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Your Ref: ECm1/LN2IM/11-29Tel: +27 (0) 41 5065412, fax: +27 (0) 41 5857261

PO Box 11, Port Elizabeth, 6000

Republic of South Africa

website: www.nelsonmandelabay.gov.za

Our Ref: 19/3/1/1/3

Deals with this matter: J Mkosana

Tel: +27 (0) 41 5061332

e-mail; jmkosana@mandelametro.oov.za

Cape EAPrac Environmental Assessment PractitionersPO Box 2070George6530

Date: 26 June 2013

Attention: Melissa Mackay

ALGOA BAY SEA BASED MARINE AQUACULTURE DEVELOPMENT ZONESon Algoa Bay, Eastern Cape

The comments for the Nelson Mandela Bay Municipality (NMBM) Public HealthDirectorate, Environmental Management sub-Directorate are based on the NationalEnvironmental Management Act (NEMA) Section 2 Principles, the Nelson MandelaBay Municipality Open Space System (NMBMOSS), draft NMBM EnvironmentalManagement Framework (EMF), draft Bioregional Plan draft Desired State of theEnvironment (DSoE) Plan, the draft Environmental Impact Report (EIR) and the draftEnvironmental Management Programme (EMPr).

With the advent of this activity, these will be significant human resource usage anddevelopment stresses on a highly dynamic ecosystem such as the coastal shoreline.NEMA Section 2 (4)(r) stresses the importance of focusing specific attention inmanagement and planning procedures related to development which can causealterations within this sensitive and vulnerable environment. As this is essentially apilot project, no real evidence can be given on the effects of this aquaculture ventureon the coastline. The study is focused primarily on sea-based activities and does notinclude the land-based concerns that may occur, the report does, however, state theinclusion of this in studies related to later applications for environmentalauthorization.

The first phase of development occurs at Algoa 1, option 1 (north), and the mostimportant issues are the negative effects on specialist tourism and recreationalfacilities, real estate values and vessel navigation routes even after mitigationmeasures are put in place. Ecological concerns also come forth when the pollution ofthe water column is considered as well as the effects that chemicals and therapeuticpesticides may have on the surrounding environment (like the introduction of bio-active compounds and their longevity in the water column as well as living tissues).This could be an even bigger problem if exotic fish species are considered due to thepotential for habitat modification giving a competitive disadvantage to the wild

WORKING TOGETHER FOR UBUNTU

2

population. For this reason, we cannot agree with the cultivation of non-indigenousfish species and ask that exotic fish species are completely excluded from theproposal (even though a Risk Assessment was done).

If future development of Algoa 1, option 2 (south) occurs following positiveoperational monitoring feedback, then additional problems such as the negativeimpacts on the local fishing industry and the provision of goods and services by localbusiness could occur. Although it will be dealt with at a later stage for environmentalauthorization it is a cause of concern for the metro as the local fishing industry andthe business produced are an essential part of the local economy and thecommunities. There could be conflict if the processes are not explained properly tothe communities so community involvement should be an integral part of the processat all stages. The skills development and training opportunities linked to the proposedactivity would be good for the metro, but keep in mind that protests can be a problemif communities and local business owners feel excluded.

Visual impacts are also a cause for concern, as it might have a negative effect ontourism and the aesthetics related to the beaches; also the NMBM EMF draft DSoEPlan puts emphasis on the protection of the metro's visual features. There is no validoption for mitigation within the first phase of development as the fin-fish cages will bevisible along the beachfront and it would be an even bigger concern if the activitiesare moved closer to the shore as proposed under mitigation measures for the socio-economic impacts on page 37 of the EIR. As stated in the report, the only noteworthymitigation measures would be layout and design alternatives relating to the colour ofthe cages above the sea surface. How will this have an impact on the potential tocontinue hosting international sporting events such as lronman and also applicationsof the beaches for Blue Flag Statuses in future?

Also, the NMBM, as a local authority, should have at least one representative withinthe proposed Environmental Liaison Committee (ELC) so as to remain informedabout future activities.

The report will be made available to other Service Directorates within the NMBM forfurther commenting.

I trust that these recommendations will carry your favour and if there are anyquestions or comments please feel free to contact me.

JORAM MKOSANADIRECTOR: ENVIRONMENTAL MANAGEMENTPUBLIC HEALTH DIRECTORATE

WORKING TOGETHER FOR UBUNTU

Dr. Shirley Parker-Nance Marine Biologist and Taxonomist Port Elizabeth South Africa 24 June 2003 shirley.parker-nance@nmmu.ac.za

Cape EAPrac Environmental Management Practitioners Tel: 044 874 0365 Fax: 044 874 0432 Cell: 084 584 7419 5 Progress Street, Eagles View Building, First Floor P.O. Box 2070, George, 6530 Website: www.cape-eaprac.co.za Dear Melissa Mackay Comment on the Draft Environmental Impact Report for the Development of Sea Based Marine Aquaculture Development Zone in Algoa I hereby submit the following comments after careful study of the Draft Impact Assessment report. I would like to address two main issues:

Environmental impact of the proposed Development of Sea Based Marine Aquaculture Development Zone on the suggested site - Algoa 1 (north and south) and Algoa 5.

The impact of the proposed development on the people and tourism industry in Port Elizabeth. Environmental impacts It is clear that the lack of a comprehensive understanding of the dynamic oceanography processes within Algoa Bay and the biodiversity of its reef ecosystems has led to the suggestion that Algoa 1 (north and south - as given in in draft document) could be a viable site for the development of a Sea Based Marine Aquaculture Zone. Also the proposal of the Algoa 5 site (as given in in draft document) is highly controversial as it falls within a proposed Marine protected Area. Algoa 1 (north and south) This area is situated approximately 2 km from the Port Elizabeth beachfront adjacent to an extensive inshore reef system supporting high diversity of habitats and organisms not found elsewhere. The reefs are colonized by many filter feeding invertebrates and are especially recognized for its high diversity in sponges, ascidians, bryozoans, soft corals and gorgonians. The proposed development will:

Due to prevailing winds and current in the bay move organic loaded water from the farming facility over the adjacent reef systems.

This will negatively affect exciting reef life by smothering marine invertebrates.

The nutrient enriched conditions will promote excessive algal growth which in itself will foul the natural benthos.

This will result in a change of the community structure of the reef systems, loss in biodiversity and loss of the dynamic water filtering system.

The polluted water would move close inshore as part of the well-known long shore drift or current in a northward and eastwards direction.

Algoa 5 This area is situated west of St Croix Island within the proposed Marine Protected Area. The close proximity of the island and associated penguin breeding populations strongly justifies that this area is not suitable for this development.

Impact on the people of the bay Recreational: Swimming, surfing, sailing, kiting and diving The presence of a Sea Based fishery in especially the Algoa 1 site will:

Attract predators; sharks would be especially problematic and dangerous.

Fish fecal matter in the water will decrease water quality.

The increase occurrence of seaweed present on the beach and in the surf zone will further negatively influence the attractiveness and usefulness of the local very popular beach.

Physically obstruct the open water required for sailing. Tourism Port Elizabeth deemed as the ‘water sport capital of SA’, currently boasts a well-developed attractive beach front, clean natural beaches, both sandy beaches and rocky shores and is a popular tourist attraction. A decrease in water quality due to the presence of fish effluent in the water and on the beaches will detract from its current popularity. The decrease in the safety of the waters off Port Elizabeth will also directly affect large sport events that make use of the beach and coastal waters of the bay. This would negatively affect the tourism industry directly. Conclusion I would like to strongly suggest that both sites Algoa 1 and Algoa 5 not be considered for the Development of a Sea Based Aquaculture Development zone as the cost to the environment of Algoa Bay and to the people of Port Elizabeth will be substantial. I proposed that alternatively land based systems should be further developed. It has been shown that these systems can be maintained with much reduced risk to the environment. Sincerely Dr. Shirley Parker-Nance Department of Zoology Nelson Mandela Metropolitan University Port Elizabeth

PARK PLANNING & DEVELOPMENT

CONSERVATION SERVICES

PO BOX 20419, HUMEWOOD 6013, PORT ELIZABETH

Tel: 041 508 5411 Fax: 041 508 5415

Cape EAPrac Environmental Management Practitioners Tel: 044 874 0365 Fax: 044 874 0432 Cell: 084 584 7419 5 Progress Street, Eagles View Building, First Floor P.O. Box 2070, George, 6530 Website: www.cape-eaprac.co.za Dear Melissa Mackay COMMENT ON THE DRAFT ENVIRONMENTAL IMPACT REPORT FOR THE PROPOSED ALGOA BAY ADZs General comments SANParks is of the opinion that there are too many risks for seabased aquaculture including an exposed coastline; high levels of existing development and use of the sheltered sea space; vulnerability of important wild fish stocks to potential disease and genetic impacts; and abundance of large and/or endangered marine vertebrate fauna. Furthermore Sea based finfish culture’s financial and technical viability has not been illustrated in SA, despite several years of research and development and pilot phases. However, SANParks do support finfish mariculture development focussed on shore-based, recirculating systems that carry lower environmental and economic risks. The technology for this already exists, and successful, commercial scale, shore-based finfish farms are already in operation in the East London IDZ. There is also a designated aquaculture zone within the Coega IDZ, which is currently underutilized. Why not encourage further development here? Specific Comments on Draft EIR SANParks note the recognition of the Algoa bay 5 site as unsuitable due to sensitivity of the Islands, penguins, the proposed MPA and unsuitable sea conditions. SANParks strongly supports the exclusion of this site as a Aquaculture development Zone. However, the preferred site Algoa Bay 1 also comes with several issues including user conflict, tourism impact and downstream impacts on the proposed MPA.

PARK PLANNING & DEVELOPMENT

CONSERVATION SERVICES

PO BOX 20419, HUMEWOOD 6013, PORT ELIZABETH

Tel: 041 508 5411 Fax: 041 508 5415

Specific concerns:

Attraction of sharks and other predators to the area. This has implications for diver and beach swimmers safety.

Shark nets around cages as mitigation measures for predator interaction. This will certainly result in cetacean and bird entanglement. Algoa Bay hosts about 10% of the endangered humpback dolphin, and large groups of common and bottlenose dolphins all piscivores. Algoa Bay inshore reefs are also known as the nursery area for ragged tooth shark pups, how will entanglement and drowning be prevented?

Nutrient input from the cages will have an enriching effect in the adjacent waters, affecting reef life, smothering benthic invertebrates and promoting algal growth. Algoa Bay is recognised as a biodiversity hotspot in terms of benthic invertebrate diversity.

General water quality deterioration can be expected. This will affect tourism in the bay in several ways. o The Blue flag beach status, as strong water Quality guidelines need to be followed for this

certification. o Recreational diver operations will be severely affected by the deterioration of the reefs o Beach safety trough the increase of sharks in the area o Beach and swimmers health by the deterioration of water quality on the main beaches.

Specific comments on the Social impact study Point 2.3 The comment made by the owner of Eyethu fishing “ ...more than enough of fish in the Algoa Bay area and along the coastline of South Africa to provide for demand....” and the use there of as fact in the study is irresponsible. See the DAFF publication 2012, where it states that “ The general trend of deteriorating resource status continuous....(Status of the South African Marine fishery Resources 2012, by DAFF) SANParks is concerned that the below statements make this venture very uncertain and highly unlikely to be successful, yet the study’s conclusion implies that losses in an established sector such as tourism is acceptable.

Sea based finfish culture financial and technical viability has not been illustrated in SA, despite several years of research and development and pilot phases.

No feasibility study or business plan has been prepared for the proposed mariculture sites in Algoa Bay.

high uncertainty surrounding the environmental and economic impacts associated with a development Point 7, bullet point 2: Correction: There is no cage diving activity in Algoa Bay, but a large established recreational scuba diving industry. Point 7.1.2 Make several statements about the MPA, some of which are fatally flawed, but the author did not consult the management authority SANParks,

PARK PLANNING & DEVELOPMENT

CONSERVATION SERVICES

PO BOX 20419, HUMEWOOD 6013, PORT ELIZABETH

Tel: 041 508 5411 Fax: 041 508 5415

The Addo Elephant National Park MPA is located within Algoa Bay, adjoining the terrestrial Greater Addo Elephant National Park. – There is no Addo Elephant National Park MPA, only a proposed MPA

The expanded Addo MPA will be made up of restricted zones and control use zones and it may thus be possible to accommodate an ADZ within the control use zones. - A resolution taken at the National Marine Protected Area Forum 2010 stated that no aquaculture activities would be allowed in an MPA regardless of the zonation.

Interested and affected parties did not anticipate any impact on the Addo MPA for the Algoa 1 Option 1 and 2 sites as long as the fish farms by itself do not disturb the current environment (e.g. introducing organic wastes that could attract a different mix of predators) (Michael Young and Garry Scholtz). – 1. SANParks does not support this view. One of the primary objectives of the MPA is to rebuild depleted fish stocks. Disease transfer and genetic pollution poses severe risks for our local fish populations. Local research (Dr P Cowley, South African Institute for Aquatic resources) have shown that there is a strong possibility that the kob population found in Sundays Estuary and Algoa Bay is a local resident population. Both disease transfer and genetic pollution could have devastating effects on a local level. 2 Furthermore organic/chemical pollution from the fish farms will have an effect on the MPA and associated fauna. The Bay is one linked ecosystem, with currents circulating throughout the whole bay and the transportation of organic and chemical particles in particularly a north eastern direction as the main current is a long shore directional current. 3 Due to weather and sea conditions in the bay escapees from the cages is a real genetic threat

8: Conclusion

SANParks queries the conclusion that sea cage fish farming benefits outweighs the losses in other sectors. This statement is unsubstantiated as there is no indication of impact on tourism (in terms of number of job losses, estimation of revenue loss, indication of how many small businesses might close). It is reckless

Kind regards Dr A. Oosthuizen Marine co-ordinator Park Planning & Development SANParks

18 June 2013 Attention: Melissa Mackay Environmental Management Practitioners

Email: mel@cape-eaprac.co.za Dear Melissa, RE: Comments from BirdLife South Africa on the Draft Impact Assessment Report and Environmental Management Programme for AlgoaBay Sea Based Marine Aquaculture Development Zones Our main concerns relate to the lack of an assessment of the impact of marine aquaculture on a broader ecosystem scale. We acknowledge that the Department of Agriculture, Forestry and Fisheries (DAFF) asked for these reports to be undertaken regarding the development of sea-based marine aquaculture development zones but we recommend that the DAFF undertake a full ecosystem analysis of the benefits and risks of both sea-based and land-based aquaculture. There are several factors that favour the use of land-based farms over at sea cage farming in South Africa. Firstly, the characteristics of the South African coastline and oceanography do not appear to be suited to at sea cage farms. Rough seas and strong currents damage cages and increase the likelihood of stock losses. Secondly, the South African Sustainable Seafood Initiative (SASSI), a growing consumer-awareness programme lists many fish farmed in at sea cages, including both yellowtail and dusky kobon the orange or “think twice” list (WWF-SA 2013). This is due to environmental concerns about the possibilities of stock or parasite contamination as well as pollution by organic materials. However dusky kob farmed on land is on the green list. The draft impact assessment report notes that a positive market response will be required for the farms to be economically viable. It will be considerably easier to market the farmed fish if they are on the green list, and will help the product compete with other linefish, which are on the orange list. Any sea-based aquaculture development in South Africa should also take into consideration the need for a balanced ecosystem approach (Neori et al. 2007).

There is a trend towards integrated multi-trophic aquaculture, where “extractive” species such as seaweed and shellfish are grown near “fed” species such as fish or shrimp. Such systems should be investigated in South Africa as they may mitigate many of the adverse environmental impacts of fish farming in isolation. Regardless of the site of the fish farms, a more thorough investigation should be conducted into the source of food for the farmed fish. The report mentions the availability of compound feeds such as Aquanutro but also suggests that alternative feeds may need to be developed. The species that are being considered as potential farming options are all carnivorous, and the favoured species yellowtail (Seriolalalandi) is known to target sardine. Regulations need to be in place to ensure that any alternative food source for the farmed fish does not create a higher demand for small pelagic fish from Algoa Bay, as there are already concerns about the potential competition between the fishery and the endangered African Penguin for these fish(Pichegru et al. 2012). Another concern about the potential food source was raised in the report and we feel requires serious consideration. If frozen fish are imported there is a risk of introducing fish viruses to the South African population, which would have severe impacts on the ecosystem. Should at sea farming go ahead in Algoa Bay, we have the following comments:

We agree with the marine specialist report that the Algoa 5 site should not be considered further due to the site’s location within the proposed Marine Protected Area and its proximity to St Croix Island.

The pollution of the water column by organic wastes is a concern, especially

considering that even with the mitigation actions suggested, the effect is still classed as “negative medium”. The report states that while farms generally have small footprints; reduced dissolved oxygen in the water has been implicated in the development of harmful algal blooms. The extent to which harmful algal blooms affect small pelagic fish (and therefore seabirds and other predators that feed on them) is unknown. Due to the presence of several threatened species in the bay as well as its importance for cetaceans, more scientific evidence should be supplied describing what effects harmful algal blooms may have.

Regards,

Carolyn Ah Shene-Verdoorn Policy & Advocacy Manager BirdLife South Africa

References

Neori, A., M. Troell, T. Chopin, C. Yarish, and A. Critchley. 2007. The need for a balanced ecosystem approach to blue revolution aquaculture. Environment: Science and Policy for Sustainable Development 49:36–43. Retrieved June 5, 2013, from http://www.tandfonline.com/doi/abs/10.3200/ENVT.49.3.36-43.

Pichegru, L., P. G. Ryan, R. van Eeden, T. Reid, D. Grémillet, and R. Wanless. 2012. Industrial fishing, no-take zones and endangered penguins. Biological Conservation 156:117–125. Elsevier Ltd. Retrieved May 22, 2013, from http://linkinghub.elsevier.com/retrieve/pii/S0006320711004769.

WWF-SA. 2013. SASSI Consumer Seafood Pocket Guide. Available at http://www.wwfsassi.co.za. Accessed on 05/06/2013

Ms Melissa Mackay

Cape EAPrac (Pty) ltd

PO Box 2070

George

6530

RE: Comments on the Algoa Bay Sea Based Aquaculture Development Zones

Dear Ms Mackay,

I thank you for the opportunity to comment on the Draft EIR for Aquaculture Development Zones in

Algoa Bay.

I would like to raise my concerns regarding the potential impacts this development may have on the

local ichthyofauna within Algoa Bay as well as potential impacts which may arise to reef areas

adjacent to the proposed aquaculture sites.

Cage culture of fish increases the risks of disease outbreaks and parasite infections significantly due

to the high stocking densities of these operations. Site Algoa 1 is situated offshore of, but in close

proximity to many shallow reef complexes on which resident fish populations occur. The

transmission of parasites and disease between the cultured species and wild fish is therefore of

considerable concern and may lead to significant impacts to the wild stocks, many of which are

already threatened or heavily targeted by commercial and recreational fisheries. Furthermore it is

probable that the cages will serve as Fish Attracting Devices (FAD) attracting reef associated species

towards them and bringing them in closer contact with the cultured species, further increasing the

risks of disease and parasite transmission.

Site Algoa 5 situated off the Sundays Estuary is located in an important biodiversity hotspot within

the proposed Addo Marine Protected Area as it is situated offshore of the Sundays estuary. The

Sundays Estuary has been shown to play a critical role as a nursery and feeding area for dusky kob

populations in Algoa Bay, a species which is severely depleted and considered to be overexploited.

Dusky kob move between the estuary and nearshore marine environment on an ongoing basis, and

frequent the shallow reefs off the Sundays estuary mouth and along the Sundays surf zone. Due to

their use of the estuary they occur more frequently adjacent to the estuary mouth area. In addition

there are numerous low profile reefs which are uncharted along this section of the Algoa Bay which

play an important role in the biology of this species. As was mentioned in the Draft EIR a reef was

identified to the north-west of the proposed Algoa 5 site. It is probable that there are additional

areas of flat low profile reef adjacent to this proposed aquaculture site. The risks of disease

transmission between wild dusky kob (and other species) and cultured species is likely to be

significantly greater due to the proximity of Site Algoa 5 to the Sundays estuary and high use areas of

wild fish, and at least one (but probably more) reef area which is utilised by this and other species.

Further impacts which may affect the reef ecology adjacent to the proposed aquaculture sites

include deposition of particular matter and nutrient enrichment as a result of feed wastage and

faecal matter originating from the cages. Although dispersal may occur, this is dependent on the

local current conditions and periodic accumulation on the seafloor may occur during periods of low

current conditions. Re-occurrence of such accumulation in the long-term may significantly alter the

benthic biota on both hard and soft substrata. Any changes in these benthic communities will affect

the local fish populations, particularly where reef areas are affected as these habitats support many

species of resident fish. The fish and benthic communities of reef areas within, or in close proximity

to, the proposed aquaculture zones may therefore be affected and altered as a result of these

impacts.

Kind regards,

Russell Chalmers

Aquatic Ecosystem Services

PO Box 7065

Grahamstown

6148

Tel: 082 873 9018

Email: Russell@AquaticEcosystemServices.co.za