Proposed Gippsland Renewable Energy Zone (windfarms)

Proposed Gippsland Renewable Energy Zone (windfarms)


This submission is from two fishing industry associations that represent the two largest fisheries straddling the area under consideration off Gippsland; combined they are likely the most impacted with ∼19,000 tonnes caught annually (inside and outside the area under consideration). Both are managed by the Commonwealth Government. The associations are:

1. The South East Trawl Fishing Industry Association representing the Commonwealth Trawl Sector (CTS)
fishery; and,
2. The Southern Shark Industry Alliance representing the Gillnet, Hook, and Trap fishery (GHaT). Strong commercial rights are provided to the fishing industry by the Commonwealth Government in two
a) Vessel Permit Statutory Fishing Rights (SFRs) which limit the number of vessels allowed to fish and set
fishing grounds which cover the area under consideration; and,
b) Quota SFRs which apportion a share of the sustainable annual catch to its holders.

In the CTS and GHaT the current total asset value of these SFR rights are ∼$450m with this value driven by many commercial factors. Quota SFRs make up most of this value. Some fishing companies own both sets of commercial rights and some only one. Fishing companies that do not own rights enter into commercial agreements to lease these from holders. The commercial rights holders within these two fisheries pay the Australian Government levies of ∼$5.4m per annum.

A case study is provided which shows that when grounds were closed to protect sea lions the impact on the fishing industry were that the cost to catch fish increased because fishers moved to new less productive areas. As cost increased fishers became less profitable. Given lower profitability the lease price that companies were willing to pay decreased, meaning the value of quota SFRs also decreased.

This submission addresses the proposition that the Government is seeking to transfer the existing commercial fishing access rights to renewable energy companies. Like the sea lion exclusion case study and consequent displacement, the proposal by Government to transfer fishing grounds to renewable energy companies, will have the same impact on the fishing industry; it is clearly proven and logical that fishing profits will fall, as will the value of vessel and quota SFRs.

Even the loss of grounds not currently used reduced the value of the vessel permit SFR because they could be used in the future to catch new or existing fish stocks.

For nearly a decade SETFIA has led the south east fishing industry in partnering with proponents to mitigate risk and impact on both the incumbent fishing industry and on various shared marine space users including renewable energy proponents. SETFIA’s excellent engagement to date with two Gippsland offshore marine windfarm proponents has shown that it is unlikely that most commercial fishing within their footprints will continue for safety reasons.

Noting SOTS and Seadragon’ s consideration of fishing, which is welcomed, this submission contends that consultation that does not take in to account any commercial fishing within the proposed area is subpar. The Commonwealth Government must consider all fishing data from the area under consideration. It is disappointing to note that the consultation documents to date pay little regard to commercial fishing.

This submission acknowledges Australia’s endeavour to reduce carbon emissions and the many mixed benefits the area under consideration offers to food supply and renewable energy.

In an effort to move forward positively, five recommendations are made:
1. When possible, renewable energy generation and commercial fishing should co-exist, this is unlikely to be achievable given the forms of fishing occurring off Gippsland; Then, given the co-existence is unlikely:
2. If the area under consideration is to be declared, a condition requiring proponents to minimise fishing impacts should be imposed, the Regulations for Offshore Infrastructure Activities allow this;
3. Fair compensation will be paid to the fishing industry when the transfer of commercial rights is to another beneficiary, the Exposure Draft Offshore Electricity Infrastructure Regulations 2022 allow this;
4. The trade-off decision between renewable energy and local fish supply should be determined based on the Australian and Victorian Communities being better-off-overall, the Exposure Draft Offshore Electricity
Infrastructure Regulations 2022 proposes consideration of the national interest;
5. If the area under consideration is to be declared, a condition requiring proponents to pay into a sinking fund to cover abandoned equipment end-of-life impact on the fishing industry should be imposed, the Regulations for Offshore Infrastructure Activities allow this.


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