Enclosure 6 - ESP Letter

                                                               Ecological Service Professionals
                                                                                   Sustainable Science Solutions




   Figure 25   Aggregation of oysters growing in narrow intertidal band on rock boulders near site 16
               in Lake Weyba (yellow circles indicate oysters)



Historical vs Current Oyster Extent

A conservative estimate of the area occupied by oysters throughout the Noosa Estuary
based on the best available information is presented in Table 4. Conservative estimates
have been used throughout to ensure that the amount of oyster habitat restored would not
substitute habitat other important habitats within the Fish Habitat Area. Based on the
calculations below, the area proposed for the Resource Allocation Authority (RAA; 1440 m2)
represents a small proportion (<3.5%) of the area within the accommodation space likely to
have been harvested (assuming that oyster habitat naturally recovered to the area of the
RAA) and less than 17.5% of the maximum annual harvested area at the peak of the industry
(Table 4). Even if we add the large areas of degraded rubble and oyster aggregations (which
are not the same as oyster beds) to the proposed RAA area, it still occupies conservatively
11 to 54% of the area that should contain oyster habitat within the accommodation space.
Therefore, based on the conservative calculations below, we consider that the proposed
resource allocation application for the purposes of supporting natural restoration of a fish
habitat known to exist in the estuary should not be considered habitat substitution, rather
natural restoration of a small proportion of important estuarine habitat type that was removed
by early settlers of the area, in the same way as previous restoration of marine plants over
bare substrate has been completed in the Noosa River Estuary.