Mod 3 - Operational Changes

I am absolutely opposed to the variation of the conditions applied to Sydney Water regarding discharges to the river.

The plant was built and commissioned only a few years ago and the ongoing costs relating to the operation of the plant should have been accurately assessed prior to commencement of the project.

If Sydney Water failed to obtain an accurate assessment the responsibility should lie with the company.

I am fully in support of the fishing and oyster farming industries objection to this proposal.

My name is Jan Stubbs and I am a long standing member of the Brooklyn community, please accept this email as an expression of my objection to Sydney Water's proposal to increase nutrient discharge limits from the Brooklyn Wastewater Treatment Plant (BWTP) into the Hawkesbury River.



The proposal to increase nutrient discharge concentrations from BWTP, acknowledges that the plant has failed to perform to design specifications. This design failure should be resolved with an engineering solution to improve effluent quality rather than by degrading the estuary by increasing nutrient discharge concentrations.



The proposal is inconsistent with NSW State Government natural resource management objectives which seek to improve estuarine health through nutrient reduction programs. Nutrients in the estuary increase the risk of harmful algal blooms becoming more prevalent which in turn threatens public health, local fisheries, oyster farming and recreational activities. This risk to estuarine health, commercial and recreational pursuits is unacceptable.



Government agencies and community groups are working cooperatively to remove nutrients from the estuary. In particular, the proposal is inconsistent with the Office of Environment and Heritage (2010) "Lower Hawkesbury Nepean Nutrient Management Strategy" which has the objective to "reduce nutrient loads from existing sources" (p1). The proposal has not been evaluated in accordance with requirements of the Healthy Rivers Commission (1998) which concludes "For future protection of river health, the commission recommends that all license renewal processes should incorporate assessment of the cumulative impacts of discharges within the relevant sub-catchment. Those assessments should be in terms of the implications of the subject activities for river health outcomes" (p71).



It is my position that current license conditions be kept for BWTP. Sydney Water should improve plant performance by installing additional or alternate treatment measures to improve the discharge quality that doesn't require increasing nutrients into the estuary or cost to residents.

My name is Lian Kathner and I am the daughter of a long standing member of the Brooklyn community, please accept this email as an expression of my objection to Sydney Water's proposal to increase nutrient discharge limits from the Brooklyn Wastewater Treatment Plant (BWTP) into the Hawkesbury River.



The proposal to increase nutrient discharge concentrations from BWTP, acknowledges that the plant has failed to perform to design specifications. This design failure should be resolved with an engineering solution to improve effluent quality rather than by degrading the estuary by increasing nutrient discharge concentrations.



The proposal is inconsistent with NSW State Government natural resource management objectives which seek to improve estuarine health through nutrient reduction programs. Nutrients in the estuary increase the risk of harmful algal blooms becoming more prevalent which in turn threatens public health, local fisheries, oyster farming and recreational activities. This risk to estuarine health, commercial and recreational pursuits is unacceptable.



Government agencies and community groups are working cooperatively to remove nutrients from the estuary. In particular, the proposal is inconsistent with the Office of Environment and Heritage (2010) "Lower Hawkesbury Nepean Nutrient Management Strategy" which has the objective to "reduce nutrient loads from existing sources" (p1). The proposal has not been evaluated in accordance with requirements of the Healthy Rivers Commission (1998) which concludes "For future protection of river health, the commission recommends that all license renewal processes should incorporate assessment of the cumulative impacts of discharges within the relevant sub-catchment. Those assessments should be in terms of the implications of the subject activities for river health outcomes" (p71).



It is my position that current license conditions be kept for BWTP. Sydney Water should improve plant performance by installing additional or alternate treatment measures to improve the discharge quality that doesn't require increasing nutrients into the estuary or cost to residents.

As a Dangar Island resident and Sydney Water customer my objection to the proposed change is based on several concerns outlined below. Reading available scientific papers and further investigation into the effects of the proposal may consolidate my understanding. In any case, Sydney Water must be held accountable to the community who were assured that the best available tertiary treatment and effluent discharge system would be installed in the Hawkesbury River.

Initial objections include:
*Sydney Water achieved community acceptance for the Treatment Plant on the premise that best available practice would be employed in the interest of the Hawkesbury's environmental protection. Proposed changes reduce standards and flaunt the community's trust in that agreement.

*Cost considerations should not take precedence over water quality concerns. In addition to thousands in installation costs, residents are currently charged $120 plus per billing period to pay for the sewerage system - more than a 100% increase in charges, or Approximately $500 per year. The costs incurred, despite previously effective and free septic systems, were accepted because we were assured effluent quality resulting from advanced technology would be in the best interests of the river's health.

* Residents were subjected to considerable coercion to ensure they hooked up to the new system - threats of future costs in the thousands were used to gain residents' initial acceptance. Now, similar coercion is being used to gain approval for lowering quality standards.

I object to the proposed modification to increase the discharge criteria from the Brooklyn Wasterwater Treatment Plant. One of the main reasons for sewering Brooklyn and surrounding areas in the first place was to improve the health of the Hawkesbury River. We were told it was the state of the art technology and filtration, we would be a model village for this type of sewerage system. A strict criteria was put in place for the discharge and now because of financial restraints the guidelines need to be changed. I don't think so. This river needs to stay healthy. It is a life blood to so many. The Hawkesbury-Nepean catchment is of great significance and needs to be preserved. Keep the original discharge criteria intact.

On Tuesday 8/11/11 a friend of ours reported seeing a pod of dolphins swimming in Broken Bay off McKell Point, Brooklyn. This has to show how healthy the Hawkesbury River is becoming after lots of work from various groups and Sydney Water. However, Sydney Water now wants to increase the discharge criteria by tenfold! [Statement redacted] The promises of Sydney Water in regards to the sewerage treatment for the Brooklyn and Mooney Mooney area now seem very hollow as part of the infrastructure has lasted less than five year!

If we are to continue the recovery of the Hawkesbury River, shouldn't Sydney Water comply with the original agenda.

Lots of house holders at Brooklyn, Dangar Island and Mooney Mooney had no choice but to go onto sewer and it has been a financial strain for some.

[Statement redacted]

I would love to see more dolphins, wouldn't you?

Leo Houlcroft

I am unable to find the Environmental Impact Audit Report for this operation which was due last August and until such time that the operation of this STP can be examine fully I cannot support any increase in discharge into the Hawkesbury River.

If this STP cannot meet its designed requirements as specified in the original approval the it should be replaced under its manufacturer's warranty - in part or whole.

Sorry I lack the facilities to create a pdf.

14 November, 2011

Department of Planning
Major Projects
Sydney 2000


Re: Brooklyn and Dangar Island Sewerage Scheme - Modification to Condition 63


I object to the request by Sydney Water to Modify Condition 63 of the prior approval of the Brooklyn Dangar Sewerage Scheme.
The request should not be considered until Sydney Water (SW) 1. fully considers alternatives to increasing nutrient levels in the effluent being discharged into the Hawkesbury River from the Brooklyn Sewage Treatment Plant (BSTP), 2. models the effects of increased nutrient loads likely to result from increased connections to the BSTP and from any discharge of effluent from the package treatment plants proposed by Gosford Shire Council for communities at Bar Point, Cogra Bay, Wobby, and Patonga, and 3. commences detailed studies of the likely effects of increased nutrient loads on phytoplankton and seagrass in the river. Models of nutrient impacts should also consider the residency time in the estuary of nutrients, heavy metals, estrogens, and other biologically active compounds discharged from the BSTP (e.g., bioaccumulation, accumulation in sediments), as well as any impact on marine life. Moreover, SW has not provided the community with details explaining the poor performance and high cost of the plant, while repeatedly assuring the community since the plant's commissioning that it was operating to specifications. The community needs this information to make an informed decision.
1. Alternatives to increased nutrient levels: SW has ignored suggestions from the community of alternatives to increasing the load of nutrients discharged from the BSTP. These included alternative and modified technologies for the operation of the BSTP, as outlined in submissions from the Dangar Island League and reducing the amount of phosphorous (P) entering the plant. The community is already moving to ban soap powders and detergents with high P levels (e.g., Aldi stores) and a ban on such products in Hornsby and Gosford Shires would be neither onerous nor difficult to implement, while considerably reducing total P loads entering the river from the BSTP and other treatment plants on the lower Hawkesbury River. Before approving the changes to Condition 63, SW should be required to show why reducing inputs is not a practical and cost-effective alternative to increasing discharge levels.
2. Impact models: The documentation provided to the public by SW regarding impacts of increased discharge loads only concludes there are unlikely to be adverse effects (e.g., pp. 22, 38 in SW's submission). There are several deficiencies in the approach taken by SW as to the impact of increased nutrient loads being discharged from the BSTP. Firstly, SW's models fail to consider cumulative impacts of increasing connections to the BSTP, the increase in Sydney's population, with greater total discharges into Hawkesbury-Nepean system, and the nutrients to be discharged from any `package treatment plants' to service the communities of Bar Point, Cogra Bay, Wobby, and Patonga. Statements from SW in their submission that nutrient loads appear to have decreased since SW commenced monitoring of river water quality ~ 20 years ago (e.g., Figure 7 in their submission) have not been substantiated. SW presents no statistical analysis of its data and visual inspection of at least the graphs of Nitrogen (N) and P strongly suggests there are no significant long-term declines. Figure 7 (ammonia) visually suggests a long-term decline, but whether this is independent of periods of high and low rainfall is unlikely and at the least requires statistical analysis. Consideration also needs to be given as to how the data presented by SW were collected, as no detailed methodology is presented in its submission. If SW is relying on water samples taken by locals (e.g., Streamwatch), than the data I have seen has significant gaps over time and samples do not appear (personal observation) to have been collected in a standardized and appropriately rigourous manner.
A major failure of SW from when it first proposed the Brooklyn-Dangar Island Sewerage Scheme was it refusal to measure or model residency time of nutrients discharged into the Hawkesbury estuary. Instead SW has relied exclusively on dilution models (often without proper consideration of more complex river flow patterns, such as the effects of tidal flows in Mooney Mooney Creek) and not taken into account any bioaccumulation of nutrients nor the fact that tidal currents may cause nutrients to remain within the estuary for greater or shorter periods of time depending on tide and weather conditions.
Of equal significance is the failure of SW to measure and model impacts of other chemicals, such as estrogens, which can occur in domestic sewage at high concentrations and are known globally to have significant adverse impacts on aquatic organisms. Domestic sewage can also contain high concentrations of heavy metals, such as cadmium, and, increasingly, nanno particles. SW appears to have data on any of these materials and their likely effects on the river. Although SW is not requesting permission to increase the loads of these compounds discharged from the BSTP, it should be required to consider the totality of its impacts on estuarine health, not consider each compound, nutrient, or chemical separately. Ecosystems simply do not work that way.
3. Impacts on phytoplankton and seagrass: Two of the most important components of any estuarine ecosystem are phytoplankton and seagrass. Both are likely to be highly responsive to changed nutrient loads within the estuary. However, SW has consistently ignored advice that it should include phytoplankton and seagrass as core components of its monitoring of effects from the discharge of effluent from the BSTP. Instead it has chosen to monitor hard bottom fouling organisms on the pylons near the discharge point, but these organisms are primarily detrital feeders and unlikely to respond to changes in nutrient loads, although higher plankton concentrations will increase growth rates. In its last response explaining why there is no need to monitor seagrass in the Hawkesbury estuary, SW said there were no seagrasses near the discharge point. This ignores the extensive seagrass beds around Dangar Island, in Mullet Creek, and at Wobby Point, not to mention smaller beds near Brooklyn and at the mouth of Sandbrook Inlet (very close to the discharge point) and the fact that the community has already invested considerable resources in protecting these seagrasses. It also shows a lack of understanding as to how nutrients, at very low concentrations perhaps, move around an estuary and can have significant effects on phytoplankton and seagrasses.
According to the marine biologists I consulted at Edith Cowan University, `There is no standard or clear understanding about how much nutrient, loads or concentration will negatively affect seagrasses, it is very much dependent on the location.' However, increased nutrient loads are implicated in the decline of seagrasses globally. One impact of increased nutrient levels in an estuary is increased productivity of phytoplankton and organisms growing on seagrasses. Both can diminish the light reaching the seagrass leading to decline and death of seagrass. Seagrasses in the lower Hawkesbury are presently continuing to recover from the high silt loads carried down stream from in-bed sand mining and poor construction practices within the catchment from the 1940s into the 1980s that diminished the light penetrating to the seagrasses. It is important that nothing be permitted to happen that will reverse this by increasing turbidity (e.g., higher plankton concentrations) or increased fouling of the seagrasses by epiphytic organisms.





According to the biologist consulted at Edith Cowan University, `The important question to ask is will the increased nutrients stimulate phytoplankton or algal epiphytes that will then reduce light and adversely affect seagrasses. If it is predicted that phytoplankton will be stimulated, what will the resultant light attenuation be? We do have a better understanding about the light requirements for seagrasses. I am guessing it is Zostera in the Hawkesbury, Zostera muelleri=capricorni has a high light requirement ~ 35% (minimum light requirement (MLR) in Photosynthetic Photon Flux Density (PPFD - light with wavelength (** of about 350-700 nm) ) and a high compensating irradiance of 80-92 muE m-2 s-1( PHOTOSYNTHETIC CHARACTERISTICS OF SEAGRASSES (CYMODOCEA-SERRULATA, THALASSIA-HEMPRICHII AND ZOSTERA-CAPRICORNI) IN A LOW-LIGHT ENVIRONMENT, WITH A COMPARISON OF LEAF-MARKING AND LACUNAL GAS MEASUREMENTS OF PRODUCTIVITY Author(s): POLLARD, PC (POLLARD, PC); GREENWAY, M (GREENWAY, M) Source: AUSTRALIAN JOURNAL OF MARINE AND FRESHWATER RESEARCH Volume: 44 Issue: 1 Pages: 127-139 Published: 1993). As this is a meadow [seagrasses near Dangar Island] that has been impacted before, any significant light reductions are very likely to affect rates of recovery. If any modelling has been done on nutrient dispersal and phytoplankton responses, then it should be possible to factor light attenuation into it too.'
Unfortunately, SW has ignored all advice regarding monitoring plankton and seagrass in the lower Hawkesbury estuary. Hornsby Shire Council has only initiated monitoring of plankton loads (chlorophyll levels) in the last year or so. As a result there are inadequate background data to determine whether even the present outputs from the BSTP are having an effect on these core components of the estuary, much less failing to consider other existing and proposed sources of nutrients entering the estuary. Proposing increases in nutrient loads in the absence of such data amounts to `environmental vandalism'.
SW's proposal, if approved, has the potential of reversing nearly 20 years of effort on the part of government and community to improve water quality in the Hawkesbury-Nepean system. While SW seemed focussed on relatively modest cost savings, the real costs to the estuary and people of New South Wales from the environmental impacts of increased nutrient levels from the BSTP have the potential to be much higher, with losses of amenities, recreation value, biodiversity, and fisheries all following from any increases in plankton loads and any decline in seagrass.

Emeritus Professor Harry F. Recher
Edith Cowan University
c/ POB 154, Brooklyn, NSW 2083

Dear Sir,

Attached please find a submission on the Brooklyn Dangar Sewerage System

CEN has seperately written to the Minsiter seeking a halt in consideration of this proposal until Sydney Water releases further information on the Operation of the existing STP.

Yours, John Asquith

14 November 2011


Mr Kane Winwood
Department of Planning & Infrastructure
23-33 Bridge Street, Sydney

Brooklyn Wastewater Treatment Plant

Dear Mr Winwood,

I understand that Sydney Water lodged a modification application with the Department of Planning and Infrastructure on 15 September 2011 to change the effluent quality limits for ammonia, total phosphorous and total Nitrogen identified in condition of approval no. 63 of the Brooklyn and Dangar Island Sewerage Scheme.

This will have a direct impact on the quality of effluent discharged directly into the Hawkesbury River.

I am writing to raise a number of questions which remain unanswered and state my opposition to the proposal in its current form. The following issues need to be addressed before it can be considered.

1. Impact of future development - The current report fails to take into consideration the impact of future discharges. Modelling provided is based on pre 2009 assumptions which do not include potential future development. Any reasonable model would account for the impact of future growth.

2. Assumptions and verification of modelling - There is a serious lack of detail provided by Sydney Water in the modelling. The information appears very basic and the detail is far from clear. I would like Sydney Water to confirm effluent compliance at the 150m dilution zone under the current development as of 2011. There is no confirmation in the report that the STP is currently meeting targets using current discharge data. In addition, Sydney Water should demonstrate a scenario effluent compliance at the 150m dilution zone that represents the potential development under the proposed scheme (option 3). I cannot understand how Sydney Water think we should make a decision without providing such information.

3. Comparative Data - Sydney Water have not provided any comparative data regarding STP discharge from other sewerage schemes. If the dilution levels at say North Richmond STP or Hornsby Heights STP are lower than Brooklyn then what is the justification for the higher levels proposed? In addition, there is no data available for comparison of the river pre and post the Brooklyn STP (ie taking into account the removal of Septics etc). Can Sydney Water demonstrate that the Brooklyn Estuary has improved in water quality since the commissioning of the STP?

4. Future Monitoring - There is no mention of how Sydney Water plans to ensure that water quality will not be compromised following this amendment. The community needs to know that appropriate systems and processes will be in place to ensure that the quality of the River is not deteriorating as a result of their proposal. What is Sydney Water's plan for ongoing monitoring and assessment?

The Hawkesbury River is one of Sydney's most beautiful and picturesque waterways. It is home to a diverse range of aquatic flora and fauna, commercial fishing and oyster industries, and a favourite recreational spot for people right across our state. This River is too important to compromise, especially considering the incomplete information which has been provided.

Section 3 of the report says that the reason for modification is that the "higher than anticipated quantities of ferric chloride required to remove phosphorous have fouled the membranes". Section 3.1.3 of the report states that the ferric chloride has caused the "ultra filtration membranes at Brooklyn WWTP required replacement after just three years instead of the expected 10 years."

This raises the serious question of whether or not the STP has met its specifications including membrane replacement, chemical consumption and energy use.

The NSW taxpayer and the residents of my community should not be penalised for failure to construct the plant in line with the original specification. This is an engineering problem requiring an engineering solution.

I would encourage the Department of Planning and Infrastructure to reject this proposal and provide an engineering solution which will not result in a lesser quality of effluent being discharged into the Hawkesbury.

Thank you for your consideration of this matter.

Yours Sincerely,




Matthew Kean MP
Member for Hornsby

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