to rehabilitate
the site following operations it does not provide any provision
for ensuring that this occurs.
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A number of aquaculture ventures including
prawn farms in the Northern Territory have collapsed shortly
after establishment and been abandoned by their owners. The taxpayer
is then left to pick up the tab of rehabilitation, if, in fact,
any rehabilitation is carried out. This is unacceptable and developers
should be required to lodge a rehabilitation bond for all such
developments. Without a rehabilitation bond Government and Industry
are failing to safeguard the public interest.
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The Environment Centre recommends that the proponent
be required to lodge a bond equivalent to the total cost of rehabilitation
of the project and that this bond be held in trust by the government
to be returned upon completion of the project if full rehabilitation
is completed.
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