Thrumster Wastewater Scheme

I am a rate payer and 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.

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

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 .

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.

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.

I am writing in response to Council’s recent submission concerning the proposed wastewater treatment plant and associated infrastructure. As a long-term resident of Fernbank Creek Road, I must express my strong objection to this proposal. The project, as currently presented, appears to be poorly conceived, inadequately investigated, and poses a significant and unacceptable risk to both residents and the surrounding environment.
This paper serves as my clear objection to A Wastewater Treatment plant in the Fernbank Creek vicinity!

I am writing to formally object to the proposed Thrumster Wastewater Treatment Plant (WWTP) project. All residents and ratepayers of Port Macquarie will be directly affected by this development and I have serious concerns about the planning, transparency, environmental impacts, financial impacts, and procedural integrity associated with the project.

Omission of Critical Information
It has come to my attention that several important documents—containing findings that challenge the suitability of the Thrumster site—were omitted from the Environmental Impact Statement (EIS), Response to Submissions (RTS), and Amendment Report (AR). These include the Strategic Wastewater Management Plan, the Discharge Options Assessment, and the Connection Investigation Response from Essential Energy (April 2025), among others.
The excluded information suggests that the selected site is less viable than alternatives like Lake Road or Koala Street, particularly in terms of financial, environmental, cultural, and public health outcomes. The failure to include these assessments undermines the credibility of the entire planning process and appears to reflect a biased agenda rather than evidence-based decision-making.
Limited and Misleading Public Communication
The Council’s public website remains incomplete and misleading. As of 10 May 2025, it still does not provide updated information on major developments such as cost escalations or infrastructure changes. Personally as a resident, until this was brought to my attention I was totally unaware of this project, let alone its financial, ecological, indigenous, or questionable transparency issues. This failure to communicate openly deprives the public of their right to fully understand and respond to the impacts of the proposal.

Cultural Heritage Concerns
I am also deeply disturbed by the treatment of the Birpai Registered Aboriginal Party (RAP) in relation to archaeological investigations. The reported exclusion of the Birpai RAP from test excavations—despite their prior involvement and formal interest—raises serious ethical and legal concerns. The fact that their objections and complaints were never documented in the EIS further demonstrates a lack of integrity and cultural respect.

Withholding of Power Supply Information
I understand that a revised power supply assessment from Essential Energy (dated 4 April 2025) revealed major changes to the electricity route for the WWTP, requiring overhead lines and a new alignment. Yet this was not disclosed in the AR or RTS. The Council’s apparent plan to introduce this as a modification at a later stage is deeply concerning and inconsistent with the principles of open, lawful environmental planning.

Financial and Ethical Issues
I am troubled by the lack of transparency surrounding the project’s funding. From what I have read, only about 30% of the required funding has been identified. No clear explanation has been given about where the remaining funds will come from, raising concerns about financial mismanagement and potential burden on ratepayers like myself.
The fact that only two companies were invited to tender—followed by their merger—and the existence of family connections between Council employees and project contractors also raises legitimate questions about the fairness and integrity of the procurement process.

Environmental and Health Risks
I am especially concerned about the health and environmental risks associated with fill materials that reportedly contain asbestos. This poses a serious risk to nearby residents, wildlife, and ecosystems. This risk appears to have been overlooked or ignored in the planning documents.

My Request
Based on these concerns, I respectfully request that the Council:
Immediately suspend further progress on the Thrumster WWTP project until a full and transparent review is undertaken.
Reassess the project site, giving proper consideration to viable alternatives, including upgrades to existing infrastructure at Lake Road and Koala Street.
Disclose a clear financial plan for the entire cost of the project and its funding sources.
Address all outstanding cultural heritage matters with the appropriate involvement of Birpai Traditional Owners.
Conduct an independent environmental and health risk review, particularly relating to the use of potentially hazardous materials.
Rectify consultation failures by engaging directly with residents of Fernbank Creek, whose lives will be most affected by the development.

This project, in its current form, is flawed in both process and substance. It risks long-term environmental, cultural, financial, and social damage. I urge the Council to reconsider the direction of this development and take immediate action to ensure that future decisions reflect integrity, evidence, and respect for all stakeholders.

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.

I live in Sydney but I am a ratepayer of 2 properties in Thumster, Port Macquarie. Until recently I was totally unaware of this proposal, and it's impacts. I write to formally object to 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.

Letter of objection attached

I write to formally object to 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.

I write to formally object to 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.

I write to formally object and 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.

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.

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 Fernbank Creek community.
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.

Subject: Personal Objection to the Thrumster Wastewater Treatment Plant Project

I am writing to formally object to the proposed Thrumster Wastewater Treatment Plant (WWTP) project. All residents and ratepayers of Port Macquarie will be directly affected by this development and I have serious concerns about the planning, transparency, environmental impacts, financial impacts, and procedural integrity associated with the project.

Omission of Critical Information
It has come to my attention that several important documents—containing findings that challenge the suitability of the Thrumster site—were omitted from the Environmental Impact Statement (EIS), Response to Submissions (RTS), and Amendment Report (AR). These include the Strategic Wastewater Management Plan, the Discharge Options Assessment, and the Connection Investigation Response from Essential Energy (April 2025), among others.
The excluded information suggests that the selected site is less viable than alternatives like Lake Road or Koala Street, particularly in terms of financial, environmental, cultural, and public health outcomes. The failure to include these assessments undermines the credibility of the entire planning process and appears to reflect a biased agenda rather than evidence-based decision-making.

Limited and Misleading Public Communication
The Council’s public website remains incomplete and misleading. As of 10 May 2025, it still does not provide updated information on major developments such as cost escalations or infrastructure changes. Personally as a resident, until this was brought to my attention I was totally unaware of this project, let alone its financial, ecological, indigenous, or questionable transparency issues. This failure to communicate openly deprives the public of their right to fully understand and respond to the impacts of the proposal.

Cultural Heritage Concerns
I am also deeply disturbed by the treatment of the Birpai Registered Aboriginal Party (RAP) in relation to archaeological investigations. The reported exclusion of the Birpai RAP from test excavations—despite their prior involvement and formal interest—raises serious ethical and legal concerns. The fact that their objections and complaints were never documented in the EIS further demonstrates a lack of integrity and cultural respect.

Withholding of Power Supply Information
I understand that a revised power supply assessment from Essential Energy (dated 4 April 2025) revealed major changes to the electricity route for the WWTP, requiring overhead lines and a new alignment. Yet this was not disclosed in the AR or RTS. The Council’s apparent plan to introduce this as a modification at a later stage is deeply concerning and inconsistent with the principles of open, lawful environmental planning.

Financial and Ethical Issues
I am troubled by the lack of transparency surrounding the project’s funding. No clear explanation has been given about updated costings or where the funds will come from, raising concerns about financial mismanagement and potential burden on ratepayers.
The fact that only two companies were invited to tender—followed by their merger—and the existence of family connections between Council employees and project contractors also raises legitimate questions about the fairness and integrity of the procurement process.

Environmental and Health Risks
I am especially concerned about the health and environmental risks associated with fill materials that reportedly contain asbestos. This poses a serious risk to residents, wildlife, and ecosystems. This risk appears to have been overlooked or ignored in the planning documents.

My Request
Based on these concerns, I respectfully request that the Council:
Immediately suspend further progress on the Thrumster WWTP project until a full and transparent review is undertaken.
Reassess the project site, giving proper consideration to viable alternatives, including upgrades to existing infrastructure at Lake Road and Koala Street.
Disclose a clear financial plan for the entire cost of the project and its funding sources.
Address all outstanding cultural heritage matters with the appropriate involvement of Birpai Traditional Owners.
Conduct an independent environmental and health risk review, particularly relating to the use of potentially hazardous materials.

This project, in its current form, is flawed in both process and substance. It risks long-term environmental, cultural, financial, and social damage. I urge the Council to reconsider the direction of this development and take immediate action to ensure that future decisions reflect integrity, evidence, and respect for all stakeholders.

Subject: Personal Objection to the Thrumster Wastewater Treatment Plant Project

I am writing to formally object to the proposed Thrumster Wastewater Treatment Plant (WWTP) project. This will affect all residents and ratepayers of Port Macquarie and I have serious concerns about the planning, transparency, environmental impacts, financial impacts, and procedural integrity associated with the project.

Omission of Critical Information
It has come to my attention that several important documents—containing findings that challenge the suitability of the Thrumster site—were omitted from the Environmental Impact Statement (EIS), Response to Submissions (RTS), and Amendment Report (AR). These include the Strategic Wastewater Management Plan, the Discharge Options Assessment, and the Connection Investigation Response from Essential Energy (April 2025), among others.
The excluded information suggests that the selected site is less viable than alternatives like Lake Road or Koala Street, particularly in terms of financial, environmental, cultural, and public health outcomes. The failure to include these assessments undermines the credibility of the entire planning process and appears to reflect a biased agenda rather than evidence-based decision-making.

Limited and Misleading Public Communication
Asa resident, I was totally unaware of this proposal. It was not till a friend told me about it and it's impacts that I even knew this was a proposal. The Council’s public website remains incomplete and misleading. As of 10 May 2025, it still does not provide updated information on major developments such as cost escalations or infrastructure changes. I am incredibly concerned about the proposals' financial, ecological, indigenous, or questionable transparency issues. This failure to communicate openly deprives the public of their right to fully understand and respond to the impacts of the proposal.

Cultural Heritage Concerns
I am also deeply disturbed by the treatment of the Birpai Registered Aboriginal Party (RAP) in relation to archaeological investigations. The reported exclusion of the Birpai RAP from test excavations—despite their prior involvement and formal interest—raises serious ethical and legal concerns. The fact that their objections and complaints were never documented in the EIS further demonstrates a lack of integrity and cultural respect.

Withholding of Power Supply Information
I understand that a revised power supply assessment from Essential Energy (dated 4 April 2025) revealed major changes to the electricity route for the WWTP, requiring overhead lines and a new alignment. Yet this was not disclosed in the AR or RTS. The Council’s apparent plan to introduce this as a modification at a later stage is deeply concerning and inconsistent with the principles of open, lawful environmental planning.

Financial and Ethical Issues
I am troubled by the lack of transparency surrounding the project’s funding. There is no clear explanation of updated costs, or any information about where the remaining funds will come from, raising concerns about financial burden on ratepayers.
The fact that only two companies were invited to tender—followed by their merger—and the existence of family connections between Council employees and project contractors also raises legitimate questions about the fairness and integrity of the procurement process.

Environmental and Health Risks
I am especially concerned about the health and environmental risks associated with fill materials that reportedly contain asbestos. This poses a serious risk to residents, wildlife, and ecosystems. This risk appears to have been overlooked or ignored in the planning documents.

My Request
Based on these concerns, I respectfully request that the Council:
Immediately suspend further progress on the Thrumster WWTP project until a full and transparent review is undertaken.
Reassess the project site, giving proper consideration to viable alternatives, including upgrades to existing infrastructure at Lake Road and Koala Street.
Disclose a clear financial plan for the entire cost of the project and its funding sources.
Address all outstanding cultural heritage matters with the appropriate involvement of Birpai Traditional Owners.
Conduct an independent environmental and health risk review, particularly relating to the use of potentially hazardous materials.

This project, in its current form, is flawed in both process and substance. It risks long-term environmental, cultural, financial, and social damage. I urge the Council to reconsider the direction of this development and take immediate action to ensure that future decisions reflect integrity, evidence, and respect for all stakeholders.

Subject: Personal Objection to the Thrumster Wastewater Treatment Plant Project

I am writing to formally object to the proposed Thrumster Wastewater Treatment Plant (WWTP) project. All residents and ratepayers of Port Macquarie will be directly affected by this development and I have serious concerns about the planning, transparency, environmental impacts, financial impacts, and procedural integrity associated with the project.

Omission of Critical Information
It has come to my attention that several important documents—containing findings that challenge the suitability of the Thrumster site—were omitted from the Environmental Impact Statement (EIS), Response to Submissions (RTS), and Amendment Report (AR). These include the Strategic Wastewater Management Plan, the Discharge Options Assessment, and the Connection Investigation Response from Essential Energy (April 2025), among others.
The excluded information suggests that the selected site is less viable than alternatives like Lake Road or Koala Street, particularly in terms of financial, environmental, cultural, and public health outcomes. The failure to include these assessments undermines the credibility of the entire planning process and appears to reflect a biased agenda rather than evidence-based decision-making.
Limited and Misleading Public Communication
The Council’s public website remains incomplete and misleading. As of 10 May 2025, it still does not provide updated information on major developments such as cost escalations or infrastructure changes. Personally as a resident, until this was brought to my attention I was totally unaware of this project, let alone its financial, ecological, indigenous, or questionable transparency issues. This failure to communicate openly deprives the public of their right to fully understand and respond to the impacts of the proposal.

Cultural Heritage Concerns
I am also deeply disturbed by the treatment of the Birpai Registered Aboriginal Party (RAP) in relation to archaeological investigations. The reported exclusion of the Birpai RAP from test excavations—despite their prior involvement and formal interest—raises serious ethical and legal concerns. The fact that their objections and complaints were never documented in the EIS further demonstrates a lack of integrity and cultural respect.

Withholding of Power Supply Information
I understand that a revised power supply assessment from Essential Energy (dated 4 April 2025) revealed major changes to the electricity route for the WWTP, requiring overhead lines and a new alignment. Yet this was not disclosed in the AR or RTS. The Council’s apparent plan to introduce this as a modification at a later stage is deeply concerning and inconsistent with the principles of open, lawful environmental planning.

Financial and Ethical Issues
I am troubled by the lack of transparency surrounding the project’s funding. From what I understand, only about 30% of the required funding has been identified. No clear explanation has been given about where the remaining funds will come from, raising concerns about financial mismanagement and potential burden on ratepayers.
The fact that only two companies were invited to tender—followed by their merger—and the existence of family connections between Council employees and project contractors also raises legitimate questions about the fairness and integrity of the procurement process.

Environmental and Health Risks
I am especially concerned about the health and environmental risks associated with fill materials that reportedly contain asbestos. This poses a serious risk to residents, wildlife, and ecosystems. This risk appears to have been overlooked or ignored in the planning documents.

My Request
Based on these concerns, I respectfully request that the Council:
Immediately suspend further progress on the Thrumster WWTP project until a full and transparent review is undertaken.
Reassess the project site, giving proper consideration to viable alternatives, including upgrades to existing infrastructure at Lake Road and Koala Street.
Disclose a clear financial plan for the entire cost of the project and its funding sources.
Address all outstanding cultural heritage matters with the appropriate involvement of Birpai Traditional Owners.
Conduct an independent environmental and health risk review, particularly relating to the use of potentially hazardous materials.

This project, in its current form, is flawed in both process and substance. It risks long-term environmental, cultural, financial, and social damage. I urge the Council to reconsider the direction of this development and take immediate action to ensure that future decisions reflect integrity, evidence, and respect for all stakeholders.

I object on the grounds of mismanagement of rate payer funds. This project is around 150 million more expensive than upgrading Koala Street plant. This money should be put into reducing odour around the Koala Street plant instead.

The treatment plant is very close to a beautiful wetland and I believe that the bird and wildlife habitat will be adversely impacted .