Minutes summary of Aquaculture meeting 28 Nov with industry reps to
discuss possible new regulatory approaches for water quality discharges
Meeting held at EHP 400 George 9th flr
Attendees:
Dean Raihman, Manager EHP ERPS (non-mining)
Andrew Harnden, Principal Environmental Officer, EHP ERPS (non-mining)
Marty and Linda Philips, Pejo Enterprises
Alistair Dick, President Australian Prawn Farmers Association (APFA)
Helen Jenkins, EP APFA
Chris Calogeras, EO ABFA
Intro
Dean:
-review of aquaculture discharge regulation in line with depts. move towards a risk based regulatory
approach for performance outcomes. This reflects the new EHP approach being applied for Qld
environmental regulation in general.
-can industry produce a ‘way forward’ proposal for consideration by the dept.
-can we find solutions for discharge regulation that are performance based without a major
legislative reform?
-coordination needed with Qld Department of Agriculture, Forestry and Fisheries (DAFF), Great
Barrier Reef Marine Park Authority (GBRMPA) also to re their jurisdictions
Discussion
Alistair Dick:
-the Qld prawn farming and aquaculture industry in general is currently subject to excessive
regulatory administrative and cost burden based on outdated regulatory approaches such as ‘total
loads’ that do not reflect the realities of individual sites and their surrounding environments
-Qld aquaculture is regulated more strictly than other industries
-need a discharge ‘background plus’ measuring system that also incorporates advanced and costeffective technologies while taking into account upstream water quality impacts on aquaculture sites
-government should be encouraging management practices that result in the greatest water quality
improvement for the amount of effort and cost expended. For example, reducing nitrogen from a
score of 10 to 5 is much easier and cheaper than from 2.5 to 1.5
-Operational policy Licensing wastewater releases from existing marine prawn farms (2001) category
A & B license discharge requirements are achievable for operators, however category C are difficult.
-concentration based licensing is not energy efficient for pond aquaculture because requires pumps
to be run for a long time for filtering nutrients. Also the more you dilute the ponds the more feed
you lose ie. for every kilo of feed you want high production. Pond based aquaculture is 90% of the
industry
-Op policy should be amended to include a ‘no disadvantage test’ where applicant enters with the
best avail technology
-Gathalungra site example: takes primary, secondary and tertiary treatment to get nutrient
concentrations to a low level to meet the very strict approval conditions
-lack of consistency in departmental conditions across operators. Some farms negotiated approvals
years ago and received difficult conditions
-industry wants a policy change that doesn’t give a disadvantage to operators in changing over to a
new discharge monitoring regime or changing proportion of species. Example. Townsville area
operation.
-licensing on the Logan River for six operations requires operators to intake class F water and clean it
to class A for the prawns tanks.
-the licensing risk score should be the same for fish and prawns because they have the same
environmental risks.
-the dept is not consistent in ensuring that all operators submit annual returns. It would be
beneficial to reduce the frequency that collated data needs to be provided to the dept.
-WQ monitoring datasets required by the dept should be restricted to only those values that are
relevant
-discharge data from existing successful pilot projects between industry and the dept could be used
to revise WQ discharge limits in the Op Policy
-completing an IEMS and the associated ongoing monitoring is expensive, and not always beneficial.
-IEMSs need to be completed by an independent third party
-BOD5 restrictions should not be part of conditioning
-other jurisdictions and professional organisations examples and information should be considered
such as South Australia, CSIRO
-GBRMPA staff with expertise include Alan Smith and Hugh Yorkston
Helen Jenkins:
-if Qld has strategic cropping areas why not have strategic aquaculture areas?
-downstream mangrove monitoring costs $6000/yr per (GBRMPA and Qld requirement). The
monitoring is not accurate and is unnecessary
-Minister’s visited the Gold Coast Marine Aquaculture operation on the 23 Nov.
-Industry in some locations are needing to turn F quality water into A quality water for prawn
farming
-Cost of water quality discharge monitoring is up to $20K cost/yr for most operations
-A Mackay farmer worked to acquire ISO accreditation but then never got an Ecobiz discount for it
-farmers have other incentives to produce positive operation data for example to Coles and Woolies
for their standards
-the industry owned code of practice for marine prawn aquaculture is 10 yrs old and requires
revision
Marty Philips:
-review of discharge regs should focus first on sorting out existing licensed operations
-farms being required to produce higher quality discharge water than water in takes
-older licenses have good conditions A and B. Cat C is hard to meet ANZECC guidelines. Nitrogen,
Phosphorus and suspended solids recommended levels are hard to meet
-state background level requirements often exceed ANZECC requirements
-regulatory approach should be same for GBR and non-GBR areas
-Monitoring by GBRMPA and the dept should be looking at the larger downstream area and impact
on the receiving environment and its assimilative capacity.
-in measuring total nitrogen should separate benign nitrogen from nitrogen that can cause harm,
and not penalise operators based on total nitrogen
-DAFF guidelines also exist and should be considered in EHP regs review
Chris Calogeras:
-the dept needs to keep better record of their intake data
-testing should be risk based, test at high risk times.
-he stated information similar to Alistair (above) on the operation discharge treatment technology
and costs
Dean:
-Should consider whether GBR and non-GBR areas should have different regulatory approaches
-what about incentives for better discharge quality?
-agree that discharge datasets provided by industry should be concise and relevant
-if change Op policy will need Cwth to endorse. Also need to consider EPBC requirements
-Dept is currently reviewing a code of practice for mosquito management to be endorsed in a few
weeks
-it is suggested industry provide comments on the Op policy, with any additional comments on
conditioning
-Industry may wish to provide an example list of model conditions, removing unnecessary
prescription from example conditions
-major legislative changes require apx 12 mths. Solutions within the existing legislative framework
can be implemented faster
-any substantial change in the depts. approach through a new guideline and/or code of practice may
require endorsement by EHPs Minister, and consultation with DAFF
Action items:
-industry to discuss industry needs and issues with DAFF minister
-Helen and Chris to provide comments on the Op policy in a timeframe convenient to their
operations. Comments should focus on improvements to the policy for existing farms, indicate
potential GBRMPA issues and how to address, and provide ideas on conditioning for new operations
-once industry comments received we’ll present them to our technical expertise staff for review, the
we’ll give to GBRMPA (Post meeting note: Op Policy being provided to GBRMPA 1st for comment,
then to DAFF & industry)
-Andrew to email the Op policy to Helen and Chris in editable version with watermark as working
draft.