Thrumster Wastewater Scheme

I have been visiting this area for 10 years and have been delighted, as an avid birdwatcher, to see a huge range of wetland birds, including Magpie geese, Swift parrot, e Emu Wren and Marsh Harriers.
I cannot help but think that this project will inevitably adversely affect these populations both during the construction phase and for the lifetime of the works.
It is widely accepted that wetlands should not be compromised.
I also have grandchildren being raised in this area who may be impacted during,particularly, the construction phase of this project due to potentially harmful, asbestos materials to be brought in from a quarry.
Also my concern includes sewage overflow in a peat based swamp. I have witnessed the flooding of this swamp in the years I have been visiting and feel this could cause serious health risks for both people and the natural species.

I write to formally raise significant concerns regarding the Thrumster Wastewater Treatment Plant (WWTP) project. Specifically, I wish to address the omission of critical documents, misleading presentation of information, and serious procedural failures involving both the Council and its consultant, GHD. These actions reflect a broader pattern of conduct that undermines transparency, integrity, and accountability throughout the project’s planning and assessment phases.

1. Omission of Key Documents and Misrepresentation of Facts
Crucial documents evaluating the viability of the Thrumster WWTP site were deliberately omitted from the Environmental Impact Statement (EIS), its appendices, and subsequent reports. These documents contained findings that demonstrated the selected site’s clear inferiority—environmentally, socially, culturally, and economically—when compared to alternatives such as Lake Road and Koala Street.
Despite this, the Council and GHD excluded the following key reports from public and departmental scrutiny:
Thrumster Wastewater Scheme – Strategic Wastewater Management Plan (Beca HunterH2O, 2023d)
Discharge Options Assessment (Beca HunterH2O, February 2024)
Connection Investigation Response – ECN-022950_MNC000088 – Thrumster Sewer Scheme V3 (April 2025)
Feedback from the Birpai Traditional Owners Corporation on cultural and heritage values

These documents concluded that the selected site is suboptimal due to:
Flood-prone location and associated environmental risks
Cultural heritage disturbance (including artefacts identified during test excavations)
Long-term ecological degradation
Negative social impacts and public health concerns
Higher capital (CAPEX) and operational (OPEX) costs

Conversely, a progressive upgrade of the existing infrastructure—an option previously supported by the EPA—would:
Improve receiving water quality
Reduce odour and air pollution
Limit cultural and ecological impacts
Require less land disturbance and offsetting
Eliminate major diversions and lower project costs

The intentional exclusion of these findings from the EIS, Response to Submissions (RTS), and Amendment Report (AR) is both misleading and deceptive, undermining the integrity of the planning process and depriving decision-makers of the full evidence base.

2. Misleading Public Communication and Withheld Cost Information
As of 10 May 2025, the Council’s official website continues to present incomplete and misleading information. The public exhibition period was not properly promoted, denying affected residents an opportunity to engage.
Moreover, substantial cost escalations relating to the construction and delivery of the Thrumster WWTP were not publicly disclosed. This intentional withholding of updated financial information reflects a pattern of opacity designed to avoid scrutiny and reinforces the project's unaffordability relative to superior alternatives.

3. Exclusion of Birpai RAP from Archaeological Excavations
On 20 November 2024, a registered representative of the Birpai Traditional Owners—who had formally expressed interest in participating in archaeological test excavations—was unjustly excluded from accessing the site, despite its location on Birpai country.
Only Bunyah Aboriginal Land Council representatives participated in the excavations, even though the site lies outside Bunyah territory. GHD’s subcontractor cited lack of immediate insurance as justification, even though the same Birpai RAP had previously participated in surveys under similar arrangements.
The RAP had raised substantial concerns about:
Excavation methodology
Disregard for identified cultural values
Heritage impacts of proposed works

Despite these objections, no reference to the incident or its implications was made in the EIS, RTS, or AR. This exclusion appears retaliatory and reflects a broader lack of impartiality and cultural sensitivity in the management of heritage processes.

Key questions that remain unanswered:
Why was the Birpai RAP excluded, despite formal registration and prior involvement?
Why were their concerns about excavation methodology ignored?
Why were excavation areas reduced and the process expedited?
Why was the discovery of artefacts dismissed as an anomaly?
Why were further values and complaints omitted from official documentation?

4. Withholding of Critical Power Supply Information
On 4 April 2025, the Council received an updated connection investigation from Essential Energy which revealed that the originally proposed underground conduit route was unfeasible. This required significant changes, including overhead power lines and a revised route—alterations that impact both the project’s footprint and environmental assessment.
This information was deliberately withheld from the AR and RTS and appears to have been reserved for later modification requests—contravening the principles of transparent and accurate environmental assessment.

Conclusion and Formal Requests
The consistent omission of critical documents, misrepresentation of impacts, exclusion of key Indigenous stakeholders, and suppression of cost and infrastructure information represent serious breaches of public trust and statutory obligations. These actions fundamentally compromise the legitimacy of the project’s assessment process.
I respectfully request the following actions:
Immediate independent review of the EIS, RTS, and Amendment Report for accuracy, completeness, and integrity.
Suspension of all planning and approval decisions pending a full investigation and reassessment of omitted reports and comparative analyses.
Transparent re-engagement with affected stakeholders, including the Birpai Traditional Owners, Thrumster network residents, and the wider community - including those that would benefit from an upgraded Koala Street treatment facility.
Public release of all previously withheld documents, including updated cost estimates, site assessments, and utility infrastructure changes.
Referral of the current EIS submission to DPHI and other relevant authorities for comprehensive reassessment, ensuring full transparency and accountability before any project decisions proceed.

The public and affected communities deserve a planning process that is honest, inclusive, and evidence-based. I urge you to take immediate action to rectify these issues and uphold the integrity of environmental and cultural assessment protocols.

As a Birrpai Man whos ancestors have be connected to the Wauchope/Port Macquarie/Gloucester/Taree/Kempsey communities for 5 generations minus my mother and myself , as which i have returned and lived on country a year ago and look to return to Birrpai Country very shortly i reject this proposal on the grounds of:
A LACK OF PROPER SITE INSPECTION IN REGARDS TO CULTURAL EVIDENCE

NOT A GUARANTEE ON UPHOLDING CULTURAL HERITAGE AND LIAISING WITH LALC AND COMMUNITY MEMBERS

SUSPECTED HIDING OF REPORTS AND FINDINGS ON THE PROPOSED SITE AREA

I suggest if the NSW government takes the First Nations people of this country seriously these steps need to be taken to ensure that the NSW shows that they truly respect us BIRRPAI/BIRPI/BIRIPI people.

Contact me if you would like my thoughts my contact details are in my account

I have shown you respect by writing this respect me by replying back with comments made towards the key points i identitfied and contact the Birpi/Bunya/Purfleet/Kempsey/Dunghutti Elders LALC with the same information i request

Marrumbu

Birrpai/Wiradyuri Man Cale James Burge

I write to formally raise significant concerns regarding the Thrumster Wastewater Treatment Plant (WWTP) project. Specifically, I wish to address the omission of critical documents, misleading presentation of information, and serious procedural failures involving both the Council and its consultant, GHD. These actions reflect a broader pattern of conduct that undermines transparency, integrity, and accountability throughout the project’s planning and assessment phases.

1. Omission of Key Documents and Misrepresentation of Facts
Crucial documents evaluating the viability of the Thrumster WWTP site were deliberately omitted from the Environmental Impact Statement (EIS), its appendices, and subsequent reports. These documents contained findings that demonstrated the selected site’s clear inferiority—environmentally, socially, culturally, and economically—when compared to alternatives such as Lake Road and Koala Street.
Despite this, the Council and GHD excluded the following key reports from public and departmental scrutiny:
Thrumster Wastewater Scheme – Strategic Wastewater Management Plan (Beca HunterH2O, 2023d)
Discharge Options Assessment (Beca HunterH2O, February 2024)
Connection Investigation Response – ECN-022950_MNC000088 – Thrumster Sewer Scheme V3 (April 2025)
Feedback from the Birpai Traditional Owners Corporation on cultural and heritage values

These documents concluded that the selected site is suboptimal due to:
Flood-prone location and associated environmental risks
Cultural heritage disturbance (including artefacts identified during test excavations)
Long-term ecological degradation
Negative social impacts and public health concerns
Higher capital (CAPEX) and operational (OPEX) costs

Conversely, a progressive upgrade of the existing infrastructure—an option previously supported by the EPA—would:
Improve receiving water quality
Reduce odour and air pollution
Limit cultural and ecological impacts
Require less land disturbance and offsetting
Eliminate major diversions and lower project costs

The intentional exclusion of these findings from the EIS, Response to Submissions (RTS), and Amendment Report (AR) is both misleading and deceptive, undermining the integrity of the planning process and depriving decision-makers of the full evidence base.

2. Misleading Public Communication and Withheld Cost Information
As of 10 May 2025, the Council’s official website continues to present incomplete and misleading information. The public exhibition period was not properly promoted, denying affected residents an opportunity to engage.
Moreover, substantial cost escalations relating to the construction and delivery of the Thrumster WWTP were not publicly disclosed. This intentional withholding of updated financial information reflects a pattern of opacity designed to avoid scrutiny and reinforces the project's unaffordability relative to superior alternatives.

3. Exclusion of Birpai RAP from Archaeological Excavations
On 20 November 2024, a registered representative of the Birpai Traditional Owners—who had formally expressed interest in participating in archaeological test excavations—was unjustly excluded from accessing the site, despite its location on Birpai country.
Only Bunyah Aboriginal Land Council representatives participated in the excavations, even though the site lies outside Bunyah territory. GHD’s subcontractor cited lack of immediate insurance as justification, even though the same Birpai RAP had previously participated in surveys under similar arrangements.
The RAP had raised substantial concerns about:
Excavation methodology
Disregard for identified cultural values
Heritage impacts of proposed works

Despite these objections, no reference to the incident or its implications was made in the EIS, RTS, or AR. This exclusion appears retaliatory and reflects a broader lack of impartiality and cultural sensitivity in the management of heritage processes.

Key questions that remain unanswered:
Why was the Birpai RAP excluded, despite formal registration and prior involvement?
Why were their concerns about excavation methodology ignored?
Why were excavation areas reduced and the process expedited?
Why was the discovery of artefacts dismissed as an anomaly?
Why were further values and complaints omitted from official documentation?

4. Withholding of Critical Power Supply Information
On 4 April 2025, the Council received an updated connection investigation from Essential Energy which revealed that the originally proposed underground conduit route was unfeasible. This required significant changes, including overhead power lines and a revised route—alterations that impact both the project’s footprint and environmental assessment.
This information was deliberately withheld from the AR and RTS and appears to have been reserved for later modification requests—contravening the principles of transparent and accurate environmental assessment.

Conclusion and Formal Requests
The consistent omission of critical documents, misrepresentation of impacts, exclusion of key Indigenous stakeholders, and suppression of cost and infrastructure information represent serious breaches of public trust and statutory obligations. These actions fundamentally compromise the legitimacy of the project’s assessment process.
I respectfully request the following actions:
Immediate independent review of the EIS, RTS, and Amendment Report for accuracy, completeness, and integrity.
Suspension of all planning and approval decisions pending a full investigation and reassessment of omitted reports and comparative analyses.
Transparent re-engagement with affected stakeholders, including the Birpai Traditional Owners, Thrumster network residents, and the wider community - including those that would benefit from an upgraded Koala Street treatment facility.
Public release of all previously withheld documents, including updated cost estimates, site assessments, and utility infrastructure changes.
Referral of the current EIS submission to DPHI and other relevant authorities for comprehensive reassessment, ensuring full transparency and accountability before any project decisions proceed.

The public and affected communities deserve a planning process that is honest, inclusive, and evidence-based. I urge you to take immediate action to rectify these issues and uphold the integrity of environmental and cultural assessment protocols.

Please see attached Submission

The Thrumster Wastewater Scheme is a major development proposed on Birpai land — and Birpai LALC was not properly consulted in the cultural heritage inspections. The current reports only recorded 38 artefacts with very poor visibility (10–20%), which means much more could be buried and undiscovered.
Please stop this project until:
✅ Proper site inspections are done
✅ Cultural heritage is fully protected
✅ Missing reports are made public

This project is being constructed in a wildlife corridor where various birds of national significance reside. Not all of these have been addressed in the proposal.
The site is generally unsuitable for a waste treatment plant, it requires significant costs to raise the height and significant investment will be required to pump the waste into the town facilities to then release into the river. Could the money be better spent by looking at options for significantly upgrading the existing facility?

I have lived in the same house for the past 45 years,and I walk Fernbank Creek Rd every day because of health reasons and have to fight with the traffic as it is,without putting more construction traffic on the road. As a rate payer of Fernbank Creek, I will eventually have to pay for this Sewage system,along with the rest of town,and we at Fernbank Creek will get no benefit from it what so ever,but will have to put up with the smell and the Destruction of our water ways.We already have the problem of Acid Sulphate in Partridge Creek and Fernbank Creek through mismanagement and we certainly dont want to escalate the problem.We also need to think of the effect it will have on our bird life and the bird watchers and photographers who use the area regularly.There is also the problem of all this land being flood prone,as is evident after the floods of 2021.The disturbance of this low land is what causes the Acid sulphate and there is no getting around this problem.Another concern is air born particles from the treatment plant getting in our Drinking water,as we are all on Tank water,(NO TOWN WATER),There just has to be a better alternative that does not have such an impact on our environment.

Objection to the Thrumster Wastewater Scheme
Submitted by: Sandra Hindman, Birpai LALC Member
Date: 14 May 2025
To Whom It May Concern,
RE: Objection to the Thrumster Wastewater Scheme
We, the Members of the Birpai Local Aboriginal Land Council, wish to raise strong objections to the proposed Thrumster Wastewater Scheme.
This project is located on Birpai Country, and we are deeply concerned that the Aboriginal Cultural Heritage has not been properly investigated or protected. The current reports only mention 38 artefacts, and visibility during the site inspection was very low — between 10% and 20%. This tells us that many more cultural items may still be present and have not been found.
Birpai LALC was not properly included in the inspection or consultation process, even though we are the recognised Traditional Custodians of this land. This is not acceptable and goes against the respect and care that should be shown when planning developments on Aboriginal land.
We also have concerns about the destruction of native bushland, threats to endangered animals, and health risks to nearby families. Important documents have been left out of the public reports, and local residents and Traditional Owners have not been given a fair chance to be heard.
For these reasons, we ask that:
• The project is paused immediately;
• A proper Aboriginal Cultural Heritage inspection is done with Birpai LALC present;
• All missing reports are released to the public;
• A new location for the wastewater facility is considered.
We ask that the Department of Planning, Housing and Infrastructure listen to our voices and take the right steps to protect Birpai Country and culture.
Yours sincerely,
Sandra Hindman
Birpai Local Aboriginal Land Council Member

Thank you for taking the time to listen to my concerns.

I am writing to express my serious objections to the proposed Thrumster Wastewater Project, which is planned for construction near my residence at 461 Fernbank Creek Road. Unfortunately, my earlier objections were not adequately addressed by the consultants. I wish to elaborate further below.

Impact on My Land, My Family, and Our Wellbeing

I am deeply concerned about the disruption this project will cause during both the construction and the operation and maintenance phases. As the nearest resident—whose home lies directly in the path of all site-bound traffic—I have been advised by subject matter experts that the impact will be so severe that I may need to seek alternative accommodation for my family of five. To date, there has been no mention of restitution or support from the Council for this disruption.

Even after commissioning, routine maintenance activities will bring frequent traffic to the site, comparable to levels expected during the construction phase. How are we expected to maintain our quality of life under these circumstances?

The ongoing presence of drive-in/drive-out construction and operations personnel raises serious concerns about local security. Given the current housing shortage in Port Macquarie, there is a heightened risk of illegal camping and trespassing on neighbouring properties. Why did the Social Impact Assessment fail to highlight these risks or propose mitigation measures? How can residents be expected to feel safe in this environment?

Environmental and Health Risks

The estimated duration for the project—from initial fill material transfer to commissioning—is approximately five years. During this time, we will endure relentless noise, dust, vibration, and heavy vehicle traffic from fill transfer, construction equipment, concrete mixers, hazardous material deliveries, and more.

This presents significant health and safety risks, particularly to my young family. Risks include:

Increased traffic incidents on a rural road.

Airborne particulates contaminating our rooftop water supply.

Noise and vibration with both physical and psychological effects.

These issues have been grossly underestimated and inadequately addressed. The dismissive nature of the responses to my previous objections has caused significant stress and anxiety for my family and other nearby residents.

Flooding, Fire, and Natural Hazards

In my time here, I have witnessed grass fires, peat fires, bogged fire engines, and flooding. Climate change is expected to make these events more frequent and severe. Yet, Council proposes to establish an elevated pad in the middle of a floodplain—affecting flood velocity and elevation, and worsening erosion and sedimentation. These impacts were shown in flood modelling but left unmitigated. No compensation, land buyback, or offset measures have been proposed.

Additionally, the absence of a standalone stormwater management report (as would be expected in similar projects across NSW) is a glaring omission. Impacts from hard surfaces and steep embankments—such as increased erosion and sedimentation—have not been adequately studied or mitigated.

Similarly, the Bushfire Hazard Assessment failed to consider the increased risk of grass and peat fires due to human activity, and the inability of existing fire trails to provide adequate access to sand plains and bushland. The consequences of these fires, which can burn underground for weeks or months, were ignored.

Ecological Impact

It is disheartening that an area of such high ecological and aesthetic value is being considered for a project of this magnitude. The environmental impact on endangered species—such as the giant dragonfly, flying possum, wallum froglet, nesting magpie geese, jabiru, marsh harriers, and emu wrens—is severe and irreversible.

The proposed "offsets" are wholly inadequate, involving only a small remnant of the floodplain. This land holds significant cultural, ecological, and social value. As outlined by the Hastings Birdwatchers, this site is of national importance for birdwatching, attracting visitors from across Australia.

These major ecological risks have been downplayed by both the consultant and the Council in a way that is misleading, inappropriate, and unprofessional.

Broader Community Impact

Council’s strategic planning appears to prioritise rapid urban development at the expense of infrastructure and community wellbeing. Roads and cycleways have been neglected, traffic congestion is worsening, and health and recreational facilities are under strain.

The decision to build a sewage treatment facility in an environmentally sensitive, flood- and fire-prone area is baffling. The project requires unnecessary directional drilling beneath creeks and roads to divert sewer westward, only to return effluent eastward to Kooloonbung Creek—placing undue pressure on the city’s social, environmental, and heritage assets.

This inefficiency and lack of foresight are alarming.

The selected location at Fernbank Creek is particularly unsuitable. When the peat last caught fire in 2019, it burned for six months, despite regular helicopter water-bombing. The Council’s own poly pipe infrastructure was destroyed in that blaze—a stark reminder of the risks involved in investing heavily in this area.

The risk of damage to underground pipelines from future peat fires—and subsequent uncontained discharge of sewage into the surrounding environment—has been ignored in the Environmental Impact Statement. This demonstrates a shocking lack of rigour and consultation.

Cultural and Heritage Concerns

The presence of Indigenous artefacts on site raises significant heritage concerns. It is troubling that the survey appears to have been halted—possibly to avoid further discoveries that might threaten the project. To my knowledge, the Birpai Aboriginal Land Council was not involved in the excavation process, while RAPs from unrelated councils conducted test digs. This is a grave oversight and a serious error of judgement by both the consultant and the Council.

Infrastructure Mismanagement

The Oxley Highway and hospital access road are already overloaded. There are no planned upgrades within the next 5–10 years. Adding more dwellings without appropriate infrastructure planning is irresponsible.

This "housing first, infrastructure later" approach results in rushed decisions and untenable outcomes. It raises concerns about potential undisclosed secondary interests driving such poor planning decisions.

A Better Alternative

I understand there is a feasible alternative: upgrading the existing Port Macquarie Wastewater Treatment Plant. Surprisingly, this would be less costly than rerouting sewerage and returning effluent in opposing directions. This solution would also better address current environmental and community impacts.

Although I don’t live near Koala Street, I am aware of ongoing odour complaints from that area. It is troubling that gradual upgrades to this existing site have been overlooked in favour of a much riskier, more damaging development at Fernbank Creek.

Conclusion

I strongly urge the relevant authorities not to approve this development. The growing awareness of its environmental, social, cultural, and economic unsuitability presents an opportunity to pursue a better solution—one that respects the people, wildlife, and heritage of the Hastings region.

Regards,

Dr Michael Potter

RE Thrumster Sewerage Plant Proposal .
My objection to this proposal is the location the proposal is planned .
Location is really only useful to the new area of Sovereign Hills . Given the limited good land to increase further home building this area would have reached 40-50 % of land already built on . Where the sewerage works is proposed is flood plain and swap . Problems of pipe line construction will only sky rocket once " ground is broken " and the service contractors uncover all the obvious site problems . The distances needed to connet into the " new customers " will also see a economic " blow out " on the cost of this facility .
I worked on Darling Harbour 1985 - 1988 and the extent of effort to pile every structure was extra ordinary. This site is worse !
Is it designed to pile every structure build in this facility ? I fear not . Have any idea on the cost involved or the ability to do this work ?
Sorry but I have no faith in council project managing this . Ocean Drive duplication comes to mind.
On to a more constructive comment .
Why is this proposed well away from the areas of real need ?
Expansion of the heavier density houses in the southern Lake Cathie, Rainbow Estate, Gem life and soon OCR expansion . Far more houses built and yet to be built in this area. A sewerage plant located somewhere between Bonny Hills and Lake Innes on the inland side of the coastal development would be of better value to the rate payers .
Has council considered what will happen when the current pumping from this area to the Koala St Plant goes wrong and the Lake Cathie ,Bonny hills area gets backed up or inoperable?

I suggest council should consult the community more on where they intend to spend the rate payers money .
This proposal does not seen sensible at the moment .
Sorry But I don't support this .

As a resident here we know the people of Fernbank Creek have had enough to contend with after the recent floods and don't need the added stress and consequences of all that this entails.I am no scientist,but totally agree with all the objections our knowledgable neighbours have put forth.I have lived on Fernbank creek Rd all my life,64 years, and absolutely love our neighbour hood and greatly respect our neighbours and their opinions.I have seen the escalation in traffic conditions and the lack of peacefulness that was,and am thankful that I no longer have children who need to walk the road to get to the bus stop as the traffic is too dangerous.I have also seen the decline in the state of the creeks.Living right on Partridge Creek we have seen the result of the Acid Sulphate issues and shudder to think how much worse it would be with Sewage Over flow added to the mix.We once could swim and fish in both Fernbank and Partridge creeks,but it is too conaminated now to do either and we would hate to see it get any worse.As my husband and I both have health problems,to worry about the issues of contaminates to our Tank Water ,and the bad odours are constantly on our minds.There just has to be a better way. Yours sincerely Rebecca Rumble (wife of Peter Rumble) 403 Fernbank Creek RD

I write to raise serious concerns regarding the Thrumster Wastewater Treatment Plant (WWTP) project, particularly around the omission of critical documents, exclusion of stakeholders, misleading communications, and procedural failings involving the Council and its consultant, GHD. I am dissatisfied with the response from council made on 9/5/25.
1. Absence of Key Documents and Deliberate Misleading Information
Crucial documents outlining infrastructure planning and site comparisons were excluded from the Environmental Impact Statement (EIS), Response to Submissions (RTS), and Amendment Report (AR), despite being available to Council and GHD. These documents clearly show the proposed site is significantly less suitable—financially, environmentally, culturally, and socially—than alternatives such as Lake Road and Koala Street.
The chosen location is flood-prone, ecologically sensitive, and of cultural significance, as confirmed by artefacts found during excavations. Meanwhile, upgrading existing infrastructure at Koala St, an option supported by the EPA, offers numerous advantages, including:
• Improved water quality and reduced odour,
• Lower cultural and ecological impact,
• Avoidance of major sewer diversions,
• Significantly lower capital and operational costs.
Key Documents Omitted:
• Thrumster Wastewater Scheme – Strategic Wastewater Management Plan (Beca HunterH2O, 2023)
• Discharge Options Assessment (Beca HunterH2O, Feb 2024)
• Connection Investigation Response - Thrumster Sewer Scheme V3 (April 2025)
• Feedback from Birpai Traditional Owners Corporation
2. Stakeholder Exclusion
Directly impacted Fernbank Creek residents were not included in consultation or decision making, while select groups such as the Hastings Birdwatchers participated in the Multi Criteria Analysis (MCA). Nearby residents were directly excluded and denied a fair opportunity to raise concerns.
3. Misleading Public Communications
As of 10 May 2025, the Council’s website continues to misrepresent the project. The exhibition period was not publicly promoted, keeping the community uninformed. Rising
project costs—due to escalating construction and network expenses—were also not disclosed, further masking the flaws of the selected site in addition to exclusions associated with the construction of access road, power upgrades associated with overhead power supply to the site, Water supply to the site, Council’s contingency, NPV for the project, ongoing O&M especially power cost estimate for unfeasible and unsustainable transfer of sewer to the fernbank Creek to transfer the treated effluent back to the Kooloonbung creek.
The location name is misleading in itself! The proposed site is in Fernbank Creek NOT Thrumster.
4. Exclusion of Birpai RAP from Archaeological Work
On 20 November 2024, a registered Birpai Traditional indigenous Owner was denied access to test excavations site by GHD’s subcontractor, despite earlier participation and the site being on Birpai country. The Bunyah Aboriginal Council (from outside the area) was included instead. The RAP’s concerns were ignored, and none of these issues—including artefact findings and formal complaints—were missing in the report by GHD and its consultant. Why was the RAP excluded? Why are his concerns and cultural values disregarded? Why were the findings of artefacts downplayed despite their potential significance?
5. Withheld Power Supply Changes
On 4 April 2025, Council received notice from Essential Energy that the original power supply route was unviable, requiring overhead cabling and footprint / impact changes. This major revision was omitted from official reports, seemingly to secure project approval without scrutiny—violating planning obligations.
6. Noise/vibration during construction
The limitations surrounding noise and nightworks have been unclear and possibly deceptive.
According to the construction work hours appendix, noise and vibration may be permitted on up to four nights within any seven-day period.


ref NV4: “No more than two consecutive nights of noise with special audible characteristics and/or vibration generating work may be undertaken in the same NCA over any 7-day period, unless otherwise approved by the relevant authority.”
7. Potential contamination of drinking water
All residents of Fernbank Creek Road rely on roof-collected rainwater as our primary source of drinking water. I understand there are plans to use fill from the cowarra water treatment and its associated network project which contains naturally occurring asbestos and other contaminations with forever materials (PFAS, etc.). This is especially concerning of long-term health impacts to my family (which includes 3 young children), and other nearby residents and workers.
8. Environmental concerns
The biodiversity report outlines the Swift Parrot, Koala, Trailing Woodruff, Leafless Tongue Orchid, Slender Marsdenia and Biconvex Paperbark impacted by the project as a “matter of national environmental significance”. This raises legitimate concerns about the suitability of the proposed location. To date, these environmental impacts have not been adequately addressed by the project.
At the proposed project site, my family and I witnessed the bush and peat fires that burned for 210 days during the 2019-2020 fire season, followed by a historic major flooding event in 2021. This raises two significant concerns:
1. The proposed area is environmentally vulnerable and prone to extreme events, which could place any new infrastructure at substantial risk.
2. The proposed elevated site has the potential to exacerbate flood risks, including spillage and overflow, in the event of a wet weather event. Current flood modelling does not include modelling based on allow for extra clogging and silting of the creeks due to discharge of the stormwater from the plants and road’s embankment and solid surfaces to the creeks .

Conclusion and Requests for Action
This pattern of withheld information, stakeholder exclusion, and misleading practices undermines public trust and legislative compliance.
I respectfully request:
1. An immediate review of the EIS, RTS, and Amendment Report for accuracy and completeness.
2. Suspension of all approvals pending a full, independent reassessment including all previously omitted reports.
3. Re-engagement with all affected stakeholders, including Birpai Traditional Owners and Fernbank Creek residents.
4. Public release of all withheld documents and revised cost estimates.
The project’s environmental, cultural, and financial impacts must be transparently reassessed before further progression.
Sincerely,
Dr Lisa An

I have heard through community that there has been Indigenous artefacts in this area and so needs be left alone for Land Council to culturally protect the area and utilise the area for 'On Country' activities....more consult with elders.
Also.....this is flood plain often..very often. Friends and family in this area get inundated with water. If treatment plant operates then will take away the tranquility of lifestyle , lots of traffic, smelly etc

As a regular visitor to Port Macquarie and an avid birdwatcher, I would like to formally object to the proposed Thrumster Wastewater Scheme (Thrumster WWS). My objection is based on serious and substantiated concerns regarding the project’s transparency, governance, planning integrity, environmental impact, and public health implications.

Throughout the planning and consultation phases, there have been consistent failures by Council and its consultant, GHD, to engage in an open and accountable process. These failures include the omission of critical documents, exclusion of relevant stakeholders, dissemination of misleading public information, and poor management of cultural heritage responsibilities.

1. Omission of Key Documents and Misleading Information
Several vital documents were not disclosed in the Environmental Impact Statement (EIS), appendices, Response to Submissions (RTS), or the Amendment Report. These include:

Strategic Wastewater Management Plan (Beca HunterH2O, 2023)
Discharge Options Assessment (Beca HunterH2O, February 2024)
Connection Investigation Response – Thrumster Sewer Scheme V3 (April 2025)
Formal feedback from the Birpai Traditional Owners Corporation

These reports clearly indicate that the selected site is less suitable than the existing wastewater infrastructure corridor at Lake Road and Koala Street. Withholding this information obstructed informed public engagement and appears to have been done deliberately to support a predetermined outcome.

The currently proposed location is on flood-prone land with known cultural and ecological sensitivity. It offers no apparent advantage over alternative sites, yet it carries significantly greater environmental, financial, and social risks. It is deeply troubling that these risks were not fully disclosed to the public or relevant authorities.

2. Public Health Risks: Airborne Particulates and Water Safety
One particularly alarming omission from Council’s documentation is any reference to airborne dust and particulate matter—despite the fact that many neighbouring properties rely on rooftop rainwater collection for drinking water.

The potential for construction dust and disturbed soil to carry harmful or carcinogenic particles presents a significant public health risk. Neither the Council nor GHD has adequately addressed this issue in project documents or public responses. The dismissive tone used in response to legitimate health concerns reflects an unacceptable lack of diligence and community care.

3. Deceptive Public Communication
As of 10 May 2025, Council's website—ostensibly the primary source of project information—continues to host incomplete and outdated material. The recent exhibition period was not publicly promoted, and new cost projections were not disclosed, despite internal evidence of significant budget overruns.

This pattern of withholding and manipulating information has compromised the planning process and further eroded public trust.

4. Exclusion of Birpai RAP from Cultural Heritage Work
On 20 November 2024, a representative of the Birpai Traditional Owners—who was registered to participate in archaeological test excavations—was denied access to the site. This occurred despite the area being within Birpai Country and despite the individual’s prior involvement.

In contrast, individuals from an Aboriginal council based outside the project area were permitted to participate. A formal complaint was lodged, followed by meetings with Council officers and the Mayor’s office in February and April 2025. Yet none of these events or concerns were included in the official documentation.

The failure to document cultural artefacts found on-site, and the exclusion of local Traditional Owners, constitutes a serious breach of proper heritage consultation practices.

5. Concealment of Power Supply Changes
On 4 April 2025, Council received a revised connection response from Essential Energy indicating that the original underground power supply route was unfeasible. This necessitated a significant shift to overhead cabling, altering the project footprint.

This critical information was not included in the RTS or Amendment Report. Intending to submit such changes as a post-approval modification is deceptive and contrary to planning obligations.

6. Environmental, Financial, and Operational Concerns
The currently proposed site presents several critical risks:
It is subject to flooding and waterlogging.
It lies within an ecologically sensitive area with documented endangered species.
It has known cultural heritage significance.
It has high construction and operational costs.
In contrast, the Lake Road and Koala Street site:
Is already partially developed and Council-owned.
Offers a lower-risk, lower-cost alternative.
Aligns with EPA recommendations.
Requires less ecological offsetting and minimal sewer network diversion.
Minimizes odour, visual, and noise impacts for surrounding residents.

Yet, for reasons that remain unexplained, this alternative was never presented transparently or seriously considered during the public consultation process.

7. Procurement and Governance Issues
Only two companies were invited to tender for the project—both of which subsequently merged. There are also reports of familial connections between Council staff and contractors involved in the project. These circumstances raise serious concerns regarding the integrity and fairness of the procurement process.

Moreover, Council has not demonstrated how it intends to finance the majority of the project, with current budgets reportedly covering only around 30% of the expected cost. This lack of transparency creates unacceptable financial uncertainty for ratepayers.

8. Material Safety Concerns: Asbestos in Construction Fill
The proposed use of large volumes of concrete and quarry rock in construction raises another urgent concern. Independent investigations have found that some quarries have supplied materials contaminated with asbestos. This presents a severe risk to public health, especially in a residential and environmentally sensitive area.

No environmental or health risk assessment appears to have been undertaken to evaluate this risk in the context of the Thrumster site.

Conclusion and Request for Immediate Action
Given the seriousness of the issues outlined above, I respectfully request that Council:

Immediately suspend the current Thrumster WWS project pending an independent review of the site selection process.

Disclose the full funding strategy and long-term financial implications of the project.

Reopen the tender process to allow broader competition and ensure transparency.

Investigate potential conflicts of interest and publish a probity report on the procurement process.

Conduct an urgent, independent environmental and health risk assessment, especially concerning airborne particulates and potential asbestos contamination.

Reassess the suitability of the Lake Road/Koala Street site as a viable alternative, based on objective and publicly available data.

The serious procedural, environmental, cultural, and ethical shortcomings of the Thrumster WWS planning process make it clear that this project cannot proceed in its current form or location. I urge Council to act responsibly, transparently, and in the public interest.

Sincerely,
Robert Rangel

I am writing as a concerned resident to formally object to the proposed Thrumster Wastewater Scheme (Thrumster WWS). My objection is based on serious and substantiated concerns regarding the project’s transparency, governance, planning integrity, environmental impact, and public health implications.

Throughout the planning and consultation phases, there have been consistent failures by Council and its consultant, GHD, to engage in an open and accountable process. These failures include the omission of critical documents, exclusion of relevant stakeholders, dissemination of misleading public information, and poor management of cultural heritage responsibilities.

1. Omission of Key Documents and Misleading Information
Several vital documents were not disclosed in the Environmental Impact Statement (EIS), appendices, Response to Submissions (RTS), or the Amendment Report. These include:
Strategic Wastewater Management Plan (Beca HunterH2O, 2023)
Discharge Options Assessment (Beca HunterH2O, February 2024)
Connection Investigation Response – Thrumster Sewer Scheme V3 (April 2025)
Formal feedback from the Birpai Traditional Owners Corporation

These reports clearly indicate that the selected site is less suitable than the existing wastewater infrastructure corridor at Lake Road and Koala Street. Withholding this information obstructed informed public engagement and appears to have been done deliberately to support a predetermined outcome.

The currently proposed location is on flood-prone land with known cultural and ecological sensitivity. It offers no apparent advantage over alternative sites, yet it carries significantly greater environmental, financial, and social risks. It is deeply troubling that these risks were not fully disclosed to the public or relevant authorities.

2. Public Health Risks: Airborne Particulates and Water Safety
One particularly alarming omission from Council’s documentation is any reference to airborne dust and particulate matter—despite the fact that neighbouring properties rely on rooftop rainwater collection for drinking water.

The potential for construction dust and disturbed soil to carry harmful or carcinogenic particles presents a significant public health risk. Neither the Council nor GHD has adequately addressed this issue in project documents or public responses. The dismissive tone used in response to legitimate health concerns reflects an unacceptable lack of diligence and community care.

3. Deceptive Public Communication
As of 10 May 2025, Council's website—ostensibly the primary source of project information—continues to host incomplete and outdated material. The recent exhibition period was not publicly promoted, and new cost projections were not disclosed, despite internal evidence of significant budget overruns.

This pattern of withholding and manipulating information has compromised the planning process and further eroded public trust.

4. Exclusion of Birpai RAP from Cultural Heritage Work
On 20 November 2024, a representative of the Birpai Traditional Owners—who was registered to participate in archaeological test excavations—was denied access to the site. This occurred despite the area being within Birpai Country and despite the individual’s prior involvement.

In contrast, individuals from an Aboriginal council based outside the project area were permitted to participate. A formal complaint was lodged, followed by meetings with Council officers and the Mayor’s office in February and April 2025. Yet none of these events or concerns were included in the official documentation.

The failure to document cultural artefacts found on-site, and the exclusion of local Traditional Owners, constitutes a serious breach of proper heritage consultation practices.

5. Concealment of Power Supply Changes
On 4 April 2025, Council received a revised connection response from Essential Energy indicating that the original underground power supply route was unfeasible. This necessitated a significant shift to overhead cabling, altering the project footprint.

This critical information was not included in the RTS or Amendment Report. Intending to submit such changes as a post-approval modification is deceptive and contrary to planning obligations.

6. Environmental, Financial, and Operational Concerns
The currently proposed site presents several critical risks:

It is subject to flooding and waterlogging.
It lies within an ecologically sensitive area with documented endangered species.
It has known cultural heritage significance.
It has high construction and operational costs.

In contrast, the Lake Road and Koala Street site upgrade option:
Is already partially developed and Council-owned.
Offers a lower-risk, lower-cost alternative.
Aligns with EPA recommendations.
Requires less ecological offsetting and minimal sewer network diversion.
Minimizes odour, visual, and noise impacts for surrounding residents.

Yet, for reasons that remain unexplained, this alternative was never presented transparently or seriously considered during the public consultation process.

7. Procurement and Governance Issues
Only two companies were invited to tender for the project—both of which subsequently merged. There are also reports of familial connections between Council staff and contractors involved in the project. These circumstances raise serious concerns regarding the integrity and fairness of the procurement process.

Moreover, Council has not demonstrated how it intends to finance the majority of the project, with current budgets reportedly covering only around 30% of the expected cost. This lack of transparency creates unacceptable financial uncertainty for ratepayers.

8. Material Safety Concerns: Asbestos in Construction Fill
The proposed use of large volumes of concrete and quarry rock in construction raises another urgent concern. Independent investigations have found that some quarries have supplied materials contaminated with asbestos. This presents a severe risk to public health, especially in a residential and environmentally sensitive area.

No environmental or health risk assessment appears to have been undertaken to evaluate this risk in the context of the Thrumster site.

Conclusion and Request for Immediate Action
Given the seriousness of the issues outlined above, I respectfully request that Council:

Immediately suspend the current Thrumster WWS project pending an independent review of the site selection process.
Disclose the full funding strategy and long-term financial implications of the project.
Reopen the tender process to allow broader competition and ensure transparency.
Investigate potential conflicts of interest and publish a probity report on the procurement process.
Conduct an urgent, independent environmental and health risk assessment, especially concerning airborne particulates and potential asbestos contamination.
Reassess the suitability of the Lake Road/Koala Street site as a viable alternative, based on objective and publicly available data.

The serious procedural, environmental, cultural, and ethical shortcomings of the Thrumster WWS planning process make it clear that this project cannot proceed in its current form or location. I urge Council to act responsibly, transparently, and in the public interest. The last thing ratepayers want to see is a repeat of the Glasshouse Arts Performing Arts Centre project, which resulted in outrageous costs to the ratepayers and ended with the dismissal of Council.

Sincerely,
Mike Hockley

I am writing to formally express my serious concerns regarding the Thrumster Wastewater Scheme (Thrumster WWS) project, its associated consultation processes, and the treatment of affected stakeholders.

Omission of Critical Documentation and Public Misrepresentation
A central issue with the Thrumster WWS project is the systematic and deliberate exclusion of crucial documentation from the Environmental Impact Statement (EIS), appendices, Response to Submissions (RTS), and Amendment Report (AR). Documents such as the Thrumster Wastewater Scheme – Strategic Wastewater Management Plan (Beca HunterH2O, 2023), Discharge Options Assessment (Beca HunterH2O, February 2024), and Connection Investigation Response – Thrumster Sewer Scheme V3 (April 2025), along with feedback from the Birpai Traditional Owners Corporation, were known to the Council and its consultant GHD, yet were deliberately withheld from public view and review by regulatory authorities.

These documents collectively demonstrate that the selected Thrumster WWS site is significantly inferior to alternatives like Koala Street and Lake Road, when assessed across financial, environmental, ecological, flood risk, water quality, social, and public health dimensions. Instead of pursuing a progressive and lower-impact upgrade of existing infrastructure—as supported by the Environmental Protection Authority (EPA)—the Council appears to be advancing a costlier and more disruptive option with little justification.

Furthermore, misleading information continues to be presented via the Council’s official website, which has failed to publicly promote exhibition periods or accurately disclose escalating project costs. This lack of transparency has misled the public and further obstructed genuine community engagement.

Exclusion of Key Stakeholders and Community Voices
Neighbouring residents, including those of Fernbank Creek, have been consistently excluded from consultation processes concerning both the wastewater treatment plant and the effluent discharge location. A notable example is the July 2023 meeting regarding effluent discharge to the creek, which directly impacts our community—yet we were not informed or invited to participate.

By contrast, other community groups such as Hastings Birdwatchers, Friends of Kooloonbung Creek, and the North Shore Progress Association were included in the Multi-Criteria Analysis (MCA). The intentional omission of directly affected residents undermines the integrity and fairness of the consultation process and contravenes the principles of equitable stakeholder engagement.

Disregard for Cultural Heritage and Consultation Protocols
On 20 November 2024, a registered representative of the Birpai Traditional Owners—approved to participate in archaeological test excavations—was denied access to the project site by GHD’s subcontractor. This exclusion occurred despite previous participation and insurance arrangements, and despite the fact that the site lies within Birpai country.

No representatives from the Birpai Aboriginal Land Council were involved in these investigations, whereas participants from the Bunyah Aboriginal Council—operating outside the project area—were permitted on site. Artefacts discovered during excavations, along with cultural and ecological findings, were not documented in the final reports, despite formal complaints and follow-up meetings with Council officials and the Mayor's office.

This not only breaches accepted standards for heritage consultation but also demonstrates a failure to respect the cultural custodianship of the Birpai people.

Environmental and Public Health Concerns
A critical omission in the Council’s documentation is the failure to address airborne particle pollution, particularly concerning residents who rely on rooftop rainwater harvesting for drinking. Airborne contaminants, including known carcinogens, present a serious public health risk that has not been considered or mitigated in project plans.

Responses from the Council and GHD to these concerns have been inadequate, factually incorrect, and dismissive. For example, in addressing odour issues, the Council proposed installing a covered inlet without an Odour Control Unit (OCU), noting this would reduce infrastructure lifespan. Such reasoning is unacceptable. The obvious and responsible solution would be to install an OCU—not compromise residents’ health and quality of life.

Council responses have been vague and non-committal, using language such as “additional mitigation if deemed required,” which lacks measurable criteria or enforceable accountability. Residents living near the existing Koala Street treatment plant can attest to the Council’s historical failure to address odour complaints—despite persistent community feedback. Driving past Koala Street at night remains a deeply unpleasant experience, with no meaningful intervention from the Council.

Impact on Property, Livelihood, and Wellbeing
Separately, the Council approached my wife and me regarding a proposed flood-free access road that would traverse our property. We responded in good faith, open to negotiations to find a fair and equitable outcome. The road, however, would have passed directly in front of the site approved for our future family home—rendering it uninhabitable in its original form.

In response, we initiated plans to relocate the house to another part of our block and re-submit a development application. Even with this compromise, our new access would still be shared, and Council has since exerted increasing pressure, culminating in a notice of potential compulsory acquisition or easement—without any guarantee of development approval for the relocated site.

This coercive approach has caused significant stress and anxiety for our family, particularly as we had previously received assurances from the Council that we would not be disadvantaged. Instead, we now face the risk of being left with a property that cannot reasonably be used for its intended purpose, despite our consistent cooperation.

Call for Oversight and Investigation
The cumulative effect of these actions—deliberate document omissions, misleading public communication, stakeholder exclusion, cultural disregard, and aggressive land acquisition tactics—paints a deeply troubling picture of governance and process management.

This situation warrants formal investigation by independent oversight bodies such as the Office of the Ombudsman and the Independent Commission Against Corruption (ICAC), particularly given the substantial public funds at stake and the pattern of mismanagement exhibited by the Council and its consultants.

Conclusion
The Thrumster WWS project, as currently designed and administered, fails the tests of transparency, accountability, and public interest. A more appropriate solution—upgrading the Koala Street and Lake Road facilities—has been sidelined in favour of a less suitable, more expensive, and more damaging alternative.

It is imperative that this matter receive serious and immediate scrutiny. Our community deserves a process that respects cultural heritage, protects public health, and upholds basic standards of fairness and integrity.

Yours sincerely,
Russell Dick

I am writing as a concerned resident to formally object to the proposed Thrumster Wastewater Scheme (Thrumster WWS). My objection is based on serious and substantiated concerns regarding the project’s transparency, governance, planning integrity, environmental impact, and public health implications.

Throughout the planning and consultation phases, there have been consistent failures by Council and its consultant, GHD, to engage in an open and accountable process. These failures include the omission of critical documents, exclusion of relevant stakeholders, dissemination of misleading public information, and poor management of cultural heritage responsibilities.

1. Omission of Key Documents and Misleading Information
Several vital documents were not disclosed in the Environmental Impact Statement (EIS), appendices, Response to Submissions (RTS), or the Amendment Report. These include:

Strategic Wastewater Management Plan (Beca HunterH2O, 2023)

Discharge Options Assessment (Beca HunterH2O, February 2024)

Connection Investigation Response – Thrumster Sewer Scheme V3 (April 2025)

Formal feedback from the Birpai Traditional Owners Corporation

These reports clearly indicate that the selected site is less suitable than the existing wastewater infrastructure corridor at Lake Road and Koala Street. Withholding this information obstructed informed public engagement and appears to have been done deliberately to support a predetermined outcome.

The currently proposed location is on flood-prone land with known cultural and ecological sensitivity. It offers no apparent advantage over alternative sites, yet it carries significantly greater environmental, financial, and social risks. It is deeply troubling that these risks were not fully disclosed to the public or relevant authorities.

2. Public Health Risks: Airborne Particulates and Water Safety
One particularly alarming omission from Council’s documentation is any reference to airborne dust and particulate matter—despite the fact that many neighbouring properties rely on rooftop rainwater collection for drinking water.

The potential for construction dust and disturbed soil to carry harmful or carcinogenic particles presents a significant public health risk. Neither the Council nor GHD has adequately addressed this issue in project documents or public responses. This is an unacceptable response to legitimate health concerns and reflects an unacceptable lack of diligence and community care.

3. Deceptive Public Communication
As of 10 May 2025, Council's website—ostensibly the primary source of project information—continues to host incomplete and outdated material. The recent exhibition period was not publicly promoted, and new cost projections were not disclosed, despite internal evidence of significant budget overruns.

This pattern of withholding and manipulating information has compromised the planning process and further eroded public trust.

4. Exclusion of Birpai RAP from Cultural Heritage Work
On 20 November 2024, a representative of the Birpai Traditional Owners—who was registered to participate in archaeological test excavations—was denied access to the site. This occurred despite the area being within Birpai Country and despite the individual’s prior involvement.

In contrast, individuals from an Aboriginal council based outside the project area were permitted to participate. A formal complaint was lodged, followed by meetings with Council officers and the Mayor’s office in February and April 2025. Yet none of these events or concerns were included in the official documentation.

The failure to document cultural artefacts found on-site, and the exclusion of local Traditional Owners, constitutes a serious breach of proper heritage consultation practices.

5. Concealment of Power Supply Changes
On 4 April 2025, Council received a revised connection response from Essential Energy indicating that the original underground power supply route was unfeasible. This necessitated a significant shift to overhead cabling, altering the project footprint.

This critical information was not included in the RTS or Amendment Report. Intending to submit such changes as a post-approval modification is deceptive and contrary to planning obligations.

6. Environmental, Financial, and Operational Concerns
The currently proposed site presents several critical risks:

It is subject to flooding and waterlogging.

It lies within an ecologically sensitive area with documented endangered species.

It has known cultural heritage significance.

It has high construction and operational costs.

In contrast, the Lake Road and Koala Street site:

Is already partially developed and Council-owned.

Offers a lower-risk, lower-cost alternative.

Aligns with EPA recommendations.

Requires less ecological offsetting and minimal sewer network diversion.

Minimizes odour, visual, and noise impacts for surrounding residents.

Yet, for reasons that remain unexplained, this alternative was never presented transparently or seriously considered during the public consultation process.

7. Procurement and Governance Issues
Only two companies were invited to tender for the project—both of which subsequently merged. There are also reports of familial connections between Council staff and contractors involved in the project. These circumstances raise serious concerns regarding the integrity and fairness of the procurement process.

Moreover, Council has not demonstrated how it intends to finance the majority of the project, with current budgets reportedly covering only around 30% of the expected cost. This lack of transparency creates unacceptable financial uncertainty for ratepayers.

8. Material Safety Concerns: Asbestos in Construction Fill
The proposed use of large volumes of concrete and quarry rock in construction raises another urgent concern. Independent investigations have found that some quarries have supplied materials contaminated with asbestos. This presents a severe risk to public health, especially in a residential and environmentally sensitive area.

No environmental or health risk assessment appears to have been undertaken to evaluate this risk in the context of the Thrumster site.

Conclusion and Request for Immediate Action
Given the seriousness of the issues outlined above, I respectfully request that Council:

Immediately suspend the current Thrumster WWS project pending an independent review of the site selection process.

Disclose the full funding strategy and long-term financial implications of the project.

Reopen the tender process to allow broader competition and ensure transparency.

Investigate potential conflicts of interest and publish a probity report on the procurement process.

Conduct an urgent, independent environmental and health risk assessment, especially concerning airborne particulates and potential asbestos contamination.

Reassess the suitability of the Lake Road/Koala Street site as a viable alternative, based on objective and publicly available data.

The serious procedural, environmental, cultural, and ethical shortcomings of the Thrumster WWS planning process make it clear that this project cannot proceed in its current form or location. I urge Council to act responsibly, transparently, and in the public interest.

Sincerely,
Alison Hockley

I am writing as a concerned member of the public to formally object to the proposed Thrumster Wastewater Scheme (Thrumster WWS). I am a frequent visitor to the Port Macquarie area, and have many friends and family that reside in the area. My objection is based on serious and substantiated concerns regarding the project’s transparency, governance, planning integrity, environmental impact, and public health implications.

Throughout the planning and consultation phases, there have been consistent failures by Council and its consultant, GHD, to engage in an open and accountable process. These failures include the omission of critical documents, exclusion of relevant stakeholders, dissemination of misleading public information, and poor management of cultural heritage responsibilities.

1. Omission of Key Documents and Misleading Information
Several vital documents were not disclosed in the Environmental Impact Statement (EIS), appendices, Response to Submissions (RTS), or the Amendment Report. These include:

Strategic Wastewater Management Plan (Beca HunterH2O, 2023)
Discharge Options Assessment (Beca HunterH2O, February 2024)
Connection Investigation Response – Thrumster Sewer Scheme V3 (April 2025)
Formal feedback from the Birpai Traditional Owners Corporation

These reports clearly indicate that the selected site is less suitable than the existing wastewater infrastructure corridor at Lake Road and Koala Street. Withholding this information obstructed informed public engagement and appears to have been done deliberately to support a predetermined outcome.

The currently proposed location is on flood-prone land with known cultural and ecological sensitivity. It offers no apparent advantage over alternative sites, yet it carries significantly greater environmental, financial, and social risks. It is deeply troubling that these risks were not fully disclosed to the public or relevant authorities.

2. Public Health Risks: Airborne Particulates and Water Safety
One particularly alarming omission from Council’s documentation is any reference to airborne dust and particulate matter—despite the fact that many neighbouring properties rely on rooftop rainwater collection for drinking water. The potential for construction dust and disturbed soil to carry harmful or carcinogenic particles presents a significant public health risk. Neither the Council nor GHD has adequately addressed this issue in project documents or public responses. These legitimate health concerns have not been addressed and this reflects an unacceptable lack of diligence and community care.

3. Deceptive Public Communication
As of 10 May 2025, Council's website—ostensibly the primary source of project information—continues to host incomplete and outdated material. The recent exhibition period was not publicly promoted, and new cost projections were not disclosed, despite internal evidence of significant budget overruns. This pattern of withholding and manipulating information has compromised the planning process and further eroded public trust.

4. Exclusion of Birpai RAP from Cultural Heritage Work
On 20 November 2024, a representative of the Birpai Traditional Owners—who was registered to participate in archaeological test excavations—was denied access to the site. This occurred despite the area being within Birpai Country and despite the individual’s prior involvement.

In contrast, individuals from an Aboriginal council based outside the project area were permitted to participate. A formal complaint was lodged, followed by meetings with Council officers and the Mayor’s office in February and April 2025. Yet none of these events or concerns were included in the official documentation.

The failure to document cultural artefacts found on-site, and the exclusion of local Traditional Owners, constitutes a serious breach of proper heritage consultation practices.

5. Concealment of Power Supply Changes
On 4 April 2025, Council received a revised connection response from Essential Energy indicating that the original underground power supply route was unfeasible. This necessitated a significant shift to overhead cabling, altering the project footprint.

This critical information was not included in the RTS or Amendment Report. Intending to submit such changes as a post-approval modification is deceptive and contrary to planning obligations.

6. Environmental, Financial, and Operational Concerns
The currently proposed site presents several critical risks:

It is subject to flooding and waterlogging.
It lies within an ecologically sensitive area with documented endangered species.
It has known cultural heritage significance.
It has high construction and operational costs.

In contrast, the Lake Road and Koala Street site:
Is already partially developed and Council-owned.
Offers a lower-risk, lower-cost alternative.
Aligns with EPA recommendations.
Requires less ecological offsetting and minimal sewer network diversion.
Minimizes odour, visual, and noise impacts for surrounding residents.

Yet, for reasons that remain unexplained, this alternative was never presented transparently or seriously considered during the public consultation process.

7. Procurement and Governance Issues
Only two companies were invited to tender for the project—both of which subsequently merged. There are also reports of familial connections between Council staff and contractors involved in the project. These circumstances raise serious concerns regarding the integrity and fairness of the procurement process.

Moreover, Council has not demonstrated how it intends to finance the majority of the project, with current budgets reportedly covering only around 30% of the expected cost. This lack of transparency creates unacceptable financial uncertainty for ratepayers.

8. Material Safety Concerns: Asbestos in Construction Fill
The proposed use of large volumes of concrete and quarry rock in construction raises another urgent concern. Independent investigations have found that some quarries have supplied materials contaminated with asbestos. This presents a severe risk to public health, especially in a residential and environmentally sensitive area.

No environmental or health risk assessment appears to have been undertaken to evaluate this risk in the context of the Thrumster site.

Conclusion and Request for Immediate Action
Given the seriousness of the issues outlined above, I respectfully request that Council:

Immediately suspend the current Thrumster WWS project pending an independent review of the site selection process.
Disclose the full funding strategy and long-term financial implications of the project.
Reopen the tender process to allow broader competition and ensure transparency.
Investigate potential conflicts of interest and publish a probity report on the procurement process.
Conduct an urgent, independent environmental and health risk assessment, especially concerning airborne particulates and potential asbestos contamination.
Reassess the suitability of the Lake Road/Koala Street site as a viable alternative, based on objective and publicly available data.

The serious procedural, environmental, cultural, and ethical shortcomings of the Thrumster WWS planning process make it clear that this project cannot proceed in its current form or location. I urge Council to act responsibly, transparently, and in the public interest.

Sincerely,
Cindy Fielding-Smith

Please disregard my first submission. I accidentally uploaded the wrong letter & saved it prematurely before I read it. Below is my personal submission. Please accept my apologies for the earlier error.

I am writing as a concerned resident to formally object to the proposed Thrumster Wastewater Scheme (Thrumster WWS). My objection is based on serious and substantiated concerns regarding the project’s transparency, governance, planning integrity, environmental impact, and public health implications.

Throughout the planning and consultation phases, there have been consistent failures by Council and its consultant, GHD, to engage in an open and accountable process. These failures include the omission of critical documents, exclusion of relevant stakeholders, dissemination of misleading public information, and poor management of cultural heritage responsibilities.

1. Omission of Key Documents and Misleading Information
Several vital documents were not disclosed in the Environmental Impact Statement (EIS), appendices, Response to Submissions (RTS), or the Amendment Report. These include:
Strategic Wastewater Management Plan (Beca HunterH2O, 2023)
Discharge Options Assessment (Beca HunterH2O, February 2024)
Connection Investigation Response – Thrumster Sewer Scheme V3 (April 2025)
Formal feedback from the Birpai Traditional Owners Corporation

These reports clearly indicate that the selected site is less suitable than the existing wastewater infrastructure corridor at Lake Road and Koala Street. Withholding this information obstructed informed public engagement and appears to have been done deliberately to support a predetermined outcome.

The currently proposed location is on flood-prone land with known cultural and ecological sensitivity. It offers no apparent advantage over alternative sites, yet it carries significantly greater environmental, financial, and social risks. It is deeply troubling that these risks were not fully disclosed to the public or relevant authorities.

2. Public Health Risks: Airborne Particulates and Water Safety
One particularly alarming omission from Council’s documentation is any reference to airborne dust and particulate matter—despite the fact that many neighboring properties rely on rooftop rainwater collection for drinking water. The potential for construction dust and disturbed soil to carry harmful or carcinogenic particles presents a significant public health risk. Neither the Council nor GHD has adequately addressed this issue in project documents or public responses. This reflects an unacceptable lack of diligence and community care.

3. Deceptive Public Communication
As of 10 May 2025, Council's website—ostensibly the primary source of project information—continues to host incomplete and outdated material. The recent exhibition period was not publicly promoted, and new cost projections were not disclosed, despite internal evidence of significant budget overruns. This pattern of withholding and manipulating information has compromised the planning process and further eroded public trust.

4. Exclusion of Birpai RAP from Cultural Heritage Work
On 20 November 2024, a representative of the Birpai Traditional Owners—who was registered to participate in archaeological test excavations—was denied access to the site. This occurred despite the area being within Birpai Country and despite the individual’s prior involvement.

In contrast, individuals from an Aboriginal council based outside the project area were permitted to participate. A formal complaint was lodged, followed by meetings with Council officers and the Mayor’s office in February and April 2025. Yet none of these events or concerns were included in the official documentation. The failure to document cultural artefacts found on-site, and the exclusion of local Traditional Owners, constitutes a serious breach of proper heritage consultation practices.

5. Concealment of Power Supply Changes
On 4 April 2025, Council received a revised connection response from Essential Energy indicating that the original underground power supply route was unfeasible. This necessitated a significant shift to overhead cabling, altering the project footprint.

This critical information was not included in the RTS or Amendment Report. Intending to submit such changes as a post-approval modification is deceptive and contrary to planning obligations.

6. Environmental, Financial, and Operational Concerns
The currently proposed site presents several critical risks:
It is subject to flooding and waterlogging.
It lies within an ecologically sensitive area with documented endangered species.
It has known cultural heritage significance.
It has high construction and operational costs.

In contrast, the Lake Road and Koala Street site:
Is already partially developed and Council-owned.
Offers a lower-risk, lower-cost alternative.
Aligns with EPA recommendations.
Requires less ecological offsetting and minimal sewer network diversion.
Minimizes odour, visual, and noise impacts for surrounding residents.

Yet, for reasons that remain unexplained, this alternative was never presented transparently or seriously considered during the public consultation process.

7. Procurement and Governance Issues
Only two companies were invited to tender for the project—both of which subsequently merged. There are also reports of familial connections between Council staff and contractors involved in the project. These circumstances raise serious concerns regarding the integrity and fairness of the procurement process.

Moreover, Council has not demonstrated how it intends to finance the majority of the project, with current budgets reportedly covering only around 30% of the expected cost. This lack of transparency creates unacceptable financial uncertainty for ratepayers.

8. Material Safety Concerns: Asbestos in Construction Fill
The proposed use of large volumes of concrete and quarry rock in construction raises another urgent concern. Independent investigations have found that some quarries have supplied materials contaminated with asbestos. This presents a severe risk to public health, especially in a residential and environmentally sensitive area. No environmental or health risk assessment appears to have been undertaken to evaluate this risk in the context of the Thrumster site.

Conclusion and Request for Immediate Action
Given the seriousness of the issues outlined above, I respectfully request that Council:
Immediately suspend the current Thrumster WWS project pending an independent review of the site selection process.
Disclose the full funding strategy and long-term financial implications of the project.
Reopen the tender process to allow broader competition and ensure transparency.
Investigate potential conflicts of interest and publish a probity report on the procurement process.
Conduct an urgent, independent environmental and health risk assessment, especially concerning airborne particulates and potential asbestos contamination.
Reassess the suitability of the Lake Road/Koala Street site as a viable alternative, based on objective and publicly available data.

The serious procedural, environmental, cultural, and ethical shortcomings of the Thrumster WWS planning process make it clear that this project cannot proceed in its current form or location. I urge Council to act responsibly, transparently, and in the public interest.

Sincerely,
Russell Dick