Robyn Campbell
Hydrosphere Consulting
robyn.campbell@hydrosphere.com.au
SUBMISSION: Tweed Integrated Water Cycle Management Review (IWCM) Paper
Byrrill Creek Landcare Group thanks you for the opportunity to be involved in the process of helping to formulate the future IWCM Strategy.
As a landcare group, who have been revegetating riparian areas in the upper Tweed catchment, our priority is in maintaining healthy water ways, and pursuing sustainable solutions to water management. We consider the proposed dam at Byrrill Creek not an option due to the environmental destruction to the highest priority riparian conservation area in the Tweed. As coordinator of the Landcare group, and as a member of the CWG committee who examined Tweeds Water Augmentation options, below are comments on points that you have highlighted in your background paper.
Administration & Governance
- 1. IWCM principles, responsibilities and priorities are not fully implemented across all Council units –
The current IWCM Strategy follows a traditional IWCM approach and Council will struggle to identify, assess and implement integrated water management solutions if the various departments keep working in isolation, as they have been doing. What is to be recommended to address this issue as this is a priority?- 2. There is a need for informed and transparent decision-making and better management of community expectations – as well as effective communication with the community in order for rate payers to have faith in the decision-making process. Council needs to provide leadership and justification for its decisions based on the best available information;
As far as effective communication, may I point out that as a member of the CWG committee, the CWG members and the community have requested since 2009, that there be an Independent Review to assess and re-examine figures within the Demand Management Strategy and to evaluate more sustainable choices for Water Augmentation. To date this has not been commissioned. We hope that this Review addresses these issues.
In 2010 the choice by previous councillors to pursue a dam at Byrrill Creek dam was neither informed nor transparent decision making, nor was there any justification for their decision in the face of recommendations by Water Staff, scientific evaluations of the ecological value of the area, and the prohibition of the dam within the Tweed Water Sharing Plan in December 2010.
More recently the Water Wise workshops, put on by Northern Rivers Guardians and the Caldera Environment Centre in June and August this year, who provided Independent & nationally known Water Experts on options for reuse of water, were very poorly attended by Tweed Council staff and councillors, One of the main reasons for these workshops was to open the Councils Staff & Councillors eyes to other established best practise, innovative urban water options . No Staff attended the 2nd Workshop, and the first one was poorly attended by Councillors.
If council is really examining the “best available information” they missed a golden opportunity from experts such as Dr Andrzej Listowski, the Manager and creator of Water and Energy of SOPA, Sydney Olympic Park, Amanda Otto from the Pimpama/Coomera Projec, and engineers, Craig Zerk & Duncan Thomson from Geolink, who presented information on Orange Councils stormwater harvesting, Ballina council’s recycled water plans and new innovative stormwater & rainwater bulk capture in two Brisbane urban developments.
The NRG & CEC”s committee members request for a Council follow up meeting on how some of these ideas could be implemented in new developments was squashed by David Oxenham, Dept of Community & Natural Resources, who replied “Council and the proponent for Cobaki and Kings Forest have already agreed to a raft of WSUD principles” An outline of these principles have not been received to date.
It is little wonder that residents have little faith in Council decision making processes, nor community consultation.
- 3. A need for defendable & Robust population Forecasts
The accuracy of the Demand Management Strategy is questionable & needs a reassessment by an Independent Consultant :
DMS figures, graphs, calculations and resulting conclusions by MWH needs close examination by an Independent Review. This specifically includes
An independent evaluation of population growth forecasts as well as water consumption rate is needed as soon as possible as the debate on Tweeds Water Issues rests on accurate figures for both population and water use. ID Consulting , has provided revised population forecasts which have lowered population estimates in the DMS for 2031: 143,488 residents(DMS): to 128,135 residents(ID Consulting):This equates 10.7% reduction in population. With reduced population & steadily falling water consumption a later time frame for water augmentation will be achieved, which has been acknowledged in Issue 13.
The supply of water could to be seen as an ultimate limit to population growth. Intertwined with this is Tweed Shire’s sustainable population carrying capacity, such as the destruction of landscape values and species loss that need to be factored into the ability of the land to support a human population. The current attitude is growth at all costs, not what our beautiful biodiverse landscape can actually support., Feedback during the Tweed community strategic plan indicated population growth was a major concern to residents.
- 4. Uncertainty regarding the preferred Tweed district water supply augmentation optionThe CWG committee, Geolinks Review and the community all questioned why the shortened list of 3 options, when combinations of options was possible, sustainable reuse solutions were possible, but the only real choices put on the table by council were the dam options.
We consider that the Council Water staff have not built a convincing business case for either Dam option without considering an adequate reduction in Tweed Shire’s demand for water including reuse especially in new Greenfield areas.
General Evaluation
There is an urgent need for Integrated Water Solutions to Tweeds Water Management that are outlined in the aims and objectives throughout the IWCM srategy 2006 which state the necessity for Integrated solutions: Water Sensitive Urban Design(WSUD): Stormwater detention/capture, reducing nutrient discharge into rivers & estuaries, encouraging Environmentally Sensitive Development, reuse of water and dual reticulation in new developments. Environmental Sensitive design has not been applied in any of the approved Developments in the last 12 years eg Salt, Casurina, Sea Breeze
At present this concept of Integrated Design is not being implemented by Council Staff. A new attitude and emphasis on WSUD and ESD for new developments is a priority by both Planning & Water Department Staff
How will this be rectified?..by employing new staff who are open to innovations?
Urban Wastewater Management
19. Recycled Water in New Developments
1) “With the current Council direction and policy relating to recycled water use, the initiative to implement recycling is left to the developer which provides little incentive for recycling. Approved designs are based on traditional engineering solutions rather than integrated concepts and opportunities for wastewater recycling and demand management are not being realised. Nonetheless, future planning and assessment of recycled water schemes must weigh up the high cost to the community.”
2)“For those developments that are proceeding without the requirement for dual reticulation, there is limited opportunity for Council to review its previous decision regarding dual reticulation “
3)“Council has a target for 15% of treated effluent to reused by 2013, however, this target is not likely to be met, with between 5% and 9% of wastewater currently being recycled.”
It is obvious from the above excerpts from your background paper that the Council is unwilling to move forward or rethink decisions made.
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” Council Minutes Page 11 Item 24 Feb 15 2011: IWCM Strategy:
I ask what developer would propose it? It is up to the Council to propose, negotiate payment and ensure implementation!
2) Comment :Kings Forest & Cobaki are the largest Greenfield developments and alone account for a population increase of approx 25,000. As both Kings Forest and Cobaki (except for the first 900 lots at Cobaki) have not gone through the DA Approval yet it is therefore not too late to implement dual reticulation.
We support recommendations by Geolink “ If there is a possibility that recycled water may be supplied to a subdivision that is currently going through the design and approval process, it would be prudent to require the design of the subdivision to include dual reticulation. If the provision of recycled water to the subdivision is still undecided at the time of subdivision construction, key portions of the dual reticulation infrastructure (e.g. pipelines that run underneath roads) should be installed because it will be much cheaper than retrofitting at a later date.”
At the very least, Council should lay dual reticulation pipes at Cobaki & Kings Forest even if there is still no definite decision at present, to allow this option in the future.
This would pave the way for the other future seven developments identified in your paper by Forecast ID.
An Independent benefit-cost assessment needs to be undertaken for all water management options, specifically proritising a new Cost Analysis of Recycled Water for New Urban developments which should be commissioned immediately.
1)“Nonetheless, future planning and assessment of recycled water schemes must weigh up the high cost to the community”,
Council has repeatedly proclaimed that Dual Reticulation is too expensive to consider.
We ask how can the community weigh up the costs when No definitive figures have been provided by Council to show the cost??
Any costing so far has been based on MWH DMS figures. I have phoned the Council about specific costings for recycled water, and just been fobbed off “that its too expensive an option”, Councillor Katie Milne has repeatedly requested this information on numerous occasions as well, to no avail.
Caculations obtained from the DMS Stage1 pge 72 Table 5-30 indicate that the cost of dual reticulation would be $38.5M for the 5 major Greenfields. If this cost is divided by the expected residents
$38,500,000
÷ 34,000 major Greenfield residents (from DMS)*
= $1,131 per Greenfield resident is the resulting figure, which is quite a reasonable & feasible amount
DMS Stage 1 p.72 table 5-30
Total Costs:
Scenario 3 Total cost NPV
Dual Reticulation + Rainwater tanks +
Demand Management $ 120,783,041
Less
Scenario 1 Total NVP
Rainwater tanks + Demand Management $ 82,232,106
Total Cost of Dual reticulation $ 38,450,935
A proper benefit-cost assessment needs to be undertaken for all water management options. This cost analysis should include comparative costs to the environment: ie discharge of effluent to our estuaries, stormwater runoff and the environmental destruction involved in the construction of a new dam or enlarging our current dam
Costing should be split between Developer and Council and negotiated as part of the Development Approval.
Ballina Council’s new Recycled Water Plant could be a good comparative basis to start from.
Urban Wastewater Management
17.The opportunities for development (urban expansion) outside of the wastewater service areas is limited by the capacity of Council’s infrastructure and the environment Estuary managementplanning in the Tweed has identified issues relating to the impacts of wastewater discharges and urbanrunoff and the nutrient assimilation capacity of the waterways.
At present 7.5GL of effluent is discharged into Tweed creeks & estuaries every year with less than 5% being reused
- The (International Water Centre – 2009) EHMP Health Report Card provided a health report, which states “To keep the chlorophyll-a concentration low enough to ensure a healthy functioning ecosystem, it is necessary to reduce total catchmentdissolved inorganic nitrogen(DIN) loads by approximately 30% in both the Terranora and Cobaki Broadwater catchments.”
- “In both the Terranora and Cobaki Broadwater catchments the greatest percentage increase in pollutants found between the existing position and post development (unmitigated) is likely to be from Cobaki Lakes with 237% increase in TSS, 231% increase in TP and 270% increase in Total Nitrogen (TN)”
- “The health of the system is currently impacted by the recycling of nutrients from sediments and nutrients from STP (Banora Point WWTP) effluent tidally moving upstream to the broadwaters”
Reduction in discharges to sensitive receiving environments such as the Cobaki and Terranora catchments, should make Reuse schemes more attractive, as discharges to receiving waterways are of a concern. A recycled water plant at Banora Point WWTP to service new growth areas with dual reticulation should have been a priority.
Urban Stormwater Management:
Issues 21,22 and 23
Issue 21, 22, 23 illustrates the need for Council to a new integrated approach in urban design to reduce discharge in our waterways, stricter regulation for subdivision earth works and enforcing those regulations.
For many years the Tweed Community has been lodging complaints about stormwater pollution from the Cobaki development earthworks draining into sensitive SEPP 14 Wetlands/Cobaki Broadwater, without any remedy by Council. Kings
Forest will impact on the Cudgen Creek and Lake areas. Strict enforced regulations may help the situation.
Stormwater runoff could be integrated with Storm water capture ponds or wetlands for reuse, at the same time providing recreational open space with gardens and lakes, rather than run off into our rivers.
Every year, Sydney Olympic Park Authority is collecting, storing, treating and reusing approximately 700 million litres of stormwater, providing and enhancing fauna and flora habitat areas of the 425ha of the Parklands and irrigating the urban areas of Sydney Olympic Park.
Geolinks Review: “The use of stormwater as an alternative source of recycled water is certainly feasible and could be cost effective in locations with suitable topography. Stormwater requires treatment before it is suitable for
use as recycled water. However, stormwater runoff from new subdivisions within the Shire will receive a
substantial portion of the required treatment by default, in order to meet Council’s stormwater quality
management requirements. The additional treatment required to enable the stormwater to be used as recycled
water is likely to include filtration and disinfection.”
Staff Interviews
“Stormwater recycling at the community level is not considered beneficial due to the large amount of
rainfall, large land area required for storage and infrastructure costs. RWTs at the house level are
considered to be most appropriate”.
Comment: The high rainfall in the Tweed means that community-scale stormwater recycling may well be viable in some instances, depending on topography.
Dr Andrzej Listowski, designer of the Sydney Olympic Park, viewed the Cobaki site and felt it was an excellent site for artificial wetlands, storm water capture and reuse.
“Design of Council roads and stormwater systems does not usually incorporate WSUD due to space
restrictions. Swales are being replaced with kerb and gutter systems to reduce maintenance and
end-of pipe solutions are included. More guidelines on WSUD and less emphasis on traditional
end-of-pipe solutions are required.”
Comment: At Pimpama/Coomera the swales and artificial wetlands were designed in from the very beginning of the development. Council Planners need to use WSUD principles at the concept stage of planning, be it a development, road, or car park & to allow physical space for it to implemented properly
Administration & Governance; Further comments
- 6. Asset Management Planning
The major investment (and debt) of $75 million dollars in the new Bray Park Water Treatment Plant, distanced from the growing Tweed coastal population, indicates that a long time ago the decision was made to augment water supply either from Clarrie Hall Dam or Byrrill Creek Dam. A Cynic may question.. Does Council really want new developments that are water self sufficient, such as recycled water & large capacity rain water tanks, rather than buy their own water?
Banora Point STP, at a cost of $36 million, has recently been upgraded. It close to high growth areas and new Developments, and could have easily been built with the extra filtration processes to produce recycled water for dual reticulation… Another lack of foresight or the Cynics question?
The costs of the distant Water Treatment Plant, together with its questionable over capacity, seem to have now reduced the Council’s capacity to utilise other urbanised water supply reuse options.
8. High energy consumption and greenhouse gas emissions
There is a considerable cost of energy to process the annual production of Tweed potable water at the Bray Park Water Treatment Plant and then transport it to the Tweed Shire’s distant urban water users.
Planet Footprint reports that “ Council’s water and wastewater infrastructure consumed 12,349 MWh of energy and 13,200 tonnes CO2 equivalents in 2011/12. All energy was supplied from non-renewable sources.”
Additional energy costs are also accrued to treat approximately 8726 ML of reclaimed water and then dump it into the already nutrient rich Tweed River. Only 4.8 % of this reclaimed water is reused.
Note that one of the reasons for the decision not to implement dual reticulation at Cobaki by the NSW Joint Regional Planning Panel was high energy consumption & emissions, which is ludicrous when comparing an on site recyle facility to all the pumping required for external STP and potable water needs
If Council is planning to seriously reduce its footprint of energy consumption and greenhouse emissions, then either Dam option would be out of the equation… construction uses vast amounts of energy, and for a new dam methane emissions are high due to rotting vegetation in the early inundation process.
Urban Town Water Supply
11.There is currently no mechanism to promote retrofit of rain water tanks or installation of large rainwater tanks in new development.
Our group supports a council incentive scheme to install tanks much larger than required by BASIX or toretrofit existing properties
A minimum capacity 10,000lt tank should be mandated in DA Approvals, as in SE QLD (5,000lt), not a voluntary agreement/recommendation as proposed by Tweed Council.
Rebates such as those provided in SE QLD and by Rous Water, Lismore/Ballina should be considered to promote water savings. When rainwater tanks were installed in 236, 000 homes in SEQ as part of the Queensland Government’s Water-Wise Rebate Scheme; Tweed Shire Council only installed 117 tanks. The SE QLD tank fit-out represented a take up of almost one in four detached and semi-detached dwellings.
However, if it is a choice between either tanks or recycled water, rather than both being implemented together, we would choose implementing Recycled dual reticulation in new developments. Tanks can be retro-fitted later to existing dwellings.
13. Augmentation of the Tweed District Water Supply will be required in future due to population growth although the timing and additional supply required are unclear.
Please refer to previous Comments on Point 3 and 4. On the DMS & need for updated , Population & water consumption figures.
An erroneous graph in the DMS illustrated that Water Augmentation would need to be achieved by 2023, and the time frames have now been slid back to the 2030’s. Only 1000ML to 3,000ML extra water is needed by Tweed by 2036. To choose a dam is way out of proportion to expected yields of either dam: upgrade of Clarrie Hall Dam with a capacity of 26,300ML or a new large Byrrill Creek Dam of 36,000ML.To fulfil this small amount with a combination of reuse options is quite feasible
Geolink Review:
If Council was to adequately fund and vigorously pursue the actions specified in the Demand Management Strategy, it is quite possible that no water supply augmentation would be required within the planning horizon to 2036.
Options for Water Supply: Comment
The ultimate choice within the DMS by MWH, and support by Council, of Scenario 1 (BASIX & an inadequate 5000lt tank) for Urban Development shows a lack of foresight into Tweeds future water use & savings, in essence it relies on a centralised dam water supply, either upgrade Clarrie Hall or a new dam at Byrrill Creek.
State Government & Federal Governments Policy on Urban Water Supply all point to diversification in water supply.
Its noted in the IWCM 2006 Page 68 “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 & Natural Resource Management: “To shift away from traditional reliance on rainfall & surface storages as the sole source of supply, to a diverse portfolio of supply sources: a mix of both decentralized & centralized systems”
The choice of a new dam at Byrrill Creek as the main water supply for new developments is not an “integrated solution” Recycled water and runoff harvesting could offset the need to increase the capacity of Clarrie Hall dam
Scenario 3 from the DMS should be adopted: BASIX + Dual reticulation +Tanks, but tank size should be at least 10,000 litres.
14.The drinking water catchments are impacted by current and historical land use and development
Of concern is cattle grazing and associated farming practices, including broad acre herbicide and fertiliser application are occurring within the catchment of the Clarrie Hall Dam. In fact livestock have unrestricted access to the dam which is probably the only water supply reservoir in Australia where this is allowed. Other upstream waterways that ultimately feed into Bray Park weir are also impacted by livestock access. One example is the Council owned land at Byrrill Creek which is unfenced for the agisted cows
Our group supports the specific controls are required to be included in the LEP for drinking water catchments(Page 24)
Byrrill Creek Landcare notes that dividends from council’s water supply and wastewater businesses are used to fund stream bank protection works. (Page 20) As a land care group we consider this should be an ongoing priority, but more emphasis should be placed on revegetation projects & fencing livestock from waterways, rather than broad scale heavy use of herbicides for weed management.
Council needs more power to address and manage agricultural practices that are non-point pollution sources contaminating the urban water supply.
Catchment Management
24. There is a need for a holistic Catchment Management strategy for the Shire
Byrrill Creek Landcare group supports a total catchment approach to water cycle management as the outcome: which integrates urban & rural strategic land use planning and strengthens the linkages between existing catchment management, plans for estuary management and upstream catchment, agricultural management and IWCM programs..
This again will need to be implemented throughout the different departments within in council, to be achievable.
Tweed shire is one of the highest bio diverse areas in Australia, with internationally significant World Heritage National Parks and beautiful waterways. The true costings of the dam options, including environmental damage and loss of biodiversity should be calculated and balanced against the cost of implementing WSUD principals right now.
This shire deserves the best possible future with truly sustainable developments and the implementation of world’s best practice water management.
Yours Sincerely,
Joanna Gardner……. on behalf of the Byrrill Creek Landcare Group
Coordinator
Byrrill Creek Landcare Group
PO Box 3322 Uki NSW 2484
Phone: 02 66797039
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