Huon Aquaculture Company Pty Ltd

ABN 865 067 386 109

Parramatta Creek
Production Increase to 48,000 tpa
HOG fish products

Notice of Intent
December 2023

Prepared by
Ria Marni Amuno
Processing Environmental Manager
Huon Aquaculture Company Pty Ltd
Phone: 0409 238 257
Email: [email protected]
 Huon Aquaculture: Parramatta Creek Production Increase - Notice of Intent 2023

Foreword
This Notice of Intent has been prepared to support a future development application by Huon Aquaculture
Company Pty Ltd (Huon) to the Latrobe Council (LC). Huon is the project proponent for the Fish Processing
Facility Production Increase Parramatta Creek project.
The application is to increase production at the existing fish processing facility at Parramatta Creek from
the currently approved 33,000 tpa to 48,000 tpa of head-on-gutted fish products.

The purpose of this NOI is to provide:

• supporting documentation to the development application to the LC.
• a basis for the LC and the Board of the Environment Protection Authority (EPA) to consider the planning
and environmental aspects of the proposal under the Land Use Planning and Approvals Act 1993
(LUPAA) and the Environmental Management and Pollution Control Act 1994 (EMPCA).
• a basis for the conditions under which any approval can be given; and
• a source of information for interested individuals and groups to gain an understanding of the proposal.

This NOI has been prepared in accordance with the EPA Tasmania Guide for Preparing a Notice of Intent,
March 2023.
TABLE OF CONTENTS
Foreword .................................................................................................................................................2
EMPC Act - Section 27B(2) ........................................................................................................................1
1 Names and contact details of the person/s lodging the application .................................................1
1.1 Proponent .............................................................................................................................1
1.2 Registered address ................................................................................................................1
1.3 Name of the person lodging the application to the Council ..................................................1
1.4 Name of person/s lodging the NOI ........................................................................................1
2 Name of proposed project and location ...........................................................................................2
2.1 Project Name ........................................................................................................................2
2.2 Project location .....................................................................................................................2
3 Background of the project proponent ..............................................................................................2
3.1 Proponent’s name, contact details, and business number ....................................................2
4 Description of the proposed project .................................................................................................3
5 Location of the project and site map ................................................................................................3
6 Stakeholder consultation process.....................................................................................................5
7 General description of the physical environment that may be affected by the project ....................5
7.1 Topography ...........................................................................................................................5
7.2 Soils .......................................................................................................................................5
7.3 Climate ..................................................................................................................................5
7.4 Geology .................................................................................................................................5
7.5 Biodiversity ...........................................................................................................................5
7.6 Surface water ........................................................................................................................6
7.7 Groundwater.........................................................................................................................6
8 Key environmental, health, economic, and social issues ..................................................................6
8.1 Key environmental issues ......................................................................................................6
8.2 Key health issues ...................................................................................................................7
8.3 Key social and economic issues .............................................................................................8
9 Surveys and studies proposed or underway in relation to the key issues ........................................8
10 Proposed timetable for the project ..................................................................................................9
EMPC Act - Section 27B(2)(k)..................................................................................................................10
1 EPBC Act Approval ..........................................................................................................................10
2 EPBC Act Referral ...........................................................................................................................10
3 Bilateral Agreement made under section 45 of the EPBC Act .........................................................10
4 LUPA Act.........................................................................................................................................10

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5 Environmental Licence ...................................................................................................................10

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LIST OF TABLES
Table 1. Proposed production increase with the corresponding financial year. ..........................................9

LIST OF FIGURES
Figure 1. Parramatta Creek processing facility location. ............................................................................3
Figure 2. Current processing site layout plan. ............................................................................................4
Figure 3. Identified sensitive receptor closest to the Huon Parramatta Creek processing facility (Huon PMC
DPEMP, 2020). ..........................................................................................................................................8

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 EMPC Act - Section 27B(2)
1 Names and contact details of the person/s lodging the application
1.1 Proponent
The Proponent for this development is:
Huon Aquaculture Company Pty Ltd

1.2 Registered address

Huon Aquaculture Company Pty Ltd
Level 13, 188 Collins Street
Hobart Tasmania 7000
Phone: (03) 6239 4200
Email: [email protected]

1.3 Name of the person lodging the application to the Council

Chloe Lyne
Planning and Development Consultant
Commercial Project Delivery
Suite 1, Level 1, 178 Charles Street, Launceston, Tasmania 7250
Phone: 0408 397 393
Email: [email protected]

1.4 Name of person/s lodging the NOI

Ria Marni Amuno
Processing Environmental Manager
Huon Aquaculture Company Pty. Ltd
7218 Bass Highway, East Sassafras, Tasmania 7307
Phone: 0409 238 257
Email: [email protected]

Matthew Whittle
General Manager Sustainability
Huon Aquaculture Company Pty. Ltd
Level 13, 188 Collins Street, Hobart, Tasmania 7000
Phone: 0438 566 259
Email: [email protected]

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2 Name of proposed project and location

2.1 Project Name

Huon Aquaculture - Parramatta Creek Production Increase to 48,000 tonnes per annum (tpa)
of head-on-gutted (HOG) fish products.

2.2 Project location

Parramatta Creek Processing Facility,
7216 Bass Highway, East Sassafras
Tasmania 7307

3 Background of the project proponent

Huon operated as a private company from 1994 until it was listed on the Australian Stock Exchange
(ASX) in October 2014. The majority owners, Peter and Frances Bender, purchased the company from
Huon Atlantic Salmon Pty Ltd through the reorganisation of a Bender family company in December
1994. The business grew to become the largest privately owned salmon farming operation in Australia.
With the sale to JBS Australia Pty Ltd (JBS) in November 2021, Huon is now part of a global business.
JBS is the country's largest meat and food processing company, operating technologically advanced
production and value-added facilities and feedlots, whilst also owning Australia's largest smallgoods
manufacturer, and operating a leading high-quality meat cutting and case ready production facility.
Huon is JBS’s first entry into the aquaculture fish protein market and with JBS, Huon has improved
certainty and is part of a more diversified food production and supply business.
Huon currently operates eight freshwater sites, multiple marine farms state-wide as well as a
processing facility located at Parramatta Creek (PMC). Huon currently employs over 1100 staff
(including labour hire) with 859 (FTE) staff employed in Tasmania.
This NOI refers specifically to Huon’s PMC Processing Facility located at: 7216 Bass Highway, East
Sassafras, 7307

3.1 Proponent’s name, contact details, and business number

Huon Aquaculture Company Pty Ltd
Level 13, 188 Collins Street
Hobart, Tasmania 7001
Phone: (03) 6239 4200
Web: www.huonaqua.com.au
ABN: 79 114 456 781
ACN: 067 386 109

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4 Description of the proposed project
The PMC Processing Facility currently operates as a Level 2 activity under the Environmental
Management and Pollution Control Act 1994 and to the Permit Conditions – Environmental No 9362
granted under the Land Use Planning and Approvals Act 1993, as below.
• Municipality: LATROBE
• Permit Application Reference: DA 238/2019
• EPA file reference: 244900

Operating under the above approvals, the site functions as a fish processing facility with an approved
annual production of 33,000 tpa. This NOI will be seeking approval to increase production to 48,000
tpa of head-on-gutted (HOG) fish products.
The footprint of the processing site will not be expanded under this proposal. Planned modifications
in the processing area will be implemented to increase the efficiency of production. Other
components related to the production increase will include an increase in traffic to the site both for
employees and transport carriers, however, onsite parking area is sufficient for the planned increase
in production.

5 Location of the project and site map

The PMC Processing Facility is located approximately 25 km southeast of Devonport at Lot 1, 7216
Bass Highway, East Sassafras, Tasmania, 7307. Figure 1 shows the location of the existing processing
facility in Parramatta Creek in relation to the region. Access to the site is via a sealed existing roadway
off the Bass Highway.

Figure 1. Parramatta Creek processing facility location.

Figure 2 shows the current site map of PMC processing facility. Onsite are two sizable buildings utilised
for production, an extensive car park, a wastewater treatment system that includes primary treatment
infrastructure, four ponds, an irrigation system. Also onsite is the freshwater treatment plant,
maintenance shed and an ice plant.

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Figure 2. Current processing site layout plan.

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6 Stakeholder consultation process
Huon will consult with relevant stakeholders including the Latrobe Council and the EPA after the Board has
determined the level of the activity proposed in this NOI.

7 General description of the physical environment that may be affected by the project
In accordance with the proposed production increase, no addition to the factory’s footprint or production
infrastructure is required. No additional land will be cleared for the increase in production to occur, other
than a minimal increase in onsite parking which will not require the clearing of vegetation. The current site
hardstand areas will be able to accommodate the increase in production within the existing facilities.

7.1 Topography
Huon's processing facility at PMC is relatively flat. The current irrigation area has a gradual slope
downwards towards the irrigation area's center, and then the ground slopes upwards to a high point in
the property's north-west corner. Several ephemeral drainage lines can be seen at the low point in the
middle of the existing irrigation area, especially following heavy rainfall events.

7.2 Soils
The soils on the Huon’s PMC processing facility have been previously described by Agricultural Resource
Management (2010) and Geo-Environmental Solutions (GES) (2016). Review and assessment of the soil
mapping reports were performed to ensure the validity of the results in relation to the topography, known
geology of the area, production system, and agricultural land use activities. The soil types identified on the
property are Roebuck soil (poorly drained and moderately well-drained), China soil, and Duplex soil.

7.3 Climate
The PMC processing facility is situated in the cool temperate climatic zone. The closest active Bureau of
Meteorology weather stations to the site are the Elphin Grove (station number 091171) located in East
Sassafras and The Devonport Airport (station number 091126). The Elphin Grove weather station records
rainfall only. Temperature data, among others, are recorded at the Devonport Airport weather station.
Rainfall data summary from all the years of measurement indicated a monthly mean from 49.5 to 111.7
mm with the highest amount of rain occurring in July and the least rain happening in December. Utilising
all years of data from 1991 to 2023, the mean monthly minimum and maximum temperature range from
4.8 – 12.6 °C and 12.9 to 21.8 °C, respectively.
Dominant winds tend to be from the west-southwest and southeast during summer, autumn, and winter.
Winds in spring are pre-dominantly from the west-southwest.

7.4 Geology
Huon’s PMC processing facility site consist primarily of Permian mudstone, sandstone, and siltstone beds.
Quaternary alluvium is found in the northeastern part of the land, near the Parramatta Creek.

7.5 Biodiversity
The PMC processing facility is located within an area of the site that has been developed and used for
industrial and agricultural purposes. The proposed increase in production will be implemented on the
current industrial site. No impact on the current surrounding flora and fauna should occur.
The vegetation on and the surrounding land of the PMC facility largely comprise of grasslands. The facility
is surrounded by state forest to the north, east, and south; and an orchard on the western side of the Bass
Highway. No threatened flora species have been recorded within 500 m of the site.

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No terrestrial fauna habitat remains onsite and no threatened fauna species have been recorded within
500 m of the site according to the Natural Values Atlas Report.

7.6 Surface water

There are two main watercourses near the PMC processing facility, the Felminghams Creek and the
Parramatta Creek, and both are part of the middle Mersey River catchment. Parramatta Creek flows to the
east of the property and sourced in forestry land, around 1 km southeast of the site. Parramatta Creek in
this area is ephemeral and is sourced in boggy land in the northwest of the property. Felminghams Creek
traverses at the west of the processing site on the neighbour’s (Layton) land, joining Parramatta Creek
downstream of Huon’s processing and irrigation areas. As a result, Parramatta Creek receives any run-off,
irrigation overflow or seepage from the operation whereas Felminghams Creek receives run-off, irrigation
overflow or seepage from the irrigation downstream of the freshwater dam on Layton’s land.
Both creeks are classified as slightly to moderately disturbed due to its existing land use within its
catchments, according to the ANZECC Guidelines (2000).

7.7 Groundwater
Permanent groundwater at Parramatta Creek occurs in and moves through intersecting fractures in
Permian-age sedimentary rocks (mudstone, siltstone, sandstone) and in nearby Jurassic-age dolerite to
the north-east. These are called hard-rock unconfined aquifers. Groundwater also occurs in the veneer of
Quaternary-age alluvium along Parramatta Creek, and, to a lesser extent, along Felminghams Creek and
smaller tributary drainage lines. These unconsolidated sediments are intergranular unconfined aquifers.
The relatively low-lying areas adjacent to and including Parramatta and Felminghams creeks are
groundwater discharge areas, where upward-moving groundwater is discharged to the surface via
evapotranspiration and streamflow. The water table is close to the surface (within a metre or so in
monitoring bores on the Huon property) and it fluctuates in response to changing evapotranspiration
rates, rainfall, and irrigation.

8 Key environmental, health, economic, and social issues

8.1 Key environmental issues

a. Wastewater volume
One of the main environmental concerns related to the increase in production is the site's capacity to
manage the effluent volume. The potential environmental receptors impacted by the elevated volume of
wastewater are downstream surface waterways, soil, and groundwater.
All wastewater produced in the processing facility undergoes adequate treatment process for the effluent
to meet the requirements in the Environmental Permit. The proposed production increase will result in
30% rise in wastewater volume. The dissolved air floatation device (DAF) in the primary treatment is
currently operating for 12 hours. The DAF operation hours will be increased to a maximum of 20 hours
when required. The aeration, facultative, and settling ponds onsite currently allow a total of 72 days
retention time. An increase in wastewater volume in relation to this NOI will decrease the retention time
to 52 days. The foreseen retention time is adequate for an effective secondary treatment. In addition, an
EPA and Council approved 75 ML dam will be commissioned by July 2024. This additional volume will
increase the retention time of the wastewater for a more effective treatment process.
b. Management of solid and controlled waste
Solid wastes and controlled wastes produced at the facility include solids from the WWTP (solids
screening), packaging materials, waste from staff amenities, fish processing wastes and ash from the
smokehouses. The amount of solid and controlled waste is expected to increase with the proposed
increase in production.

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Current waste management practices are adequate and will continue with the production increase. Viscera
is ensiled, where the pH value is adjusted to less than 5, to reduce bacterial activity and be suitable for
land spreading. The viscera are transported once or twice a day, depending on production volume, to the
land-spreading site about 30 minutes away from the PMC processing facility. The transport of viscera is
carried out in 22,000 L tankers by a third-party waste transporter. Additional transport may be
implemented when required in conjunction with the proposed production increase. Huon intends to
construct a rendering facility capable of processing viscera from the PMC processing facility, however, this
is a different project with relevant approvals sought separately.
Other production fish waste such as heads, frames, and tails are sold as pet food. Fish waste not accepted
as pet food are currently sent to composting facilities. Implementation of these fish waste management
strategies will continue in line with the proposed production increase.
Waste minimisation techniques, such as source reduction, recycling, and waste auditing, will continue to
be implemented wherever possible to ensure best-practice environmental management. Packing
materials and office wastes will continue to be segregated, compacted, and stored in skips for collection
by contractors for recycling, reuse, or disposal as appropriate.
c. Increase in air emission
The PMC Processing Facility utilises three smokehouses to produce hot and cold smoked fish products.
The smoke generator has a restricted oxygen supply and operates at temperatures between 600 °C and
800 °C so that the Red-gum wood chips do not combust. The resulting smoke then circulates around the
product and fresh air is then introduced to displace the smoke in the batch process. The smoking
procedure ensures comparable concentrations of oxygen and carbon dioxide to the ambient air, in
contrast to the concentrations found in boilers and incinerators during the combustion process.
Stack monitoring is conducted once every two years in accordance with PMC’s environmental permit. The
latest monitoring data depicted an 18% less in particulate matter in relation to the standard limit. The
production increase will not cause exceedances in air emissions from the limit.
There are minor visible emissions of water vapour, both continuous and intermittent, from the hot water
and refrigeration cooling tower systems. Their emission is considered environmentally insignificant.

8.2 Key health issues

Figure 3 shows the two sensitive receptors identified in this proposal closest to the PMC processing facility.
There are two existing dwellings in the nearby vicinity of the Parramatta Creek processing facility. The
nearest existing residential receptor (R1) is the land owned by Mr. Layton that includes the orchard.
Second receptor (R2) include the Parramatta Creek rest area and a restaurant now utilised for special
events only. R2 is located more than 1 km northwest of the processing facility. Considering the results of
the air quality and odour emission studies included in the submission of the Huon PMC Development
Proposal and Environmental Management Plan in 2020, it is very unlikely that there would be any future
residential or commercial/industrial developments in the immediate surroundings as the land use is
predominantly identified as either timber production or timber reserve. Consequently, no additional
sensitive receptors have been identified for this proposal.
The distance from the site to nearby identified sensitive receptors and even to transport routes (Bass
Highway) precludes the concentrations of any emissions – whether noise, dust, gases, or liquids – from
adversely impacting passers-by. Huon maintains that the proposed initiative does not pose any public
health risks.

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Figure 3. Identified sensitive receptor closest to the Huon Parramatta Creek processing facility (Huon PMC DPEMP, 2020).

8.3 Key social and economic issues

The PMC Processing Facility is in the municipal area of Latrobe with a population of 12,420, where 48.7%
is male and 51.3% is female according to 2021 data from the Australian Bureau of Statistics (ABS). About
54.6% of the population above the age of 15 is in the labour force and 53.9% of that value work full-time.
These data depict a high level of socioeconomic disadvantage with ongoing problems of high rates of
welfare receipt and low levels of educational attainment.
Currently, the facility employs 230 – 350 full-time equivalent (FTE) staff. The proposed increase in
production will require an estimated 100 – 150 FTE employees to join the PMC team and will result in a
positive economic impact on the local community and the economy of the municipality of Latrobe by
providing additional means of livelihood to the population. Also, existing employees will receive an
increase in job security, thus will prevent future out-migration.

9 Surveys and studies proposed or underway in relation to the key issues

Huon is currently undertaking the following activities regarding increased production at the PMC
Processing Facility:
• Modelling impacts of production increase on wastewater volume and quality; and air, odour, and
noise emissions; and impact on traffic of both employees and transport carriers;
• Construction of a winter storage dam and installation of additional irrigation infrastructure;
• Viability study for desalination system to sustainably manage the incoming high conductivity
water;
• Ongoing water quality monitoring and its effect on the receiving environment such as soil,
surface water, and groundwater;
• Implementation of more efficient solid waste reduction strategies and management.

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10 Proposed timetable for the project
The PMC Processing Facility is foreseen to increase its production capacity, as shown in Table 1 below.

Table 1. Proposed production increase with the corresponding financial year.

Financial Year Amount of HOG (tonne)

2023 - 2024 32,400

2024 – 2025 35,836

2025-2026 39,551

2026-2027 47,877

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 EMPC Act - Section 27B(2)(k)

This Notice of Intent (this document) is submitted to the Tasmanian EPA to determine the level of
assessment required under the state Environmental Management and Pollution Control Act 1994 (Tas.)
(EMPCA) and to ascertain the assessment process required.

1 EPBC Act Approval

The proposed development will not impact on any protected matter in relation to the EPBC Act.

2 EPBC Act Referral

Huon Aquaculture does not indent to refer the project to the Australian Government for determination as
the proposed development will not impact any protected matter.

3 Bilateral Agreement made under section 45 of the EPBC Act

Not applicable.

4 LUPA Act
The proposed production increase will be implemented in the existing fish processing facility owned and
operated by Huon located within the boundaries of the Latrobe Municipality. The land use of the site will
remain the same. This proposal will be assessed in accordance with the Latrobe Interim Planning Scheme
2013 and is solely within the Rural Resource Zone. The relevant land use under the Planning Scheme will
be Resource Processing, being ‘Use of land for treating, processing or packing plant or animal resources.
Examples include an abattoir, animal saleyard, cheese factory, fish processing, milk processing, winery and
sawmilling’. The proposal fits within that definition and will not alter that use.
As the Latrobe Council regarded the production increase proposal as a substantial intensification of the
existing activity, a single Development Application under Section 57 Discretionary Application will be
submitted to the Council.

5 Environmental Licence
Not applicable.

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