Thrumster Wastewater Scheme

I am writing as a concerned member of the public. I am a frequent visitor to the Port Macquarie area and I'm also an avid bird watcher. I wish to formally object to the proposed Thrumster Wastewater Scheme (Thrumster WWS). My objection is based on serious concerns regarding the project’s transparency, governance, planning integrity, environmental impact, and public health implications.

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

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

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

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

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

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

4. Exclusion of Birpai RAP from Cultural Heritage Work
On 20 November 2024, a representative of the Birpai Traditional Owners—who was registered to participate in archaeological test excavations—was denied access to the site. This occurred despite the area being within Birpai Country and despite the individual’s prior involvement. In contrast, individuals from an Aboriginal council based outside the project area were permitted to participate. A formal complaint was lodged, followed by meetings with Council officers and the Mayor’s office in February and April 2025. Yet none of these events or concerns were included in the official documentation. The failure to document cultural artefacts found on-site, and the exclusion of local Traditional Owners, constitutes a serious breach of proper heritage consultation practices.

5. Concealment of Power Supply Changes
On 4 April 2025, Council received a revised connection response from Essential Energy indicating that the original underground power supply route was unfeasible. This necessitated a significant shift to overhead cabling, altering the project footprint. This critical information was not included in the RTS or Amendment Report. Intending to submit such changes as a post-approval modification is deceptive and contrary to planning obligations.

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

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

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

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

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

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

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

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

Sincerely,
Audrey Rangel

I have provided my letter as an attachment.

I have provided my letter of objection via the attached document.

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.

This project would be detrimental to the environment in the surrounding areas. There isn’t enough research to support the demand or evidence to indicate this is the best location to to build this. Would be a lot more cost effective to upgrade the current facility rather than use tax payers money.

Letter provided in attachment.

Letter attached with my objections.

I object to the submission based on the how much information has been withheld from the public, the implications on the surrounding area, environmental and health implications and cost to the rate payers.
This has been a very dishonest submission.

Please upgrade the existing waste water plant at Koala St first. I've heard it is significantly cheaper to upgrade this plant. I would drive home past it frequently and the odour is terrible at times. There are some great suburbs on the fringe of this plant that could be improved by reducing odour.

There is not enough science to back up the implications to both the environment and impact to the local residents and surrounding area.
Another ill conceived project.
The cost of this is concerning, an upgrade of the current facility would be more beneficial.

On 20 November 2024, a a registered representative of the Birpai Traditional Owners Indigenous Corporation —who had formally expressed interest in participating in archaeological test excavations—I was unjustly barred from accessing the site. This exclusion occurred despite the site being located on Birpai country.
Notably, no representatives from the Birpai Aboriginal Land Council participated in the test excavations. Only Bunyah Aboriginal Council representatives were involved, even though the site lies outside Bunyah country. GHD’s subcontractor justified this exclusion by citing a lack of immediate insurance coverage—despite the same I have previously participated in surveys (including those for the Cowarra Water Supply Scheme) under the insurance cover of the sub-consultant.
The exclusion appears retaliatory, as I had voiced strong concerns over the excavation methodology, disregard for identified cultural values, and potential negative impacts on heritage significance. I filed a formal complaint to the Council, met with Council representatives on 10 February 2025, and shared my feedback. Despite ongoing negotiations for further involvement in heritage surveys for amendments to the EIS (including Cowarra and Thrumster), my concerns remained unresolved.
I later escalated the issue to the Mayor’s office in April 2025. Yet none of these events or the substance of my complaint was disclosed in the EIS or associated reports by GHD and Niche. This omission demonstrates a clear lack of impartiality, transparency, and integrity in how the archaeological process was managed.
Key Concerns:
• I was excluded despite prior invitation and past participation.
• I had concerns regarding excavation methodology and cultural heritage ignored.
• Excavation areas reduced and the process was rushed.
• No report about my exclusion was presented.
• There is a likelihood of more artefacts despite the discovery of one.
• My additional identified values excluded.
• My Complaints and Concerns were not reflected in any documentation.

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, as follows:
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 who 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.
Thank you for your consideration of this objection.

Please see attached document

I am submitting a 7 page document outlining my informed and sincere objection to the so called "Thrumster Wastewater Scheme". The name itself is misleading-the facility is not located in Thrumster, but in Fernbank Creek. It is clear that by referring to it incorrectly, , the council is obscuring the reality: this is a plan to build a sewage treatment plant in the midst of a sensitive creek's environment.
Proceeding with the project exposes both the council and the state to serious financial and legal risks. The location is highly unsuitable, posing a real danger of flood related damage an accidents-risks so significant that insurance companies may refuse coverage or demand prohibitively high premiums (such is the case for the private properties in this location). These Liabilities combined with the already inflated project costs, could far exceed the financial capacity of Port Macquarie Hastings Council and potentially lead to financial ruin or the Council, placing an undue buren on ratepayers.

I am submitting a 7-page document detailing my informed and sincere objection to the so-called "Thrumster Wastewater Scheme." The name itself is misleading—this facility is not located in Thrumster, but in Fernbank Creek. It is clear that by referring to it incorrectly, the Council is obscuring the reality: this is a plan to build a sewage treatment plant in the midst of a sensitive creek environment.
Proceeding with this project exposes both the Council and the State to serious financial and legal risks. The location is highly unsuitable, posing a real danger of flood-related damage and accidents—risks so significant that insurance companies may refuse coverage or demand prohibitively high premiums. These liabilities, combined with the already inflated project costs, could far exceed the financial capacity of Port Macquarie Hastings Council and potentially lead to financial ruin for the Council, placing an undue burden on ratepayers.

Please see attachment for my submission of Objection to the Thrumster Wastewater Scheme SSI-56980459

I have attached my submission.

I am submitting a 7-page document detailing my informed and sincere objection to the so-called "Thrumster Wastewater Scheme." The name itself is misleading—this facility is not located in Thrumster, but in Fernbank Creek. It is clear that by referring to it incorrectly, the Council is obscuring the reality: this is a plan to build a sewage treatment plant in the midst of a sensitive creek environment.
Proceeding with this project exposes both the Council and the State to serious financial and legal risks. The location is highly unsuitable, posing a real danger of flood-related damage and accidents—risks so significant that insurance companies may refuse coverage or demand prohibitively high premiums. These liabilities, combined with the already inflated project costs, could far exceed the financial capacity of Port Macquarie Hastings Council and potentially lead to financial ruin for the Council, placing an undue burden on ratepayers.

I am submitting a 7-page document detailing my informed and sincere objection to the so-called "Thrumster Wastewater Scheme." The name itself is misleading—this facility is not located in Thrumster, but in Fernbank Creek. It is clear that by referring to it incorrectly, the Council is obscuring the reality: this is a plan to build a sewage treatment plant in the midst of a sensitive creek environment.
Proceeding with this project exposes both the Council and the State to serious financial and legal risks. The location is highly unsuitable, posing a real danger of flood-related damage and accidents—risks so significant that insurance companies may refuse coverage or demand prohibitively high premiums. These liabilities, combined with the already inflated project costs, could far exceed the financial capacity of Port Macquarie Hastings Council and potentially lead to financial ruin for the Council, placing an undue burden on ratepayers.

I am submitting a 7-page document detailing my informed and sincere objection to the so-called "Thrumster Wastewater Scheme." The name itself is misleading—this facility is not located in Thrumster, but in Fernbank Creek. It is clear that by referring to it incorrectly, the Council is obscuring the reality: this is a plan to build a sewage treatment plant in the midst of a sensitive creek environment.
Proceeding with this project exposes both the Council and the State to serious financial and legal risks. The location is highly unsuitable, posing a real danger of flood-related damage and accidents—risks so significant that insurance companies may refuse coverage or demand prohibitively high premiums. These liabilities, combined with the already inflated project costs, could far exceed the financial capacity of Port Macquarie Hastings Council and potentially lead to financial ruin for the Council, placing an undue burden on ratepayers.