produced for · 2020. 8. 30. · this via a fact sheet posted on the engage vic website. there is a...

Environment Protection Act 1970 Section 20B Conference Report Application: Upgrade of sewage treatment plant in Elliott St, Warrnambool.

Applicant: Wannon Region Water Corporation

Produced for

Conference Date: Wednesday 5 August 2020 Conference Chair: Jennifer Lilburn

Declaration I am the Chairperson appointed under Section 20B of the Environment Protection Act 1970 to preside over a consultation Conference relating to a Works Approval Application by Wannon Region Water Corporation for the upgrade of a sewage treatment plant (STP) in Elliott St, Warrnambool. I hereby submit my report to the Environment Protection Authority as required under the provisions of the Act.

Jennifer Lilburn, Director Kismet Forward

B.Ed Environmental Studies (Deakin University), B.App.Sci Environmental Assessment & Land Use Policy (Deakin University), Adv.Dip Group Facilitation (Groupwork Institute of Australia), Cert. Public Participation (International Association of Public Participation), Cert. Conflict Management Coach Limitations of Use This report has been prepared for EPA Victoria’s consideration as part of its assessment of the Works Approval Application by Wannon Region Water Corporation. The author has included reflections and recommendations that represent an impartial, non-expert view, based on the comments made by community members at the Section 20B Conference held online on 5 August 2020.

Considerable effort has been made to ensure that the report accurately reflects the discussions that took place at the 20B

Conference. However, the feedback by its nature is subjective and not always consistent. It cannot necessarily be construed to be an accurate reflection of the weight of the broader community or stakeholder opinion. No formal statistical analysis of data has been undertaken.

No responsibility or liability can be taken for errors or omissions, or in respect of any use of or reliance upon this report by any third party.

Front cover photo attributable to https://en.wikipedia.org/wiki/Warrnambool

Terms, acronyms and abbreviations used in this document

Applicant Wannon Region Water Corporation CBA Cost-Benefit Analysis

Dirty decant Discharge of untreated or partially treated wastewater

EPA Environment Protection Authority Victoria HHRA Human Health Risk Assessment IDEA Intermittently decanted extended aeration MBR Membrane Bioreactor Technology the Conference The Section 20B Conference STP Sewage treatment plant SEPP State Environment Protection Policy WRWC Wannon Region Water Corporation

https://en.wikipedia.org/wiki/Warrnambool

3 WRWC Works Approval application to upgrade sewage treatment plant 20B Conference Report August 2020

Table of Contents Executive Summary ..................................................................................................................................................................................................... 4

1. Introduction and background .............................................................................................................................................................................. 5 1.1 Summary of the Application .............................................................................................................................................................................. 5 1.2 Timelines and submissions ................................................................................................................................................................................ 5 1.3 The Section 20B Conference .............................................................................................................................................................................. 6 1.4 Invitations and participation .............................................................................................................................................................................. 6 1.5 Conference format ............................................................................................................................................................................................. 7 1.6 This report.......................................................................................................................................................................................................... 7

2. What we heard: Issues and Concerns .................................................................................................................................................................. 9 2.1 Theme A: Discharge quality and impact ............................................................................................................................................................ 9 2.2 Theme B: Treatment system and past compliance .......................................................................................................................................... 14 2.3 Theme C: Concerns with the approval process ................................................................................................................................................ 24 2.4 Theme D: Location ........................................................................................................................................................................................... 28 2.5 Other feedback and questions ......................................................................................................................................................................... 30 2.6 Outstanding Questions .................................................................................................................................................................................... 32

3. Community suggestions ..................................................................................................................................................................................... 33

4. Chair’s reflections and recommendations ......................................................................................................................................................... 36 4.1 An STP that meets future demand and community expectations ................................................................................................................... 36 4.2 Moving towards the reuse of ‘waste’ water .................................................................................................................................................... 37 4.3 Building social licence ...................................................................................................................................................................................... 38 4.4 Improving confidence in WRWC’s reports ....................................................................................................................................................... 39 4.5 Regaining confidence in the EPA ..................................................................................................................................................................... 40

Appendix: Conference Agenda .................................................................................................................................................................................. 41


Executive Summary Wannon Region Water Corporation (WRWC) has applied for a Works Approval to upgrade their sewage treatment plant (STP) in Elliott St, Warrnambool. The upgrade to the plant is needed to increase capacity to manage demand for sewage and wastewater treatment until 2040.

An online community Conference, held on 5 August 2020, was conducted under Section 20B of the Environment Protection Act 1970. The Conference provided an opportunity for 57 community members to raise and discuss opinions and concerns about the proposal. Key points raised by those attending have been documented in this report.

The proximity of the mixing zone to Shelly Beach and popular diving areas is a cause of concern. Many attendees and submitters were worried about current and potential impacts on both human and marine health.

There is considerable concern regarding the 300-metre radius of the mixing zone. The rationale for the 300 metres was questioned, as has the integrity of the modelling used for the mixing zone.

A sentiment amongst many who oppose the upgrade is that the proposal is not best practice and that WRWC should be focussed on delivering Class A recycled water for wide reuse. WRWC is seen as not having sufficiently investigated alternative paths for the upgrade.

There was a common call for tertiary treatment for the wastewater. It is acknowledged that the applicant has endeavoured to address this via a fact sheet posted on the Engage Vic website.

There is a strong belief that trade waste customers should be more responsible for their waste products and should share more of the cost burden of any upgrade.

WRWC’s effluent screening is seen as inadequate as it does not capture microfibres or microplastics below 1mm. There is also considerable anger directed at WRWC for its claim that a percentage of the plastics found on local beaches is from sources other than its outfall.

Feedback from some participants indicates a level of distrust of the applicant and the transparency of its communications, especially regarding the proposal. There is also community scepticism regarding the stated benefits of the proposal.

EPA and the applicant have critical roles to play in acknowledging community concerns and transparently and thoroughly explaining how future environmental and health impacts will be negated.

Nineteen recommendations are included in this report. These aim to achieve the following:

• An STP that meets future demand and community expectations • Moving towards reuse of ‘waste’water • Building social licence • Improving confidence in WRWC’s reports • Regaining confidence in the EPA


1. Introduction and background 1.1 Summary of the Application Wannon Region Water Corporation (WRWC) has applied for a Works Approval to upgrade their sewage treatment plant (STP) in Elliott St, Warrnambool. According to the applicant, the upgrade to the plant is needed to increase capacity to manage demand for sewage and wastewater treatment until 2040.

WRWC proposes installing a new inlet screening facility. The proposal also includes two new intermittently decanted extended aeration (IDEA) tanks at the site.

The existing STP treatment process begins with coarse inlet screening to remove solids and non-biodegradable materials prior to flows entering the IDEA tanks for treatment. Once treated, effluent undergoes further fine screening through a series of tertiary screens (currently WRWC is engaged in a project to install a 1 mm screen automated tertiary effluent screen) before being discharged directly into the Southern Ocean at Thunder Point.

1 https://s3.ap-southeast-2.amazonaws.com/hdp.au.prod.app.vic-engage.files/4915/9677/9601/S22_Notice_Wannon_Water_-_Final_7_Aug_2020_q.pdf

1.2 Timelines and submissions The Works Approval application was received by EPA on 15 April 2020. On 20 May 2020 EPA advertised the opportunity for community comment on the Application in metropolitan and local newspapers and accepted public submissions until 1 July 2020. The community was invited to ask EPA and the applicant questions from 20 May 2020 - 24 June 2020.

EPA Victoria received 83 submissions.

All submissions to the EPA can be viewed at https://engage.vic.gov.au/epa-works-approvals/wannon-water.

In response to the submissions, on 7 August 2020 EPA issued a Notice to Supply Further Information under Section 22 of the Environment Protection Act 1970.1 The Notice requested the applicant to supply (among other things):

• A Human Health Risk Assessment, particularly targeted at users of the coastal area around Thunder Point,

• A revised proposal that complies with SEPP (Waters) for marine waters outside the current mixing zone, and

• An explanation of, monitoring processes for, and mitigating solutions for the risk of ‘dirty decants’ and microplastics discharge, which have occurred in recent years.

https://s3.ap-southeast-2.amazonaws.com/hdp.au.prod.app.vic-engage.files/4915/9677/9601/S22_Notice_Wannon_Water_-_Final_7_Aug_2020_q.pdf



https://engage.vic.gov.au/epa-works-approvals/wannon-water


1.3 The Section 20B Conference A face-to-face public forum was not possible due to Covid-19 restrictions. Instead, an online Section 20B Conference (‘the Conference’) was held on Wednesday 5 August 2020 7-9 pm.

As part of the Conference process, an online forum was held via https://engage.vic.gov.au/epa-works-approvals/wannon-water between 1 and 30 July 2020. This forum enabled community members to ask questions and make a comment for consideration at the Conference.

The purpose of the Conference was: • For EPA to gain a better understanding of community concerns

and issues that need to be considered; • To inform the public about the Works Approval application, the

assessment processes and its current status; • To identify potential resolutions for issues relating to the

Application; and • For the community to raise any additional matters relevant to

EPA’s assessment. The Conference was chaired by independent facilitator Jennifer Lilburn of Kismet Forward. It took place via MS Live Events.

Under section 20B(4) of the Environment Protection Act 1970, ‘The Authority shall take into consideration the discussions and resolutions of any Conference under this section and the recommendation of any person presiding at that Conference.’

2 https://engage.vic.gov.au/epa-works-approvals/wannon-water

1.4 Invitations and participation The Conference was advertised on the Engage Victoria website2, and invitations were sent directly to all people who had lodged a submission to EPA.

Twelve participants took part in the production of a community video that outlined their views. Nine people took part in the online question and answer forum.

Fifty-seven people attended the online Conference, mostly from the Warrnambool area but some from as far away as Canberra. It was acknowledged that the project is proposed for the traditional lands of the Eastern Marr, however participants were also based on Wadawurrung/Wathaurung, Wurundjeri, Yorta Yorta, Bunurong, Ngunnawal, and Gunditjmara lands. Participants comprised a mix of community members as well as observers from EPA, WRWC and local government.

Five representatives of EPA were present at the Conference to explain the Works Approval assessment process, and the submissions received, and to assist with the moderation of online feedback. Three representatives of the applicant were also present to explain the proposal and to respond to community feedback firsthand.




1.5 Conference format The Conference was held online due to the Covid-19 restrictions preventing face-to-face meetings.

A copy of the agenda is provided as an Appendix.

The Conference was opened by Stephen Adamthwaite, Manager Development Assessments Unit (EPA) EPA Victoria, who acknowledged Country, welcomed everyone and thanked them for their attendance. Facilitator Jen Lilburn then ran through the format for the meeting.

This was followed by a short video presentation from Andrew Jeffers, Managing Director, WRWC, who briefly outlined the development proposal.

Stephen Adamthwaite outlined the EPA Works Approval process.

David Robinson, Project Officer Development Assessments, EPA, provided by pre-recorded video a summary of the issues and concerns that were raised through the 83 submissions regarding the proposal. These had been categorised into five themes: Theme A: Discharge Impact Theme B: Treatment System Theme C: Discharge Quality Theme D: Regulatory/Approval Process Theme E: Location

A second video featuring Andrew Jeffers of WRWC and other WRWC representatives was played which was developed in response to questions and concerns raised in the community submissions. It was noted that the video intended to generate discussion at the 20B Conference.

A video developed by community members outlining their concerns with the proposal was also played.

All presentations are available at https://engage.vic.gov.au/epa-works-approvals/wannon-water.

Participants were invited to post questions and comments about the proposal, add any further issues and concerns which had not been captured in the summary document, and suggest ideas that could minimise their concerns should the proposed development proceed.

It is noted that there were some technical difficulties during the Conference, for which the facilitator apologises.

1.6 This report The key output of the Conference is this report documenting the key issues, opinions, and concerns of Conference participants, along with possible solutions to issues raised. Comments, questions and responses by attendees, WRWC and EPA have been edited, with every effort made to preserve the intent.

Due to the considerable overlap between themes, the author has combined feedback for Theme A: Discharge Impact, and Theme C: Discharge Quality into a single theme of A: Discharge Quality and Impact. Comments related to previous compliance have been added to Theme B: Treatment system, also to reduce overlap.

It is also important to note that the author has placed community feedback where it appears to be a ‘best fit’. For example, all comments relating to the mixing zone have been placed under the sub-heading of Impact on Human Health. This is because the primary intent of the mixing zone is to protect health.

https://engage.vic.gov.au/epa-works-approvals/gillieston-meat-processing-facility-works-approval-application





Because of the online format of the consultation process, there were various ways in which people could provide input to the process. The following icons indicate the source of community feedback. All feedback without an icon was received during the Conference.

Community video

Online forum

Support for comment or question (indicated by the number of ‘likes’ attributed during the Conference)

The brief for the 20B Conference Chair highlighted that the Conference Report should:

• Provide an independent perspective of the Conference; • Highlight issues raised during the Conference; • Identify issues that were resolved; and • Make recommendations about aspects that the Chair deems

as requiring scrutiny by EPA as it decides on the Application. EPA Victoria staff will consider this report during their assessments of WRWC’s Application.

It is highlighted that the author of this report neither agrees nor disagrees with statements made by community members or the applicant at the Conference or the online forum. Comments are included in this report without endorsement or judgement of them or their veracity.

It is NOT within the scope of this report or the author to recommend whether the Application should be approved or rejected.


2. What we heard: Issues and Concerns 2.1 Theme A: Discharge quality and impact

Priority issues within this theme3 • Concerns with mixing zone modelling and testing • The potential impact on human health and the marine environment • A desire for discharged water to be Class A standard

Summary of community feedback EPA provided a summary of community concerns about this theme from the submissions. Subthemes for which there was additional feedback or questions during the Conference are listed in the first column below. A consolidated summary of additional feedback from Conference participants is shown in the second column below. This column includes comments and questions in the community-produced video or posted on the Engage Victoria online forum . Responses by WRWC and EPA have also been edited/summarised.

Submission feedback4 Additional Conference/online forum feedback Response by WRWC/EPA

Risk to human health (inc comments about the mixing zone) (39 submitters) • Risks to human health, both

inside and outside of the mixing zone, from exposure to the effluent/dirty decants via fishing, diving, snorkelling and rock pooling.

• Secondary treated sewage water is high in pathogens such as bacteria and viruses and poses risks to the public. The faecal bacteria levels are 12 x what's permitted. According to the World Health Organisation, if you swim in this water, you've got a 1 in 20 chance of becoming ill. x 2

WRWC: The EPA has approved a mixing zone from the point of discharge to 300m offshore. Within the mixing zone, it is accepted that there may be some risks associated with the discharge of treated effluent. We undertake routine monitoring within the mixing zone and beyond to establish if the Warrnambool STP is having an

3 Priority issues were identified by the number of similar comments and the level of support indicated during the Conference. 4 These had been raised via community submissions before the Conference and were presented for the online forum and during the 20B Conference as a basis for discussion. Some further consolidation of this summary has been done



• The mixing zone assessment has been undertaken considering the median wave height of 2.5m. This analysis does not consider that recreational use of this area with primary contact (e.g. diving, snorkelling) will largely occur during the calmest days of the year.

• Diving and snorkelling websites promote Thunder Point and Merri Marine Sanctuary because of the diversity of marine life. What's the point of having this great spot for recreation if you can't use it because of the nearby outfall? x 2

• Is it safe for humans within the mixing zone? The current 'mixing zone' has a radius of 300m, which means 600m of the coastal park is unsafe for recreational use. x 5

• There is only a single sample point that extends to the Merri Sanctuary in the mixing zone modelling. There is no replicated study. The hydrodynamic model that should inform the mixing model is inherently flawed. Discharge mixing has been examined to the 300m boundary across 3 three sampling events with a single data point at 800m. Extrapolating outside the bounds of the data does not provide useful information: (1) Shelly Beach is not used widely - no data provided to demonstrate that this is the case. (2) the closest high-use beach is the Flume, but Stingray Bay is closer at 1.3km (3) discharge monitoring is only conducted to the 300m boundary - no data beyond this area. (4) Modelling of dispersal is entirely based on the swell, not winds and currents. (5) lateral dispersal from wind and currents during prevailing westerly wind conditions have not been addressed. The main

impact on the receiving environment or if there is a risk to the beneficial uses. The latest investigation stated that within the mixing zone, there is no evidence of harm to humans, unacceptable impacts on plants and animals, loss of aesthetic enjoyment or objectionable odour. WRWC: We strongly urge the public not to undertake recreational activities within the mixing zone, and there are warning signs discouraging people from swimming. WRWC: The 300m mixing zone was used as the basis of the empirical modelling as this is the Warrnambool STP's EPA licenced mixing zone. WRWC: In developing the model, we ground-proofed some of the outputs based on current conditions, used the sampling and impacts on the environment from our routine monitoring to date. That gave us confidence that the model was suitable for the current situation, if not a little conservative. From this, we extrapolated future scenarios at higher flows. EPA: EPA expects the performance of discharges to improve over time, especially where mixing zones are used, but this expectation may be offset to some degree by increasing pollution loads (e.g. population growth). EPA will regularly review licences to ensure in the long term that facilities are as close to best practice as



problem is the use of a global wave model, resolution 50km to provide info on coastal hydrodynamics. x 29

• What is the underlying rationale for the 300m mixing zone? There is no clear basis for using this in the zone modelling document. What if there are inherent issues regarding the modelling? x 12

• Does the EPA expect standards for water discharge from outfalls to become more stringent as our understanding of the impact of pollution becomes more evident? How will this impact the current approval? x 4

• Has E.coli or enterococci at the periphery been measured regularly in times of low mixing? Will E.coli/phosphorus levels be carefully monitored at nearby swimming beaches? x 3

• What is the treatment level of your effluent at the point of discharge? x 4

• Perisher snowfields recently report COVID-19 detected in sewage. Human and animal waste have many pathogens that pose a risk. What capacity does WRWC have to test for pathogens prior to ocean discharge? x 2

reasonably possible and meet Victorian policy and community expectations. WRWC: E.coli and enterococci are measured routinely, typically at low tides and during periods of low mixing to enable safe access. The most recent results showed that the concentrations ranged from 0-4orgs/100ml and 0-3orgs/100ml, respectively. EPA: The level of nutrients and pathogens in the discharge are matters EPA will consider during the assessment of the Application. WRWC: Wastewater will have undergone primary and secondary treatment with tertiary screening prior to discharge. WRWC: We comply with our testing obligations as per our approved EPA licence. Testing for pathogens is undertaken with guidance from the EPA. We participate in research and development programs investigating other potential pathogens as per other water authorities.



Impact on the marine environment Management and monitoring of the marine environment (24+5 submitters)

• The risk to the marine environment not been adequately addressed in the proposal.

• Continued ecological damage/impacts on the natural environment, including Belfast Coastal Reserve and Merri Marine Sanctuary.

• Lack of monitoring outside 300m mixing zone

• WRWC's monitoring leaves a lot to be desired

• Plastics cause environmental damage that can cascade through ecosystems.

• WRWC's current attitude towards polluting plastics in the marine environment is ambiguous. In its risk register, it acknowledges that the likelihood of plastics discharging into the ocean with the current controls is highly likely, but with low consequence.

• Impact on the kelp beds and habitat. x 3 • High phosphorus and nutrient concentrations

in the wastewater lead to algal blooms, and algae blooms can be toxic to aquatic species and us.

• Have studies been done on the impact of sewage on the Merri Marine Sanctuary? The weedy sea dragon is a nationally threatened species because of human impacts on inshore habitats. x 15

• Are the marine survey reports available online? x 4

WRWC: There are ecological studies undertaken at the ocean outfall. Independent specialist reports which assess the impacts within the mixing zone are included in the Works Approval application. The reports note that at a broad level, there are minor impacts within the mixing zone, but no impacts outside the mixing zone. We will continue to monitor the marine environment routinely and undertake future augmentations as required to manage risks to beneficial use, considering any licencing requirements from the EPA. EPA: The marine survey reports accompany the EPA Works Approval submission.

Discharge should be Class A standard (5 submitters)

• I want tertiary class A+ water treatment to be added to the wastewater treatment plant, and I want the state government to pay for it.

• Has an economic evaluation of this proposal versus Class A water treatment been done?/ There is no economic argument that says they don't need to do tertiary treatment on that plant/ How much would it cost to do tertiary alongside an upgrade? x 12

WRWC: The cost is dependent on the level of treatment required and the technology needed to reach that quality. A typical tertiary treatment plant to produce Class A quality water (excluding any supply infrastructure), would cost $30-40 million to construct, on top of the proposed $40



• Class A is good enough for Melbourne’s ETP, why not Warrnambool? x 5

million capacity upgrade. There would also be ongoing treatment cost, which could be $2 to $3 million per year, which would significantly impact all customer bills. We have a fact sheet on our project web page that has a link on the EPA approval page. We need to undergo this upgrade before going to tertiary treatment. https://WRWCw.wannonwater.com.au/news-projects/projects/warrnambool-sewage-treatment-plant-upgrade.aspx#tertiary-treatment-and-class-a-water

Should consider wetlands and eco forest as a form of reuse (1 submitter) • All the wastewater from the STP can be pumped

into a large wetland. This will encourage more wildlife and tourism. Look at Byron Bay's wetlands and the 750,000 trees planted to help soak up the water. x 2

WRWC: WRWC is not against recycling treated effluent. Currently, the costs are prohibitive for such a scheme. Many other environmental and social considerations would need to be considered. We are committed to exploring these options in the future.

https://www.wannonwater.com.au/news-projects/projects/warrnambool-sewage-treatment-plant-upgrade.aspx#tertiary-treatment-and-class-a-water




2.2 Theme B: Treatment system and past compliance

Priority issues within this theme5 • Failure of the applicant to adequately consider other treatment systems and methods including reuse of ‘waste’ water • Trade customers should treat waste to a higher level, particularly to reduce high phosphorus inputs to the STP • Discharge of microplastics and other solids into the ocean

Summary of community feedback EPA provided a summary of community concerns about this theme from the submissions. Subthemes for which there was additional feedback or questions during the Conference are listed in the first column below. A consolidated summary of additional feedback from Conference participants is shown in the second column below. This column includes comments and questions in the community-produced video or posted on the online forum . Responses by WRWC and EPA have also been edited/summarised.

Submission feedback6 Additional Conference/online forum feedback

Response by WRWC/EPA

The outfall is the wrong solution, not best practice, should be reuse Inadequate exploration of alternatives



(36+20 submitters)

• Disposal should be land-based and create useable by-products.

• Ocean discharge is not an environmentally responsible solution for secondary treated wastewater in any developed country.

• The Warrnambool community can benefit from plans to upgrade the technologies rather than simply expanding the existing treatment systems.

• More research investment should be devoted toward tertiary treatment options as the proposed upgrade does not offer a significant reduction of environmental impacts and only seeks to maintain increase capacity.

• The proposal by WRWC to dump excessive amounts of poorly treated trade waste, via a domestic outfall into our great Southern Ocean, is a stark rejection of the Victorian standard set by the Melbourne Eastern Treatment Plan.

• The proposed works do not include any measures to improve the capacity or performance of the existing secondary treatment process. x 2

• If the expansion of residential properties is fuelling the upgrade, then the aerated treatment plants will help. x 2

• This $40 Million expansion does not include better treatment of wastewater but is based on the same technology that has failed us and our fragile marine environment for far too long. The current system is already decades behind modern practices in wastewater treatment.

• Technologies considered for the upgrade of the existing plant in its current location were assessed based only on their ability to meet the current (lenient) effluent quality requirements – not the improved effluent quality required to protect human health and the environment.

• With the growth of Warrnambool and surrounds, it is worth considering investing in

WRWC: We considered different treatment options, including an anaerobic digestive system; these have been in use at sewage treatment plants for more than a century. Anaerobic treatment is not considered viable at Warrnambool due to: • This technology is best suited to industrial

waste only. The IDEA process has a proven history of compliance at Warrnambool and provides the flexibility to handle varying incoming sewage from domestic and industrial customers.

• It has risks, including odour, by-product production, and off-gas disposal, which would cause public impacts.

• The cost to construct a new plant would be significant. The existing gravity sewer network would also need to be extensively modified to send sewage to a plant in a different location.

Upgrading the existing plant provides a cost-effective solution that will meet current EPA licence requirements. The decision is based on a balanced outcome where environmental, social and financial aspects were considered. WRWC: Alternative inland sites were considered in the initial planning stages of the project, along with investigations into potential options for recycled water use, but these were not currently viable. The Warrnambool sewerage system is


a system that will be able to manage the forecast increase in waste.

• Has any consideration been given to a state-of-the-art bio digestive system? These systems would have to exist as not every area has an ocean nearby to pollute.

• Did WRWC consider options that do not include discharge into the ocean? x 3

• Many councils reuse and highly treat their wastewater. We need more storage and more cutting-edge technologies in recycling this valuable resource. We need to use this wastewater to drought-proof our environment. It is only wastewater if you waste it. x 6

• Have you considered extending the outfall pipeline into the sea to increase mixing and reduce impacts on the coast? x 2

• If discharging to the ocean is not good for the environment or wanted by the community, why does the government and the EPA still allow it? x 4

• If the upgrade isn't approved, how is the plant going to cope going forward if it’s at capacity now? x 3

• If WRWC achieves approval under the current proposal, what would encourage or require them to implement tertiary treatment, or drive their trade waste

based on a complex network of mains that flow by gravity to the lowest point in the system - the existing Warrnambool STP. To change this would require extensive and intrusive modifications in community spaces, streetscapes and private properties at a high cost to our customer base. It would also involve the use of additional pumps, adding to ongoing environmental impacts and customer bills. WRWC: Other councils and water corporations recycle, and the implementation and scale of these facilities vary depending on local drivers. WRWC: It was found that the outfall would have to extend 800m offshore, costing around $10M. We are not against this as a future option, but it was not included within the scope of the proposed upgrade for several reasons. Please refer to Section 8.4 of our Works Approval Application. WRWC: Our EPA discharge licence governs us for each STP site within our service region. Each plant has a unique Licence, which is based on the raw sewage characteristics and the receiving environment. The EPA undertakes extensive reviews of the types of treatment used and considers the impacts that each plant is likely to have on the receiving environment. WRWC: If the upgrade isn't approved, the project can't proceed. WRWC would have to reduce trade waste from industry, and that would impact the operation and capacity of their businesses,


customers to achieve treatment at source, before 2040 (the Works Approvals design horizon)? x 4

• There are plenty of STPs which are not on the coast. x 1

which will result in a reduction in jobs and lost opportunity for growth. WRWC: As part of the development of our next Price Submission (capital works program), we have committed to engage with the community in 2021/22 about tertiary treatment at Warrnambool. If a viable use or sufficient public support for tertiary treatment facility were found, WRWC would include the project in the Price Submission and seek approval from the Essential Services Commission. This would need to be funded through additional payments from customers as a voluntary improvement upgrade or by the users of the recycled water. If the EPA required tertiary treatment as a new licence condition for the Warrnambool STP, WRWC would have to plan further upgrade projects to move towards compliance with the new requirements. Funding would need to be from additional payments by our customers unless there was a substantial government funding contribution.

Trade waste customers should treat their waste to a higher level High phosphorus levels (26+20 submitters)

• Companies should not be subsidised by the taxpayer or other WRWC customers but encouraged to invest in their onsite treatment.

• Mixing domestic with trade causes problems • If your Trade waste customers treat their

waste, then how come there is so much fat in the wastewater that arrives at the plant?

WRWC: We constantly discuss quality improvement upgrades with our major trade waste customers. They pre-treat waste at their sites.


• Industries that create a high proportion of waste should contribute more to the plant upgrade

• Too much emphasis is being placed on handling industrial and trade waste which could be treated offsite, before being received at the treatment plant.

• Phosphorus concentrations from the Warrnambool plant are about 10x higher than for a similar plant treating domestic sewage.

• Phosphorus reduction in concentration and annual kg load should be a major focus of any treatment upgrade plan.

• The phosphorus concentrations in the effluent do not meet the Victorian requirements, and this will damage the environment in this remarkable area.

• Can the EPA recommend industry upgrade their waste before it enters the domestic? x 3

• In Leongatha, Saputo had to upgrade its waste treatment and take responsibility for the cost involved. Has this been explored with a thorough CBA x 4

• How much flow did the receival station that was built in 2013 to treat the region's industrial waste add to the Thunder Point treatment plant load and flow?

• If the plant "does not propose to release excessive amounts of poorly treated trade waste" as stated in the WRWC video, can WRWC explain why the effluent phosphorus limit is more than three times the normal concentration in Australian raw sewage? x 10

• What happened in July 2018 that resulted in 29 breaches concerning phosphorus levels?

x 4 • There is no advantage of combining carbon-

rich waste with phosphorus-rich waste where biological phosphorus removal is not being used. As biological phosphorus removal is not being proposed in the STP upgrade, why not treat the huge phosphorus load at its source, rather than discharging it to the environment? x 5

WRWC: Phosphorus has to be tackled by the customers; the upgrade will not significantly impact it. WRWC: All customers contribute to fat within sewerage, some more than others. Fats tend to solidify in the sewerage pipe systems and at times solidify within the treatment tanks. Solidified fats are removed from the sewerage system at the inlet screening plant, and also at the new tertiary outlet screens. We have individual trade waste agreements with all major and minor trade waste customers. Major trade waste customers have limits on the amount of fats they are permitted to discharge. We have a program that requires minor trade waste customers to clean their grease traps and monitors the performance of major trade waste customers, responding to any observations of increased fats discharged to the sewerage system EPA: EPA can and does encourage both waste minimisation and pre-treatment by industry, but the mechanism to manage these inputs is through Trade Waste Agreements made under the Water Act. WRWC: The brine receival facility was built to accept industrial salty waste, not prescribed waste. WRWC undertook an extensive analysis of the current sewage system and modelled scenarios to forecast future capacity requirements for Warrnambool. The brine receival facility was


• If WRWC does not take trade waste, the respective industries will find sustainable ways of dealing with their waste.

• To say that it would cost jobs is scaremongering. x 9

considered "negligible" for future flow allowances in terms of flow and loading when compared with the sewer network. WRWC: The phosphorus concentration in the Warrnambool STP sewage is elevated due to contributions from trade waste customers. The limit is the EPA licence limit. WRWC: There is no biological phosphorus removal other than that which occurs naturally through the uptake in the biomass in the treatment plant. The carbon-rich waste is used as part of the nitrogen removal process, so it has benefit in that regard. In our trade licence agreements, major customers have phosphorus limits, and we are in constant discussion with them about how phosphorus can be further removed at the source.

Microplastics and other solid waste (29 submitters)

• The plans provide a 1mm screen of the final effluent that will catch visible plastic pieces, but not the true microplastics in the forms of fibre, nanoparticles, and other fine plastic forms used in the home.

• With the next stage of membrane filtration, most of the offending plastics can be removed. This next step was flagged for 2040; we don't

• We still don't know the health consequences of microfibres, but Ausmap research shows microplastics are entering the food chain starting with shellfish and moving up to larger fish and marine mammals. x 1

• WRWC's effluent screening doesn't capture microfibres and microplastics below 1mm such as clothing tag fasteners. What proportion of microplastics passes through a 1mm filter? x 6

WRWC: Microplastics are defined as plastics less than 5mm. Our commissioning of the new screen demonstrated that no solids over 1mm passed through under the test scenarios. We are planning to continue research and development in this area to understand the performance of the screen better. WRWC: About 80% of microplastics are removed through secondary treatment processes. The 1mm screen will remove additional plastics down to that size, but the issue of microplastics is a broader societal issue.


believe we can wait until then to clean up the marine environment.

• Will the new system be able to treat microplastics as per European best practice?

x 3

• Why would plastics from the wider ocean land up in such concentrations at Thunder Point and not other beaches nearby? Isn't WRWC's outflow a much more likely explanation? x 16

WRWC: We have had a reasonably fine screen at the plant since December 2017. Over ten months, we collected plastics that got through the inlet screens for the treatment plant, and the quantities collected did not represent the amount of plastic on the beach. Some plastics circulate through the ocean currents around the world, and we don't know if what is on the beach is a mixture of these plastics and potentially historical outfall from the plant. Our proposal has a very robust improvement to both inlet and outlet screening treatment.

No backup system for plant failure WRWC poor track record - lack of trust in WRWC or the EPA Amenity – visual Current Licence limits not adequate Ongoing regulation concerns (26+7+11+2+3 submitters)

• I would like to see more thorough emergency contingency plans in the event of a failure

• Redundancies should be put in place so water can be stored if there is a breakdown

• Historically plant failures have only been brought to the EPA and broader community's attention by concerned community members. Numerous times there have been spills, and WRWC has not actively addressed these.

• If there was a major leakage incident at this site, what is the likelihood of effluent draining downhill to the Merri River wetlands? We already know there have been problems with overflow to the ocean - but what about future overflow to land areas? x 2

• Since 2017, Volunteers have recorded 383 occasions of sewage-related pollution at Shelly Beach. More than 40 reports have been made to the EPA when significant gross pollution has occurred. The 98% compliance with the EPA licence reported by WRWC is based on weekly samples. It is measured against extremely lenient effluent quality

WRWC: Raw sewage has never overflowed into the ocean. Any onsite spills are detained within the site boundary. If a substantial spill or a blockage at the start of the plant occurred, the sewer network would back up, spilling at a low spot along the STP driveway near the golf course. There is negligible risk that this could make its way to the Merri River wetlands due to the local terrain. Regarding the possibility of treatment chemicals overflowing, the Warrnambool STP has very small amounts of chemicals onsite, and they are stored and bunded in accordance with regulatory requirements


• Lack of openness, transparency, and honesty in public communications on behalf of WRWC. Not addressing issues such as dirty decants and plastic/fat ball pollution events when reported to them by members of the public.

• With the nurdle spill in November 2017, WRWC did not fess up until social media and the EPA stepped in.

• A history of misinformation and lack of dedication to best practices towards environmental and community concerns have lowered trust in the services of WRWC.

• I have no confidence in WRWC (WRWC) or the EPA. Some of EPA's regulations were downgraded, which allowed WRWC to meet compliance regulations on discharging microplastics into the ocean. Even though the new plant might meet existing EPA regulations, these regulations are not robust enough.

• Visible fatty solids and other waste, brown coloured water/foam near the outfall

requirements when compared to the vast majority of Australian STPs.

• Weak licence conditions – community reported numerous perceived licence breaches such as nurdles, grey sewage sludge, and balls of fat, yet none were seen as licence breaches. The inclusion of the condition "Discharge of wastewater must not contain visible floating foam, oils, grease or litter" on 20 November 2019 resulted in a Pollution Notice that stated copies of 42 breach notices were provided for the period 22 November to 2 December 2019. Why did it take the community reporting multiple pollution incidents to WRWC and the EPA before any action was taken?

• Is WRWC's Board aware of their responsibilities under Victoria's General Environmental Duty legislation concerning the risks to human health and the environment? Are they aware of their liabilities under this upcoming legislation? x 4

• The Thunder Point Coastal Park sewage ocean outfall borders the protected Merri Marine Sanctuary. The treated sewage wastewater discharged is far from clean - plastics such as cotton buds and nurdles have been routinely discharged along with balls of

WRWC: Yes, the Board is aware of their responsibilities under Victoria's General Environmental Duty legislation EPA: For any other participants who would like to know more about Victoria's new Environment Protection Act 2018 including General Environmental Duty: https://WRWCw.epa.vic.gov.au/about-epa/laws/new-laws WRWC: The brown discharge does not occur every day. WRWC: Until the recent amendment where maximum discharge limits were included within the Licence, we did not have to report dirty decants as a licence obligation. With the revised Licence we now report dirty decants.

https://wrwcw.epa.vic.gov.au/about-epa/laws/new-laws


• Grey scum can be seen and smelt. Rockpools contain scum litter and algae blooms

• There have been golf ball-sized fat balls and ricotta cheese-like incidents washing onto the beach.

• Why has the EPA has allowed such a weak licence to be granted in the first place?

• How is it that WRWC can self-regulate their adherence to the EPA licence? How many times has there been an incursion and they have not reported it to the EPA? Does the EPA regularly audit the paperwork at the wastewater treatment plant and does the EPA let these results be made public. It is always tough having one govt agency regulating another govt corporation.

rancid fat, dirty foam, murky brown water, and grey scum wash on the beach.

• Does that dirty brown discharge happen every day? x 1

• The parameters of pollution set by the EPA are not strict enough to offer protection of our marine ecosystems.

• If all the 'answers' go back to the EPA's approved/allowed levels of E.coli, bacteria, phosphorous, calcium, sodium, chloride, etc., then we are in serious trouble. x 6

• If WRWC gains approval to double the plant flow at the current, very poor effluent quality requirements, there will be no requirement for them to seek further EPA approvals or deliver any improvements until after 2040.

• Can WRWC confirm that "dirty decants" do not exceed the licence limits? x 7

High salt inputs to plant limit reuse options (1 submitter) • Why is WRWC not required to remove salt so

that water can be recycled? • Given that there is an elevated level of salt

that would prevent potable reuse, does that also eliminate wetland and farm usage?

WRWC: The Warrnambool sewerage system and STP are based on a user-pays model, whereby customers pay for a proportional amount of the infrastructure and its operating cost based on their contribution to flow and loads. Currently, there is no requirement for salt to be removed before entering the STP or during the treatment process before discharge into the ocean. We do


not incur any additional costs to process the salty sewage, which results in there being no salt charge for our customers. Should a licence condition change or recycling opportunity present requiring salt removal at the Warrnambool STP, the cost to do so would be shared by all customers based on the user pays principle. WRWC: Without separation, incoming sewage streams or specific removal in the treatment process, the elevated level of salt in the influent to results in the treated effluent not being suitable for most reuse applications. WRWC in the early stages of assessing the upgrade options considered separating the waste streams either via a separate plant or at the existing plant. However, the factors regarding environmental, social, and economic issues meant that these options were not considered further. Desalination (reverse osmosis) can decrease the salt concentrations to suitable levels for a wide range of reuse applications. However, the capital and operational costs are relatively high. There are also additional environmental impacts of such processes such as increased greenhouse gas emissions through energy use and production of highly concentrated brine waste that would also need to be considered.


2.3 Theme C: Concerns with the approval process

Priority issues within this theme7 • The need for independent peer review of modelling, testing and reporting • Poor environmental track record of WRWC • The leniency of EPA licence and failure of EPA to adequately monitor breaches • Lack of robust cost-benefit analysis of the proposed upgrade

Summary of submission feedback EPA provided a summary of community concerns about this theme from the submissions. Subthemes for which there was additional feedback or questions during the Conference are listed in the first column below. A consolidated summary of additional feedback from Conference participants is shown in the second column below. This column includes comments and questions in the community-produced video or posted on the Engage Victoria online forum . Responses by WRWC and EPA have also been edited/summarised.

Submission feedback8 Additional Conference/online forum feedback


Inadequate community consultation (6 submitters)

• The promise to keep the wider community fully informed of this project, including the justification for this

• What level of community consultation was undertaken before this? x 3

• Of the 83 submissions received in this process, not one was in support of the project as it stands. How does Wannon Water reconcile such a response if it considers its earlier community

EPA: You can find information on consultation in Wannon Water's Application from pg 9 https://s3.ap-southeast-2.amazonaws.com/hdp.au.prod.app.vic-engage.files/3615/8951/0390/Wbool_STP_Upgrade_Works_Approval_Application_Final_Revision.pdf. The EPA works approval process the timelines are at https://engage.vic.gov.au/epa-works-approvals/wannon-water


https://s3.ap-southeast-2.amazonaws.com/hdp.au.prod.app.vic-engage.files/3615/8951/0390/Wbool_STP_Upgrade_Works_Approval_Application_Final_Revision.pdf






option has not been met. From what I can see, there has not been a single post this year on the WRWC Facebook page about the proposal.

consultation process to have been successful?

WRWC: The Warrnambool STP provides wastewater treatment services to more than 37,000 people. An advertisement seeking expressions of interest to participate in the Stakeholder Reference Group (SRG) was published in the Warrnambool Standard, in a letterbox drop to residents in a wide surrounding area, and direct correspondence to community groups and major customers. The SRG comprised members from a broad cross-section of our customer base and community and met at two workshops to consider the proposal and inform our decision. The subsequent nurdle event (an Australian first) sparked greater community interest in the issue of marine plastics. Since then, we’ve consulted with the community and put additional measures in place that were not part of the original upgrade project, including new manual effluent screens and a new automatic effluent screen. We also initiated and sponsored the Clean Oceans Collective providing $30,000 in seed funding for the program which included workshops, training volunteers to contribute information about ocean debris to a national database and investigate source reduction plans. We remain committed to listening to our community. Once the community engagement process is completed, we will adopt the advice received from our regulatory authorities and investigate the merit of any suggestions put forward by the community.

Length of time of commitment - short term solution locked in for 20 years (2 submitters)

• We will have a system for the next 20 years that is based not on the latest technology,

• What will we do in 20 years - double capacity again? x 3

• How much room is there on the site for future expansion - after this planned stage?

WRWC: The proposed upgrade is based on a modelled future scenario predicted to occur in nominally 2040. This factored in anticipated population growth along with input with major trade waste customers (existing and new).


but old technology that already fails, with these failures, often kept from the general public.

• The proposed upgrade offers nothing more than an expensive band-aid, short-term solution.

The inlet screening facility has been designed with allowances for flow capacity up to 2065 predicted flows, and this structure cannot be easily expanded. The inlet screening facility and proposed new IDEA tanks have been designed with allowances for Membrane Bioreactor Technology (MBR) to allow for a more rapid technology upgrade in the future should additional capacity or treatment quality objectives change. Details on this can be found in the Works Approval application. The proposed upgrade has been designed to allow future expansion/upgrades, but WRWC will review the entire system to ensure that an expansion or upgrade is the correct decision at that time. WRWC: There is an area earmarked for future expansions and upgrades.

The proposal needs peer review

• Q: Will the proposal be subject to scientific peer review? x 14

• Q: How can in-house experts decide on this matter independently? Surely external reviews are essential. x 6

• Q: Why do some of the questioners think that EPA would not be independent? x 3

EPA: EPA's assessment will include a scientific review of all technical materials submitted within the Application. We have internal scientists and engineers with expertise in wastewater treatment technologies and impacts on marine environments from this kind of waste stream. We will utilise them to form our decision. At times, we go to third party expertise to support our assessment making. We don't do that in every case; it depends on what expertise we think is relevant to assist with our assessment. EPA: We are independent of the applicant - we do not have a vested interest in approving the proposal and will assess it on its merits.

Modelling

• The proposal looks to double the current approved flow and more than

WRWC: The proposal allows for roughly 100% flow increase and a 50% load or level of contaminant increase in the sewage. This stems


double the current load - that is, a 100% increase. Why is it only proposed to increase the secondary treatment capacity by 50%? This will just result in greater overload. x 2

from forecasts based on residential growth and growth in the industry around the region. It's always important that any time we look at an upgrade project, we envisage various growth scenarios that might play out in the future. This enables us to forecast factors including future contaminant levels within the sewage, which formed the basis for the upgrade proposal.


2.4 Theme D: Location

Priority issues within this theme9 • Plant location is too close to public beaches and housing

Summary of community feedback EPA provided a summary of community concerns about this theme from the submissions. Subthemes for which there was additional feedback or questions during the Conference are listed in the first column below. A consolidated summary of additional feedback from Conference participants is shown in the second column below. This column includes comments and questions in the community-produced video or posted on the Engage Victoria online forum . Responses by WRWC and EPA have also been edited/summarised.


Adjacent to a marine park Site location is unsuitable (11+1 submitters) • The marine park is nearby with

important kelp ecosystems that support marine life such as the common sea dragon.

• STP too close to public access areas, proximity to residential housing, increased transport of dry waste through developed residential areas, increased

• Given the amount of industrial waste being treated and the proposed expansion, WRWC plant is too close to public beaches and housing developments. x 2

• I am not reassured that this process of looking for separate sites involved adequate community consultation, and I would like to see it revisited and assessed by an independent and impartial authority.

x 4

WRWC: The treatment plant upgrade will include foul air treatment which is not currently part of the existing plant and will protect amenity. WRWC: The mixing zone does not extend to Shelly Beach – see satellite picture on page 31 of the Works Approval application. WRWC: The initial stages of this project involved looking at various alternatives




effluent volume, unknown contaminants in the effluent, changing profile of waste, unknown risks to public health.

• What about when people from the new housing estate start accessing Shelly Beach and Second Bay for swimming and other recreation? x 1

• The treatment plant services Warrnambool, Koroit and Allansford. Could services be divided to enable the development of another system elsewhere? x 1

• Who owns the site?

including treatment plants to the west, east, and north WRWC: WRWC is the committee of management of the site where the treatment tanks are located and where the expansion of the extra tanks would go. While it is Crown land, WRWC has responsibility for that land.


2.5 Other feedback and questions A consolidated summary of additional feedback from Conference participants is shown in the first column below. This column includes comments and questions in the community-produced video or posted on the Engage Victoria online forum . Responses by WRWC and EPA have also been edited/summarised.

Additional Conference/online forum feedback


Public action, awareness and education

• Expecting our 'society' to reduce using this and that is not a reality. Let's stop this at the STP and start using our intelligence. More storage, less waste. x 4

• Should we as the public look at what we use and eliminate a lot of the microplastics and other "non-organics" we are adding? x 2

• Was the plant originally constructed to 'treat’ cotton buds, nurdles, fat balls, and anything else that we the public are happy to be rid of? x 4

WRWC: In the 1930s, raw sewage was discharged in the same approximate location as the treated effluent is released today. Over time, significant upgrades have occurred to provide better treatment. The proposed upgrade is another step in improving the treatment process and protecting the environment. WRWC also has a campaign to raise awareness around the impacts of flushing material down the drain. Elimination at the source is preferred rather than treating at the end of the pipe.

Chemical/other risks • Concerns re trucks transporting waste and

chemicals – is it safe? • What heavy metals or chemicals are being

treated at the sewage plant? x 1

WRWC: There is no truck waste to the site; it all comes by pipe. There is a septic receiver facility located at the site. Properties with septic tanks get them pumped out every three years, and the waste goes to the septic receiver facility. There are no chemicals, just septage. The only chemical other than cleaning chemicals for equipment is polymer, which is used as part of the biosolids dewatering process. WRWC: The treatment plant treats a range of heavy metals and chemicals through the biological process and settle out or are oxidised in the biological treatment process




Costs and economics • Acceptance of the proposal would result in a

large shift in costs, both financial and environmental, from corporations to Warrnambool’s community.

• Was cost the over-riding factor for not building a tertiary treatment plant now? For example, if membrane treatments are under consideration for the future, why not install such technology now?

• What are the ongoing costs of this upgrade? • Distributional consequences of the proposal x

1 • We can't get an understanding of costs unless

we understand what your trade waste producers are paying. This makes it difficult to believe a "jobs" justification.

• Meeting minimum standards is the focus, and the short-term economy depends on this. How can we lobby for greater recognition and investment for "beyond" solutions, and how is this being communicated up the chain, if at all?

x 4

WRWC: Cost was just one of the weighting factors used in the multi-criteria assessment. The proposed upgrade was selected as the best overall option based on: • Treatment reliability and flexibility • Capacity for future growth • Capital and operational cost • The overall impact on the environment • EPA discharge licence requirements • Advice from our technical design experts • The need to continue the operation of the existing treatment plant during

construction. This option also paves the way for future tertiary treatment, such as MBR, when certain triggers or drivers occur. WRWC: The ongoing costs include increased aeration demand, substrate dosing, and more general operational costs with running a larger facility. WRWC estimates that electricity consumption will gradually double as the flow and loading to the site increases through to 2040. In terms of actual operational costs based on 2040 forecasts, we estimate they would be around $500,000-$600,000 per year. WRWC is a not-for-profit organisation reliant on income from customers to fund operations and capital projects. Each year we engage with representatives from our entire community base to determine their priorities. The latest engagement found that customers want us to continue to protect the environment. However, they would like to see bills remain as low as possible. We do not object to treating our wastewater beyond the requirements of our approved EPA licence, but this would involve additional infrastructure and operational costs, ultimately impacting all customer bills. WRWC




actively lobbied both the federal and state government for funding to help meet the cost of the proposed upgrade, but this was unsuccessful.

2.6 Outstanding Questions

• Has WRWC considered the potential economic impacts on the local economy/tourism industry, that doubling E.coli levels may have if it is found that levels are substantially higher than they should be at local swimming beaches?

• Relying on the "mixing zone" to achieve disinfection by dilution effectively introduces antibiotic-resistant bacteria to the environment without barrier, from where they can move through the food chain. Has this been considered by the EPA in setting conditions, and WRWC in the human health risks? x 3

• Could local government pass requirements that each new housing development has its own aerated wastewater treatment plant which services 6-8 properties and then this relatively clean water can then start its journey down the sewer? Councils could also give ratepayers a treatment block of chlorine that can be placed into each toilet in each household. This would decrease the amount of sewage needing treatment at the STP.

• WRWC is not dealing with microplastics under 1mm such as

microfibres and smaller plastics such as clothing tag fasteners. That means if the public wants to stop this themselves (at source), then they would need to purchase a microfibre filter for their washing machine for $300+. Is this what WRWC expects the residents of Warrnambool to do?

• What research has been commissioned on microplastics <1mm carrying bacteria and viruses towards Warrnambool beaches and beyond? x 1

• Are Middle Island's Little Penguins eating plastic from the outflow? What is the impact on Whales at Logan's Beach? x 1

• What weighting did WRWC use for the environment in their decision process (in the graph it appeared to be about a 30% weighting)? What weighting was financial given?


3. Community suggestions Conference attendees and online forum respondents were asked: “If the proposed development were to proceed, what could be done to minimise your concerns? (e.g. ideas for design or operation of the site)”. Their consolidated ideas follow.

Improve confidence in monitoring and studies • Require a full Environmental Impact Statement or equivalent to

ensure that the proposed discharge has no detrimental impact on the environment and protects the environment and users of the Thunder Point area.

• Peer review of the consultants' reports x 3 • Fix bad modelling

Address health concerns • Public safety and health risks in and around the mixing zone

need to be adequately addressed.

Review of 300-metre mixing zone radius • Mixing zone range should be along the coast, not circular. Extend

1km on each side of the outfall and 300m offshore x 2

Look at alternatives for the use of treated wastewater rather than ocean outfall • Look at the success of other councils- e.g. Shoalhaven Shire,

Byron Bay Shire, Parkes City Shire, Sunshine Coast Shire, East Gippsland Water. x 11

• Future proof it as a wetland refuge - treated wastewater could remake Lake Wangoom, or be an environmental water supply to Tower Hill.

• https://ecoteam.com.au/services/constructed-wetlands/

• Other countries drink their treated wastewater x 1 • Why put anything in the ocean? Let's pretend the easy option is

not available. x 8 • There are widely used alternatives that will protect our

environment and health, and enable our community to benefit from the water, energy, and nutrients available in our sewage. Treating Thunder Point as a dumping ground for our sewage and wastewater is no longer acceptable. It’s time for change. Give Warrnambool the clean, blue backyard it deserves.

• The solution is not a one-size-fits-all. We need to harness many systems. Wetlands, mop crops such as hemp, bamboo, and tree lots, large wet weather storage dams, irrigation for farmers, public spaces, domestic aerated wastewater treatment plants, reed beds, eco-forests. Most of all, the will to lead the way in dealing with our waste! x 1

• We need to adopt a circular economy approach with our waste. No more linear solutions, which create more problems x 2

Upgrade to Class A • Upgrade to A+ is the only ethical solution. The plant should be

considered a resource recovery facility x 3

Trade waste customers should improve treatment

• Impose trade waste controls to ensure their discharges are at pollutant concentrations typical of normal municipal sewage.

https://ecoteam.com.au/services/constructed-wetlands/


Consider phosphorus and nitrogen removal at Warrnambool Cheese and Butter and nitrogen removal at Midfield. This is much more efficiently achieved prior to discharge to sewer – even more so using modern technologies such as struvite precipitation or deammonification.

• WRWC should work with their industrial trade waste customers to mitigate against plastic pellets (nurdles) and other plastics in the wastewater stream. These features (sound trade waste controls, filtration, disinfection) are common practice at the majority of the STPs – why not in this plant?

Treatment suggestions • Impose effluent quality criteria for solids (10 mg/L), gross solids

(nil), total phosphorus (<6, which is efficiently achieved for typical sewage), total nitrogen (<10) and enterococci (<35 at discharge), all in line with accepted modern practice. x 6

• Require effluent disinfection before discharge/ Reduce the amount of enterococcus and phosphorus entering the environment. x 7

• Utilise low head (and low power) disk or cloth media filtration to 5 or10 microns rather than effluent screening. This will provide superior protection for the plastics being discharged under current operations for low additional capital and operating costs.

x 7 • Ensure that the upgrade works proposed will be sufficient to

treat the projected load • Has potable reuse been considered? x 2 (WRWC: Potable

reuse has not been considered as part of this upgrade and this is

unlikely to be viable due to the salt content of the wastewater and availability of water in the region.)

Improve public awareness and communications • Public awareness of the site appears to be poor. Locals are

genuinely surprised to know their sewage ends up in the ocean. Consider a 24-hr, public live feed. School groups could monitor it as a project to alert them to the problems they will face when the system once again reaches capacity in 2040 x 3

• Tours of the plant for local primary school children so they can understand what world-class best practice for water treatment looks like.

• Public notices every time there is an 'unusual' event, possible discharge of pollution or biomass.

• WRWC to provide public information on what is captured by the new automatic effluent screen.

Full Cost-Benefit Analysis • Is there a benefits study on the reuse and recycling of this

resource? x 2 • A full CBA should be prepared that takes account of the full set

of costs and benefits and distributional consequences for all stakeholders, not just the council. This would be consistent with state and national CBA/business case guidelines and consistent with international best practice and experience for improved sustainability outcomes for local communities. Should also include risks. x 9 (WRWC: We did a cost-benefit analysis on treating effluent to a higher standard for use on public open spaces in 2011 and found no viable alternatives. One of the challenges is the high cost to treat the sewage to a high quality


and turn it inland, and as there is reasonably ample low-cost groundwater, there wasn't a demand for it. We'll continue to look at that and explore that possibility. There was an economic assessment undertaken of this project for the investment in sewage treatment to enable growth. It allows the growth of Warrnambool and its businesses and has quite a significant multiplier effect and is a strong economic project for the region.)

Improve confidence in WRWC operations • 100% Compliance with the State Environmental Protection

policies • Consider a lower approved load for a horizon much shorter than

20 years. This will enable further controls to be provided. x 6

Other • People are proposing things that cost a lot of money - why don't

we consider investing a small % of that money on other areas of the catchment to improve the marine environment - stormwater nets, catchment works - fencing rivers. x 2

• Separate the two: industries in one, localisation domestic in another. x 2 (WRWC: This was considered in the options analysis in selecting the preferred treatment upgrade option.)

• Have you factored in the use of solar, wind, and hydro to offset carbon footprints? (WRWC: WRWC has committed to reducing greenhouse gas emissions to net-zero by 2050. We are also taking action to reduce our carbon footprint, e.g. installation of a wind turbine in Portland (offsetting the electricity consumption of the city's water and sewerage treatment facilities) and large solar panel arrays on a wide range of our facilities. We have considered the carbon footprint of the Warrnambool STP

throughout the design process. Table 2 of the Works Approval document shows that the proposed upgrade has one of the smallest impacts in this area. We considered anaerobic treatment which could potentially provide an alternative energy source for the STP. However, the high cost and incoming sewage stream ruled this option out.)


4. Chair’s reflections and recommendations EPA and the applicant have critical roles to play in acknowledging community concerns and transparently and thoroughly explaining how future environmental and health impacts will be negated.

The following solution-focussed recommendations are made in response to community comments, concerns, and opportunities that were expressed at the 20B Conference and via the online forum. Adoption of the recommendations and suggestions will assist in alleviating community concerns and improving community engagement and relations with regulators and the applicant.

4.1 An STP that meets future demand and community expectations It is noted that, as pointed out by a post on the online forum, the Moyne Shire Economic Development Strategy Action Plan 2019-202411 identifies the upgrade of the Warrnambool wastewater treatment plant as a high priority to support the continued growth of the dairy processing capability of the region.

Correspondingly, as residential areas and industry grow in the Warrnambool area, it is clear that the existing STP needs to be upgraded to accommodate the inevitable increased generation of wastewater.

However, WRWC’s past performance and the perceived leniency of its EPA Licence has angered many community members. These factors have made them sceptical about the applicant’s ability to

11 http://www.moyne.vic.gov.au/Our-Services/Economic-Development/Economic-Development-Strategy pg 12

protect the coast, its ecology and its users, particularly given the proposal involves similar technology but increased throughput in the future.

The proximity of the mixing zone to Shelly Beach and popular diving areas is a cause of concern. Many attendees and submitters were worried about current and potential impacts on both human and marine biodiversity health. It is a reasonable community expectation that the coastline is safe12 for (appropriate) recreational use and marine life, particularly given its proximity to the Merri Marine Sanctuary and the Belfast Coastal Reserve.

The proposed STP upgrade is an opportunity to address community concerns by introducing technology that meets public expectations and SEPP requirements. The recent Section 22 Notice for Further Information, as briefly described in Section 1.2 of this report, aims to seek clarity on how the proposal will protect human health and marine biodiversity, and prevent future dirty decants and discharge of microplastics.

To further address these concerns as expressed through the 20B Conference process, I recommend that EPA Victoria:

1. Reviews the STP’s Licenced discharge limits in line with SEPP objectives and community expectations, particularly for phosphorus, nitrogen, solids (including microplastics and microfibres smaller than 1mm), E.coli and enterococci.

2. Reviews, through EPA’s Public Health Unit, the requested Human Health Risk Assessment and any additional health

12 Safe from a health perspective (as opposed to the dangerous swells and currents that are common in the area)

http://www.moyne.vic.gov.au/Our-Services/Economic-Development/Economic-Development-Strategy

http://www.moyne.vic.gov.au/Our-Services/Economic-Development/Economic-Development-Strategy


risks associated with the Application that have not been included in the HHRA.

3. Requires, if feasibly possible, the discharge point to be extended offshore, with an improved diffusion capability and a correspondingly smaller, offshore mixing zone.

4. Requires WRWC to regularly monitor and publicly report on the environmental impacts of discharge beyond the mixing zone.

5. Ensures that the proposed upgrade works will be sufficient to treat the projected load.

6. Requires WRWC to place public notices at coastal access points whenever there is an ‘unusual’ event, where discharge exceeds limits of the Licence.

The common belief that trade waste customers should be more responsible for the treatment of their wastewater will be addressed in the implementation of Recommendation 1. A more rigorous discharge requirement for WRWC is most likely to lead to tighter controls by WRWC regarding the influent it accepts. The view that trade waste customers should share more of the cost burden of any upgrade is a matter that WRWC may consider as part of its future pricing strategy.

Recommendation 1 should also address the concern that WRWC’s effluent screening enables discharge of microfibres or microplastics smaller than 1mm.

13 WRWC (June 2020) Tertiary treatment and Class A recycled water Info sheet

The concern expressed in the Conference regarding the current 300-metre radius of the mixing zone should be alleviated by Recommendation 3 above.

Recommendation 4 will enable community members to keep track of cumulative impacts on the marine environment and raise concerns if needed.

Recommendation 5 is made in response to some attendees’ concern that the proposal would not meet future waste projections.

4.2 Moving towards the reuse of ‘waste’ water A sentiment amongst many who oppose the upgrade is that the proposal is not best practice and that WRWC should be focussed on delivering Class A recycled water for wide reuse. To this end, WRWC is seen by many participants as not having sufficiently investigated alternative paths for the upgrade, and there was a common call for tertiary treatment of the wastewater to enable it to be recycled. As it was pointed out, this is consistent with the Victorian Government’s 2016 Water for Victoria – Water Plan and 2020 Recycling Victoria – A New Economy policies.

It is recognised that the STP already recycles 60 ML of water for onsite use and that a local market additional recycled water does not currently exist.13 However, there was a strong call by community attendees for WRWC to view the water derived from its processes as a resource. In response, WRWC committed to ‘exploring these options in the future’, noting cost implications.


I therefore recommend that EPA Victoria:

7. Requires the Warrnambool STP to undertake tertiary treatment and production of Class A water within five years.

8. (Following the achievement of Recommendation 7) encourages WRWC to find value-added uses for treated water.

Five years should be sufficient to build the cost into the 2023 price submission, seek the necessary approvals and explore market opportunities for the recycled water, or use it (as some suggested) to support nearby wetlands or other environmental reserves.

It is acknowledged that WRWC must also consider earlier community feedback that prices for domestic customers should not increase. It is hoped that the weight of feedback received during the Works Approval application process (including the Conference), and tighter regulatory controls through an improved Licence will assist future submissions to government for funding assistance.

4.3 Building social licence Feedback from some participants indicates a level of distrust of the applicant and the transparency of its communications, especially regarding the proposal.

Social licence refers to the ongoing acceptance of a company or industry's standard business practices and operating procedures by its employees, stakeholders and the general public14.

14 https://www.investopedia.com/terms/s/social-licence-slo.asp 15 ibid 16 Ibid 17 WRWC (June 2020) Tertiary treatment and Class A recycled water Info sheet

Social licence is created and maintained slowly over time as the actions of a company build trust with its local community and other stakeholders. A company must be seen to be operating responsibly, taking care of its employees and the environment, and being a good “corporate citizen”. When problems do occur, the company must act quickly to resolve the issues or the social licence to operate is compromised.15

In practice, the initial basis for social legitimacy comes from authentic engagement with all members of the community and providing information on the project, the company and what may happen in the future and then answering all questions16. My experience with WRWC over the 20B Conference process indicates a genuine desire to engage with community members authentically. The Information Sheet17 produced in response to community submissions is an example of this desire, as was a genuine effort by WRWC staff and consultants to answer as many community questions as possible during the Conference. WRWC’s Community Engagement Framework18 and its Regional Advisory Forum are evidence of a good strategic approach to building community relationships.

However, to build social licence, companies must first do the right thing and then be seen doing the right thing19. This means evaluating and re-evaluating operational and management systems

18 https://www.wannonwater.com.au/stronger-communities/community-engagement.aspx#community-engagement-framework 19 https://www.investopedia.com/terms/s/social-licence-slo.asp

https://www.investopedia.com/terms/s/social-license-slo.asp

https://www.wannonwater.com.au/stronger-communities/community-engagement.aspx#community-engagement-framework

https://www.wannonwater.com.au/stronger-communities/community-engagement.aspx#community-engagement-framework

https://www.investopedia.com/terms/s/social-license-slo.asp


to ensure that they are meeting contemporary standards and expectations.

The concern of some community members that the Warrnambool STP is not operating within modern and acceptable discharge parameters undermines WRWC’s intent to build community confidence. This concern is exacerbated by a view that WRWC’s objectives (and public statements) are about keeping within the (in the view of some) inadequate EPA Licence parameters, rather than safeguarding the coastal environment from the impacts described by Conference participants.

In addition, WRWC’s claim that some of the plastics found on local beaches came from sources other than the STP is further evidence to some that WRWC avoids taking responsibility for its operational failings.

Many of the above recommendations will assist the building of WRWC’s social licence. I also recommend that EPA Victoria:

9. Requires the applicant to develop further plain English fact sheets about the proposal, including answering relevant outstanding questions as detailed in Section 2.6 of this report. Efforts should be made to ensure the documents are not written from a public relations perspective but are developed with the purpose of building community understanding.

10. Requires the applicant to engage directly and genuinely with members of the community to discuss operational

20 Involve, as defined by the International Association of Public Participation’s Spectrum of Public Participation https://www.iap2.org.au/resources/iap2-published-resources/

challenges, better understand concerns and resolve issues. This could involve an expansion of the Advisory Forum model to involve20 a broader community cohort.

11. Considers a further information session or question and answer process after the Requests for Information have been received from the applicant and accepted by EPA. This session should feature appropriate technical experts to answer community questions clearly and succinctly. MS Live Events is NOT recommended for this session.

4.4 Improving confidence in WRWC’s reports The lack of social licence, at least among some Conference participants, was also reflected in a deep distrust of the reports presented and modelling used to date. Hence, there was a call for peer review of reports produced by or commissioned by WRWC. With this in mind, I recommend that EPA Victoria:

12. Engages a suitably qualified expert to peer review the suitability and effectiveness of the proposed effluent screening strategy.

13. Verifies, through independent expert assessment, the nature and extent of the potential impact of the outfall on marine biodiversity and the likely ability of the applicant to keep this impact within SEPP (Water) limits.

https://www.iap2.org.au/resources/iap2-published-resources/

https://www.iap2.org.au/resources/iap2-published-resources/


14. Engages a suitably qualified expert to peer review both the modelling methodology and modelling data once the new mixing zone has been established via Recommendation 5.

4.5 Regaining confidence in the EPA Some participants and submitters view the EPA as being lenient with its licencing and enforcement, and there is concern this would continue if the proposal is approved. It is hoped that the above recommendations, especially #1 and 3, will help to regain community confidence in this regard.

I also recommend that EPA Victoria:

15. Ensures that any future breaches of licence conditions are enforced and publicised.

16. Actively and publicly explains the EPA’s role and history in managing WRWC compliance.

Finally, my overarching recommendations are that EPA Victoria:

17. Gives due consideration to the recommendations and suggestions contained in this report.

18. Responds (in its Works Approval Assessment Report) to each of the above recommendations.

19. Provides a plain English response to each of the above recommendations directly to submitters, online forum contributors and Conference participants.

It is highlighted that I neither agree nor disagree with statements made by community members or the applicant at the Conference or the online forum. Comments are included or summarised in this report without endorsement or judgement of them or their veracity.

I take this opportunity to thank participants of the Conference for the respectful and patient manner in which they conducted themselves, despite their concerns and the very challenging technology issues.

Jennifer Lilburn Director, Kismet Forward B.Ed Environmental Studies (Deakin University), B.App.Sci Environmental Assessment & Land Use Policy (Deakin University), Adv.Dip Group Facilitation (Groupwork Institute of Australia), Cert. Public Participation (International Association of Public Participation), Cert. Conflict Management Coach

Appendix: Conference Agenda

produced for · 2020. 8. 30. · this via a fact sheet posted on the engage vic website. there is a...

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