IWCM- Review by Save Byrrill Creek Group February 2102

To the General Manager, Mr Mike Rayner

Tweed Water Staff Tweed Shire Council

The Save Byrrill Creek group welcomes the opportunity for an Independent Review of the IWCM

For this to be a truly independent Review we request that both Hunter Water and MWH are not contracted to do the Review. We support an independent body such as the Institute for Sustainable Futures, University of NSW who could review this whole process with fresh eyes.

Our reasons for the exclusion of Hunter Water and MWH are:

MWH have a long history linked to Tweed Council. They are the authors of the Tweed DMS and were involved in the selection process for Tweeds Water Augmentation Options. MWH also authored a lot of the documentation, that was found to be inaccurate, on the Traveston Dam SE QLD which was banned by the Federal Government. Hunter Water are the authors of the IWCMS 2006 and were also proponents for the failed Tillegra Dam, Newcastle.

We request that the Demand Management Strategy (DMS) and Tweeds Water Augmentation Options is also reviewed during this process.

The Community Working Group on Tweeds Water Augmentation Options and the general community have repeatedly requested the Tweed Council for an Independent review of the Demand Management Strategy(DMS) since March 2009. As the IWCM is the precursor to the DMS, and both are interelated, we ask that the Review looks beyond the parameters of the  IWCM and includes the DMS, in which many anomalies have been found and  should also include the documentation of Tweeds Water Augmentation Options

We also request that Geolinks Brief Review of Tweeds Water Supply Feb 2010 be included in the Documents to be reviewed.

Geolink is an independent environmental management and design consultancy firm, based in Lennox Heads, who offered to do a brief Review of the Councils DMS and Water Options, which was sent to Council in Feb 2010. SEE ATTACHED 1.

A few Salient points from this review include:

1.Undertaking the Demand Management Strategy and the Water Supply Augmentation Options Study as a separate processes (as has been done in Tweed Shire) is unlikely to produce the best outcome. Both processes are a means to the same end. The most appropriate and sustainable water supply strategy should be developed by considering all options in an integrated manner.

2. It would have been beneficial to include all of the options considered in the Demand Management Strategy within the Water Options Study (i.e.rainwater tanks and localised recycled water). A shortcoming of the Water Supply Augmentation Options Study, is that combinations of options were not considered.

3. A recycled water scheme is likely to be most practical in the five greenfield major development areas. Cobaki could have an on site system as was suggested in the DMS. It would be prudent to require the design of the subdivision to include dual reticulation: key portions of the dual reticulation infrastructure should be installed at the development stage because it will be much cheaper than retrofitting at a later date.

4.Geolink believe there is an opportunity to consider (and re-examine if necessary) options that involve considerably less social and environmental impact than the options that were shortlisted in the Water Supply Augmentation Options Study.

5.The Tweed at present has plenty of water and with the demonstrated reduction of water use, despite an increase in population, and with rigorous proactive demand management actions its possible no water supply augmentation may be required within the planning horizon to 2036.With approximately 3000ML only needed.. what is the rush?

We also request that the Documents listed within The Summary on Page 6 of this Submission be included in the Documents to be reviewed.

Community Consultation Process

We also welcome the proposed Community Consultation during this process, however the concerns of Tweed residents and the Community Working Group (CWG), who requested a more sustainable water solution to Tweeds Water Augmentation, were ignored by both the Council Water staff and Councillors.  SEE ATTACHED 2. CWG Statement March 2010 In asking for community input, there is the equal responsibility of Council to take heed and act on the community’s requests.

Integrated Water Solutions

Throughout the IWCMS 2006 the aims and objectives state innumerable times the necessity for Integrated solutions: Water Sensitive Urban Design, Stormwater detention/capture, reducing nutrient discharge into rivers and estuaries, encouraging Environmentally Sensitive Development, reuse of water and dual reticulation in new developments. Eg Summary iii, iv,and v: Urban Waste Water Actions, General Urban Actions 3., 11, 13, and 14, 18 and 20 5.3.1 Page 69  Preliminary Strategy 3., 11, 13, and 14, 18 and 20. 5.2.1 Page 68 Options for Integration; 1:High Quality Effluent Reuse, 4: Decentralised Sewerage,5: Stormwater reuse, 6: Water Sensitive Urban Design.

IWCM Page 68 Quote “It is likely that a range of integrated solutions will need to be adopted across the catchment in order to achieve a sustainable urban water cycle. Sustainability is unlikely to be achieved through the adoption of just one or two key integrated solutions or strategies.

This is in line with recommendations from the QLD Govt Dept of Environment and Natural Resource Management: To shift away from traditional reliance on rainfall and surface storages as the sole source of supply, to a diverse portfolio of supply sources: a mix of both decentralized and centralized systems SEE ATTACHED 3.

It is interesting to note that when Geolink, put forward the idea of using multiple options for water supply their Review was discounted and questions about figures in the DMS were ignored by the Council

I put to the Council that since 2006 the IWCM integrated objectives and solutions have been buried and not adopted. The solution for water supply has been one choice and one choice only: of a centralized dam system either at Byrrill Creek or Clarrie Hall.

Council Inaction on an Integrated Water Solution

There have been plenty of opportunities for Council to implement diversity, decentralization and reuse of water which have repeatedly put aside over the years since the adoption of the IWCM. Granted since 2006 Bogangar Sports Field, Chinderah Golf Course and Condong Cogeneration Facility now use recycled water but this is a minimalistic token. As 71% of Water use is consumed by residential rather than commercial use (DMS Exec Summary Figure E1) The target should be to ensure new developments, with a projected population of 35,000, incorporate major water saving. Development Applications for Cobaki and Kings Forest Greenfield Developments, with a proposed extra 25,000 population has been a shining example of the lack of action by Council. Leda Developers originally proposed dual reticulation, and council did not negotiate this through properly with them and it was abandoned.

In May 2011 the Save Byrrill Creek Group twice presented the case for implementing 10,000lt Water Tanks plus dual reticulation at Cobaki Development to the  NSW Regional Panel of Planning. During enquiries to Council by the NSW Regional Panel on Cobaki, when there was a good chance to implement dual reticulation into the development consent, the council again backed down on implementing dual reticulation plus rainwater tanks, instead only recommending voluntary 5,000lt rain water tanks. We believe this was an incomprehensible lack of foresight into Tweeds long term water future, as it has now set a precedent for Leda’s other Development of Kings Forest which is being approved currently. In surrounding shires, Pimpana/Coomera SE QLD and Ballina it is the Councils that state to developers quite clearly that a condition of your Development approval will be Dual reticulation, rainwater tanks and water sensitive Urban Design. In Tweed it seems we pander to the multi million $ developers and lose a golden opportunity for a more sustainable future.

Councils attitude is reflected in this statement: “In respect to new development, Council is willing to receive and assess submissions from developers who propose reuse” Quote Council Minutes Page 11 Item 24 Feb 15 2011: Integrated Water Cycle Management Strategy: I ask what developer would propose it? It is up to the Council to propose, negotiate payment and ensure implementation!

Problems that warrant Investigation within the DMS and Council Report on IWCM

1. Population Predictions and Water Consumption need to be recalculated in the Review

Graph: Figure 4-1 TSC Total Demand Forecast Page 20 DMS is misleading using a pre BASIX Baseline Scenario. A TSC workshop in October 2010 indicated this was a sliding graph dependent on water consumption and population growth which had altered and already reduced since 2009 DMS and that the timeframe for augmentation could be extended. If the total future water supply demand  is based on these erroneous calculations it alters other scenarios within the DMS.

New Population Figures: A new company, ID Consulting, recently engaged by Tweed Shire Council, has provided revised population forecasts (Council website) which have dramatically lowered population estimates for 2031: 143,488 residents(DMS): 128,135 residents(ID Consulting):This equates to 15,353 less residents than predictions within the DMS a 10.7% reduction in population which should be carried through to water consumption.

2. Pge 18 Table 4-1 Number of Accounts and 4.2 Annual Consumption may be wrong

Geolink questioned that tables in the DMS did not add up and may be an overestimation of 14% which if carried through in further calculations could change the whole scenario. Further checking show it to be 12-13%, and that water consumption according to 4.1 and 4.2 should be decreasing, not Increasing. A Review needs to recheck these figures.

3  The choice of Scenario 1 by Council and recommendations in the conclusion is not backed up by other statements within the DMS:

As part of the DMS, dual reticulation and decentralized sewerage was found to be no advantage over BASIX and 5000L water tanks” Page 12 Council Minutes Feb 15 2011 Item 24 IWCM

We disagree with this statement: For a start BASIX is state regulated and would have to be adhered to anyway. Scenario 3 within the DMS is the outstanding sustainable choice for saving water, utilizing BASIX and both Dual reticulation and tanks in new developments. Water consumption is reduced from167 L/person /per day to 93 L/person /per day.

Page 99 Conclusions 9. DMS “Reduction of potable water use was determined to be approx 36%, 42% and 61% for Scenarios1, 2 and 3 respectively for Greenfield areas excluding West Kingscliff” . This is a 25% saving from Councils chosen Scenario 1!

Page 100 Conclusions 13. DMS: “Scenario 3 has the highest savings potential at the lowest cost per kl saved to the community….. The majority of the costs  are the responsibility of the householder

Dual reticulation recycled water could be used for outdoor garden use and toilets which accounts for approximately 30-40% of a household use. Rainwater tanks could be used for Washing machines and showers which accounts for another 40-50%. The remaining approx 20% for kitchen use and taps comes from the council water mains.

4.The choice of Scenario 1 by Council contradicts The Far North Coast Regional Strategy Plan 2006: Page 40 10 Water and Energy Resources: Actions ” All future development is to apply water sensitive urban design principles including the use of dual reticulation systems in releases of adequate scale and meet storm water management targets that support the environmental values of the catchment.

Environmental Impacts have not been factored in to the DMS choice of options or this  equation of “advantage.”

Page 99 Conclusions 9. DMS “From an environmental perspective Scenarios 2 and 3 reduce return effluent flows to water ways by more than 10%”

Councils statement: “dual reticulation would provide no greater environmental social or economic benefit than rainwater tanks“.  Table 5-29 of the DMS shows a reduction in STP discharges of 1,401 ML/yr for the dual reticulation options compared to 0 ML/yr for the water tank only option.

Page ii Summary IWCM) 7.5GL of effluent is discharged into our creeks and estuaries every year with less than 5% being reused Urban storm water runoff contributes heavily to nutrient and sediment loads with only limited treatment currently occurring“. I ask in this situation why are we not reusing water recycling through dual reticulation and storm water capture and creating healthy water ways at the same time?

Basically with no large water savings (ie Scenario 3 but with a larger tank of 10,000lt or more) incorporated into new developments, a new water supply would need to be built, either upgrading Clarrie Hall or a dam at Byrrill Creek. Both of these choices have huge environmental impacts. The 36,000ML dam at Byrrill Creek would have 400ha bulldozed and cleared, 21 ha of high conservation lowland forest in Mebbin National Park would be inundated and the greenhouse impacts of a new dam and construction would be vast.

The State Government Weirs Policy does not support new or expanded dams.

NSW Weirs Policy: Approvals for New or Expanded Weirs Page 3 An increase in town water supply for the purposes of meeting projected population demand cannot be used as a justification to approve a proposal to build a new, or expand an existing weir, if environmentally friendlier alternatives to meeting that demand exist which are also economically feasible.

Water Sensitive Urban Design and Environmentally Sensitive Developments:   IWCM objectives clearly promote Water Sensitive Urban Design and Environmentally Sensitive Developments  and suggest how sustainable development could be achieved through regulations.

IWCM Page 58 5.1.4 General Urban Issues “There are a number of control measures to encourage or enforce sustainable development which come under the banners of Environmentally Sustainable Design(ESD) and Water sensitive urban design (WSUD) These are in the form of planning controls at a state level (BASIX)  and at a Council level with the inclusion of ESD  and WSUD requirements in existing DCP’s. These control measures need to be subject to constant review and revision to ensure they are achieving the desired objective of sustainable development.

None of the Developments that have been approved, or are being approved at present within the Tweed Shire adhere to these sustainable principles. Where are the swales instead of concrete gutters, storm water capture ponds and recycled water options? Where is the open space and vegetated areas to reduce run off? Instead house block sizes are being reduced to less than council standards and buildings fill the entire house block. Urban development, with its paved surfaces, are the main contributing factor to rainfall runoff and storm water pollution.

The developments that have gone ahead in Tweed Shire over the last 10 years have changed the face of this shire, particularly the coastal areas: especially Salt and Casurina, which are in the inundation zone for sea rise levels due to climate change. At the Sea Breeze Development, Pottsville, which has been built since 2006, we do not see environmentally friendly and water sensitive design: It was bulldozed, not an original  tree left, concrete gutters, overflows and run offs polluting nearby creeks. At Cobaki site: Koala food trees were destroyed, the site was bulldozed, with huge sediment out flows into the Cobaki Broadwater on May 6th 2010  SEE PHOTO ATTACHMENT 4

At Bilambil Heights: protected trees were cut down by a contractor, and recently adjacent to  Kings Forest: Blacks Creek, riparian areas were illegally cleared in the Nature reserve, with an apology from Leda, but not even cautioned by Council. How a core habitat area for Koalas got initial development approval by Council in the first place is unbelievable. Are these examples of implementing sustainable developments and are the “control measures being enforced”?


  • It is quite clear that the accuracy of the Demand Management Strategy needs close examination.
  • Future population and water consumption need an entirely new study within the Review
  • That the ultimate choice within the DMS by MWH, and support by Council, of Scenario 1 (BASIX and an inadequate 5000lt tank) for Urban Development showed a lack of foresight into Tweeds future water use and savings, in essence it relies on a centralised dam water supply, either upgrade Clarrie Hall or a new dam at Byrrill Creek.
  • Their decision has not taken into account environmental impact issues of stormwater or effluent discharge into water ways, or the future construction of dams.
  • This is partly a result of the Councils action of separating the DMS entirely from the Tweed Water Augmentation Options, which is in itself contradicts the aims and objectives within the Integrated Water Cycle Management Strategy.
  • The choice of Scenario 1 is also in contradiction to NSW Government Policies and Strategies: 1.Far North Coast Regional Strategy Plan 2.Tweed Alluvial Water Sharing Plan 2010 3.The NSW Weirs Policy
  • It is also quite clear that objectives and aims within the IWCM Strategy on Water Sensitive Urban Design and Environmentally Sensitive Developments have not been implemented in the last 6 years.

The Save Byrrill Creek Group supports Geolink’s recommendations:

Integrate Water supply Options with the DMS Options (not as a separate process); consider a Combination of  supply options; plan and implement a recycled water scheme in the five Greenfield major development areas; Increase tank size to 10,000lt,and with rigorous proactive Demand  management actions it’s possible no water supply augmentation may be required within the planning horizon to 2036.

Tweed shire is a beautiful area, one of the highest bio diverse areas in Australia, with internationally significant World Heritage National Parks. This shire deserves the best possible future with truly sustainable developments and the implementation of worlds best practice water management.

Yours Sincerely,  Joanna Gardner……. on behalf of the Save Byrrill Creek Group


The Save Byrrill Creek Group request the Review examine all associated documentation listed below:

Tweed Council Documents

1. Tweeds Integrated Water Cycle Management Strategy 2006

2. IWCM  Status Report Feb 2009

3. IWCM  Status Report Feb 2011

4. Tweed Demand Management Strategy 2009

5.Tweeds Water Augmentation Options

Independent Documentation

1. Brief Technical Review of Tweed Water Supply, Geolink ATTACHMENT 1.

2. Community Working Group on Water Augmentation: Statement March 2010 ATTACHMENT 2

3. Excerpt from “Toward a Water Sensitive Future”: QLD Govt Dept of Environment and Natural Resource Management ATTACHMENT 3

4.Ariel Photo of Cobaki Broad water May 6th 2010 ATTACHMENT 4

5. PDF of Powerpoint presented at Community Access to Council by Joanna Gardner on 3rd March 2011 ATTACHMENT 5


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