Thrumster Wastewater Scheme

I am writing to formally object to the proposed Thrumster Wastewater Scheme for the following reasons:

1. Threat to Endangered Species and Ecological Habitats
The environmental impact assessment, including reports prepared by GHD, indicates that the proposed development could lead to the destruction of critical habitat and cause significant, potentially irreversible effects on both terrestrial and aquatic ecosystems. This includes impacts on listed threatened species such as the Giant Dragonfly (Petalura gigantea), Swift Parrot, Slender Marsdenia, and Koala which are of National Environmental Significance. Furthermore, the project does not include these environmental offset costs (credits) which are typically required when such habitat destruction occurs, in dollar value, in their project cost estimate.

2. Aboriginal Cultural Heritage
The site holds potential cultural significance, evidenced by the findings at the proposed Thrumster Waste Water site, in the Niche Report. 38 artefacts, including a large museum-quality blade core, were discovered. However, the survey recorded poor ground visibility (10–20%), suggesting the study may not have been comprehensive.
No consultation appears to have taken place with the Birpai Aboriginal Land Council. Given the cultural sensitivity of the site, further independent investigation and appropriate stakeholder engagement should occur before proceeding.

3. Construction Impacts: Noise, Dust, and Contamination Risks
The amendment document presents contradictory information regarding construction noise limits. Specific clauses (e.g., NV4 in Appendix B) potentially permit noise and vibration for up to four nights per week, which may cause significant disturbance to nearby residents. These discrepancies require clarification and independent review.

Additionally, the concurrent Cowarra Water Supply Scheme reportedly containing soil with naturally occurring asbestos. Concerns exist regarding the potential use of this fill at the Thrumster site without appropriate testing or disclosure to residents or regulatory bodies. If substantiated, this raises serious public health risks, especially given the proximity of families and young children.

Only visual water quality monitoring during construction is proposed. This is inadequate to detect contaminants such as asbestos fibers, silica dust, or sediment runoff, all of which could adversely affect local waterways and groundwater sources which residents depend upon

4. Operational Risks and Maintenance Concerns
The project documentation lacks detail on operational risks, such as chemical transport safety, odour emissions, vermin, and ongoing maintenance traffic. For instance, there is no assessment of potential incidents, such as vehicular accidents involving chemical transport vehicles (e.g., chlorine), which could result in environmental harm.

5. Power Supply Uncertainty
The plan for electrical connection from Essential Energy appears outdated or incomplete. Current documentation omits whether the power lines will be underground or aboveground—an important consideration due to potential land acquisition impacts and community safety. Moreover, the associated costs for the new power supply have not been factored into the project budget.

6. Stormwater and Flooding Concerns
The development reduces permeable land and adds substantial hard surfaces, increasing stormwater runoff and the risk of sedimentation in Partridge Creek and Fernbank Creek. Floodplain loss is not adequately addressed in the modelling, particularly in light of known flood events in 2020.
In 2020, this area had significant floods and many houses on Fernbank Creek Rd and Hastings River Drive were flooded. If you remove this flood plain with land fill, any further flood will have greater impact with increased flood levels on the residents of Fernbank Creek Rd and therefore increase the risk of sewage spill from the plant. Further modelling taking into account a change of land use should occur
Furthermore, flood modelling does not appear to incorporate future climate change effects such as sea level rise or land-use changes—rendering the existing flood risk analysis potentially unreliable.

7. Odour and Bioaerosol Pollution
Concerns remain regarding the impact of odour and airborne contaminants on neighbouring properties. Specifically, the potential for bioaerosols, including microorganisms and toxins from wastewater processes, has not been properly assessed.
The RTS document claims that bioaerosols are unlikely due to enclosed treatment processes. However, the amendment report describes an open bioreactor system, which may facilitate the release of bioaerosols into the surrounding environment—particularly concerning for nearby residents reliant on rainwater tanks for drinking water.
The odour analysis still lacks an analysis of the impact of temperature inversion (which occurs overnight) on odour pollution to the local residents

8. Flood-Free Access and Traffic Hazards
The development lacks flood-free access, with primary roads falling below the 1-in-100-year flood level. Local residents report significant pressure regarding land access, raising concerns about transparency and fair engagement.

Additionally, the project is expected to substantially increase heavy vehicle traffic on Fernbank Creek Road, which lacks adequate infrastructure for pedestrians, including children and cyclists. The road is narrow and currently not designed for the volume or type of traffic the project would bring. GHD reports dismissing pedestrian presence in the area do not reflect community reality.

9. Missing Documents and Transparency Concerns
Key documents, including cost comparisons and alternative site assessments, have not been disclosed to residents. For example, residents adjacent to Partridge Creek were reportedly excluded from consultation meetings, raising concerns about equitable community engagement.
I respectfully request that the Department of Planning, Housing and Infrastructure formally obtain and review the following documents:
• Thrumster Wastewater Scheme – Strategic Wastewater Management Plan (Beca HunterH20, 2023d)
• Discharge Operation Assessment (Beca HunterH2, February 2024)
• Connection Investigation Response (April 2025)
• Feedback from the Birpai Traditional Owners Corporation

10. Project Cost and Viability
Costings for the Thrumster Scheme have risen dramatically—from $134 million (excluding GST and contingency) to over $200 million. When including operational costs, costs will be $312 million plus power infrastructure costs, road upgrade costs and environmental offset costs etc. The total cost potentially will be greater than $400 million.
Comparatively, a centralised upgrade of existing infrastructure (e.g., Koala Street facility) was costed at $265 million, offering potentially lower environmental and cultural impact. It is unclear why this option was not transparently presented to the community or selected by Council.
Recommendations
In light of the concerns outlined above, I respectfully request that the Department of Planning, Housing and Infrastructure:
• Suspend all approvals relating to the Thrumster Wastewater Scheme pending a full review of the project documentation, environmental assessments, and community consultation process.
• Investigate the feasibility of upgrading the existing Koala Street facility as a more cost-effective and environmentally appropriate alternative.
• Engage transparently with all stakeholders, including residents of Fernbank Creek and the Birpai Traditional Owners.
• Require disclosure of all previously withheld documents under the Government Information (Public Access) Act (GIPA).
• Commission independent reviews of health, environmental, cultural, and traffic impacts prior to proceeding.

Thank you for your consideration of this submission.
Sincerely

I have attached a Word doc listing my concerns about this project.

I have attached a Word document outlining my objection to the project,

n addition to my previous submission, please find photos of Fernbank creek Rd and partridge creek lane taken today 20/5/25. Evidently this area floods significantly in heavy rainfall. This is an inappropriate location for a sewerage plant. In heavy rainful I am concerned about:
1) flooding to the propose site
2) flooding to access roads and restricted access to the site
3) possible high frequency of discharge into the area during heavy rainfall and subsequent health impacts to humans, livestock and surrounding wildlife
4) increasing flood prone areas adjacent to the access road and site (and into our current property) due to raising of the road and site

Do not build any form of sewerage or treatment plants on such low lying grounds as this. The sewerage pits are all overflowing currently due to stormwater flowing into septic lines instead of the stormwater drains to flow into the ocean.

I have attached a Word doc detailing my concerns about this project.

The proposed location of this project is within an are that floods and/or retains water and creates a lot run off. Being extremely near to the Hastings River, this may result in accidental spillage into the river, poisoning the river. Another site of less risk should be found.

I am a high school student who walks everyday along Fernbank Creek Rd to the bus stop at Hastings River Drive, often with my sisters. My parents have informed Council and GHD numerous times about the issue of safety for pedestrians like myself. Why has Council and GHD misled the Derpartment of PHI in their RTS where they state that there is no pedestrian activity expected?
I also walk my dog everyday on the road where I see heaps of other pedestrians and cyclists.
Why is the Council risking my safety?
With the noise and vibration expected during construction, how am I expected to study and sleep well?
I also attend a local high school which will also be affected by noise and vibration. I am very effected by this project

Formal Objection to the Thrumster Wastewater Treatment Plant (WWTP) Proposal
I write to formally object to the proposed Thrumster Wastewater Treatment Plant (WWTP) due to significant concerns regarding omitted critical documents, misleading information, and serious procedural failures by the Council and its consultant, GHD. These issues undermine transparency, integrity, and accountability in the planning and assessment process.

1. Omission of Key Reports and Misrepresentation of Facts
Essential reports evaluating the site’s viability were deliberately excluded from the Environmental Impact Statement (EIS), its appendices, and subsequent assessments. These omitted documents highlight the site’s inferiority compared to alternatives such as Lake Road and Koala Street.
Excluded reports include:
• Thrumster Wastewater Scheme – Strategic Wastewater Management Plan (Beca HunterH2O, 2023)
• Discharge Options Assessment (Beca HunterH2O, Feb 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
Findings indicate the site is unsuitable due to:
• Flood vulnerability and environmental risks
• Cultural heritage disruption (artefacts identified in test excavations)
• Long-term ecological degradation
• Negative social and public health impacts
• Higher capital (CAPEX) and operational (OPEX) costs
Meanwhile, an upgrade to the existing infrastructure—previously supported by the EPA—would:
• Improve receiving water quality
• Reduce air pollution and odour impacts
• Limit cultural and ecological disturbance
• Avoid major land acquisitions and diversions
• Lower overall project costs
The deliberate exclusion of these findings from the EIS, Response to Submissions (RTS), and Amendment Report (AR) constitutes a deceptive omission, depriving decision-makers of vital evidence.

2. Misleading Public Communication and Withheld Cost Information
Despite assurances of transparency, the Council’s website continues to present incomplete and misleading project details. The public exhibition period was inadequately promoted, preventing affected residents from meaningful engagement.
Additionally, significant cost escalations have not been disclosed. The absence of updated financial data reflects intentional opacity, obstructing scrutiny of the project's feasibility compared to more viable alternatives.

3. Exclusion of Birpai RAP from Archaeological Excavations
On 20 November 2024, a representative of the Birpai Traditional Owners—who had formally registered interest—was unjustly denied access to participate in archaeological excavations on Birpai Country. Instead, only Bunyah Aboriginal Land Council representatives were allowed involvement, despite the site being outside their territory.
Concerns raised by the Birpai RAP include:
• Poor excavation methodology
• Disregard for cultural significance
• Heritage destruction risks
Despite formal objections, no reference to these concerns appears in official project documentation, raising serious questions about impartiality and cultural sensitivity.

4. Suppression of Critical Infrastructure Changes
On 4 April 2025, Essential Energy’s updated connection investigation revealed that the originally proposed underground conduit was unviable, necessitating significant revisions. Overhead power lines and altered routes affect environmental and planning considerations.
This critical information was withheld from the AR and RTS, seemingly reserved for later modifications—contravening environmental assessment principles.

Conclusion and Formal Requests
The suppression of key reports, misrepresentation of project impacts, exclusion of Indigenous stakeholders, and withholding of financial and infrastructure data constitute serious breaches of public trust and statutory obligations.
I respectfully request the following immediate actions:
1. Independent review of the EIS, RTS, and AR for accuracy, completeness, and integrity.
2. Suspension of all planning decisions pending a full reassessment of omitted reports and comparative site analyses.
3. Transparent re-engagement with affected stakeholders, including the Birpai Traditional Owners and local residents.
4. Public disclosure of all withheld documents, including updated cost estimates and site assessments.
5. Referral of the EIS to DPHI and relevant authorities for comprehensive reassessment before project approval.

The affected communities deserve a planning process that is honest, inclusive, and evidence-based. Immediate corrective action is necessary to uphold the integrity of environmental and cultural assessments.

I strongly object to the misleadingly named "Thrumster Wastewater Scheme," which is actually planned for Fernbank Creek—a sensitive environmental area. By misidentifying the location, the Council obscures the true nature of this project: a sewage treatment plant in a vulnerable creek ecosystem.
Beyond environmental concerns, this plan carries immense financial and legal risks. The site is prone to flooding, increasing the likelihood of costly accidents. Insurance may be unavailable or prohibitively expensive, adding to the already inflated costs. These liabilities could overwhelm Port Macquarie Hastings Council’s financial capacity, threatening economic stability and unfairly burdening ratepayers.

As a concerned member of the community, without bias & I object to the project proposal based on the following primary concerns:
- I am aware of the potential for irreversible environmental damage to the existing flood plain & the concerned the impact of this project can cause with long term damage to the natural ecosystem.
- its my understanding that a far more economical alternative is available in the upgrade of the existing infrastructure at Koala Street with savings to the rate & taxpayers estimated to be several million of dollars.
- the existing inferior public road system in the immediate vacinity cannot support the machinery required to undertake the proposed infrastructure & therefore put the immediate public at risk (ignoring the noise pollution they will be expected to endure).
- and finally, I have been made aware of the existence of aboriginal relics located at & around the proposed site. If that's the case, then the respective elders should be consulted & naturally be invited to participate in the process before any decisions on approval are progressed.

Objection to the Thrumster Wastewater Scheme
Submitted by: John Wagstaffe Community Member and Aboriginal

To Whom It May Concern,
RE: Objection to the Thrumster Wastewater Scheme
I wish to raise strong objections to the proposed Thrumster Wastewater Scheme.
This project is located on Birpai Country, and I am deeply concerned that the Aboriginal Cultural Heritage has not been properly investigated or protected. The current reports only mention 38 artefacts, and visibility during the site inspection was very low — between 10% and 20%. This tells us that many more cultural items may still be present and have not been found.
I understand Birpai LALC was not properly included in the inspection or consultation process, even though They are the recognised Traditional Custodians of this land. This is not acceptable and goes against the respect and care that should be shown when planning developments on Aboriginal land.
We also have concerns about the destruction of native bushland, threats to endangered animals, and health risks to nearby families. Important documents have been left out of the public reports, and local residents and Traditional Owners have not been given a fair chance to be heard.
For these reasons, we ask that:
• The project is paused immediately.
• A proper Aboriginal Cultural Heritage inspection is done with Birpai LALC present.
• All missing reports are released to the public.
• A new location for the wastewater facility is considered.
We ask that the Department of Planning, Housing and Infrastructure listen to the community and take the right steps to protect Birpai Country and culture.
Yours sincerely,
John Wagstaffe
26 Doncaster Avenue,
Port Macquarie. NSW 2444

Cultural requirements have not been met

Personal Objection to the Thrumster Wastewater Treatment Plant Project.
Please read attachment for in depth comments on the proposed Waste Water Plant .

I have attached a Work doc and two photos taken of flooding today 21/5/25.

I am attaching here by:
1. SES dangerone map issued yesterday. It clearly shows Fernbank Creek as a central disaster zone. The "Danger logo" actually is just about where the plant is planned for. Reflecting how irresponsible it is to plan such a plant in a constant danger zone with frequent floods (Major ones: 2013,2021,2025), but the creek is in overflow most of the time as the creek is just a name, its full with everything one can imagine and its no more than a few centimeters deep. And council kows of it very clearly.

2 photos of my own land, showing water from the reek that advanced into the padocs. The creek itself is about 150 meters away.

I am attaching hereby several pictures taken in the last 2 days in the Fernbank Creek area. It's flooded heavily! The road leading to the planed site is closed, the alternative passage planned is too. Such amount of rainfall on the large concrete surface on he plant will rush down towards the creek which all year round is unable to accommodate any water. Its capacity at all times and spills over the neighbouring lands. No such plant, within the limited budgets is geared to be able to hold so much water and will by no doubt at all, end up as raw sewage in the marshes, the swamps and contaminate every meter of this unique ecosystem.