EIA or not EIA - That should be the question?

I have finally been able to get my hands on a copy of THE document a couple of weeks ago... The fish farmers have tried to specifically prevent me from accessing this document... and reading through this document, I am now understanding why they did not want me to discover it! The foundation of the Gansbaai Salmon Farm and the associated permit is hidden in this 75 page long document entitled as follows:

Accompanying this report is a 128 page long Volume II - Appendices.

These two documents are available for download (30Mb) here:

http://www.WhiteSharkTrust.org/salmon/Draft_Environmental_Scoping_Report.pdf

http://www.WhiteSharkTrust.org/salmon/Draft_Environmental_Scoping_Report_Appendix.pdf

Have I then been wrong to accuse the Gansbaai Salmon Farm of lacking a proper EIA? Well, this is most definitely THE document that the Gansbaai Salmon Farm AND Marine and Coastal Management have claimed to be the EIA. But the answer to the above question, is a clear NO. This document is, in short, a description of potential problems and solutions for the establishment of the farm, but not an EIA.

On page 19, section 4.6 entitled 'Purpose of this report', we read:

'The purpose of this scoping report is to provide information on the proposal in the context of the potential environmental impacts. Recommendations and mitigation measures are put forward so as to reduce negative impacts and to enhance the activity from a social and environmental perspective.

This report aims also to identify aspects which should be subject to ongoing monitoring should a pilot project be approved by DEAT.'

So, this is what this document really is, a SCOPING REPORT!

More importantly, on page 20/21, section 5 entitled 'Assumptions and Limitations', we read:

'Although there is a large amount of information on net cage farming of fin fish in other parts of the world there is only a very limited amount of information on this practice in South Africa. As a result much of the information contained in this report is gleaned from experiences overseas. It is therefore essential that should approval be given for the establishment of net cages, the approval should be for a pilot study which, with effective monitoring, will be able to confirm the results of this assessment and will also allow for the implementation of any additional mechanisms required to minimise impacts.

The assumption has been made therefore that good practice methodologies that work in other parts of the world are likely to be effective in South African waters.

This impact assessment has concentrated on the potential impact of the proposed salmon farm on the surrounding environment and has not looked at the potential impacts of the surrounding environment on the salmon farm (e.g. stock loss due to predation by seals, the impact of high seas on the net cages, etc.) apart from broad statements made on this issue.'

A SCOPING REPORT BASED ON OVERSEAS INFORMATION!

Stop using this document as if it was the Holy Grail of EIAs... Just STOP! This is just a larger and more elaborate version of the document I sent out to the media initially. This certainly does not give the Gansbaai Salmon Farm owners or employees the right to use it in all and any circumstance as if it was written in stone. I am not attacking the Environmental Consultant firm either, just the concept.

I certainly have never read a document that includes so many 'woulds', 'coulds', 'possibly', 'uncertain', 'unknown', etc words in virtually every paragraph and sentence. Where has the 'PRECAUTIONARY PRINCIPLE' gone? Have the farmers not read the document?

Another important issue: There is absolutely no mention about Sharks in the whole document! What is Dyer Island known for? Rocks? Kelp? Sea Lice? Pigeons? Why are White Sharks NOT mentioned in this document? Are they avoiding the question deliberately knowing that White Sharks represent a non-negligible risk to the farm and to themselves? White Sharks would be classified as 'High Significance' in the risk assessment factor of this document had the issue been addressed.

On page vi, we read:

'In addition, should this pilot study be authorised a very important condition attached to the authorisation should be effective monitoring of the activities by an independent body. Issues that should be monitored are identified.'

This supports what I have been trying to establish for the past few months: monitoring by an independent body. So why is there no direct monitoring? Where is the independent body? DEAT issued a permit for this salmon farm based on the findings of this document... Maybe whoever approved this farm proposal should have read it properly and made sure that at least the few proposed permit conditions contained in the document be established and enforced.

The reason why this issue is so important is summarized on page 12:

'... If viable, this mariculture activity can potentially extend further along the coast...'

One of the key elements that the document does not address is the choice of the initial location of the salmon farm? South Africa presents over 3'000 kilometers of coastline, why would any sane person of (even) mediocre intelligence choose Dyer Island (or for that matter near any area that includes a large concentration of natural predators)?

I also clearly remember the farmers claiming that the area (one time they said 200 meter and another time they said 400 meter radius) around the fish farm is closed... Well, let's take this document seriously for once, and we read on page 15:

'Both the proposed sites are open areas, which means that they are not closed off to users, except for fin fish cage culture other than Salmon Salar Sea Farming (Pty) Ltd...'

In conclusion, anyone is allowed to approach the fish farming site at any time. And I would like to encourage this... The more people go to look at the farm, the more monitoring will take place! Please report any observations (e.g. Seals, Sharks, Birds, Whales caught or entangled in the nets or line, or any irregular activity or observations) to the local authorities (and to me please)!!!

Moreover on page 12, we read another statement that should actually promote these approaches:

'Furthermore, tourism, a much needed economic element for the Gansbaai region, may be stimulated by the proposed salmon farm, for the very reason that it will be a first for South Africa and that salmon is a sought-after fish.'

This is probably one the most ridiculous claims I have ever encountered! First of all, tourism is flourishing in Gansbaai with the Fynbos, Whales, Sharks and Dyer Island ecosystem... I hardly think that tourists will hesitate (or even be remotely interested) to see a breaching captive Salmon in a pen, when alternatively, they can view breaching White Shark or Whales in liberty... But I might be wrong... Promoting tourism? The ONLY reason why tourism was mentioned in this document is political: Tourism is the key magic word in the South Africa of today. In reality, the fish farm will more likely affect the tourism in a negative way if (when) the farm pollution affects the local ecosystem, or animals get caught in the nets or killed by the farmers!

On page 47, the document reads:

'It is not possible to accurately predict the expected level of entanglements, or the value of the various mitigation procedures recommended to limit entanglements. Any interaction between marine mammals (particularly large cetaceans) and the facility should therefore be documented for use in future planning.'

In general, this document deals exclusively with marine mammals... This issue is directly linked to the choice of specialists who compiled this document:

• Ken Finlay (Southern Whales Consultancy): Marine Mammal Specialist
• Doug Jeffery (Doug Jeffery Environmental Consultants): EIA Consultant
• Greg Stubbs (Salar Aquaculture Consultancy): Aquaculture Specialist

Obviously, Sharks and Birds will fall short of the otherwise detailed marine mammal information provided in the document.

But the document also offers some clear insights into the real pollution it will create. Pollution that the authorities and the fish farmers claim to be negligible or inexistent. So why did the local Abalone farmers demand a four kilometer exclusion area from any of their sea water intakes? Does this not clearly indicate that the sea water around the fish farm will be polluted with chemicals, drugs, antibiotics and diseases that may affect the Abalone farming should they be located too close?

Anyway, I believe that this document is providing some interesting arguments and, for once, some answers... and I will continue to report on activities and arising news with regards to this Gansbaai salmon farm in these pages...

The important point to remember when reading through this document is that it was written four years before the establishment of the farm, and that all (if not most of) the proposed solutions are not in place at this stage. Words are very nice, but implementing them is something else!