Rhett Duncan - Unitywater Topic : MCU21/0110 - Noosa Springs Hotel

Okay. Good morning. Unitywater is the water and wastewater service provider for the Noosa region. My name is Rhett Duncan. In my role as executive manager, customer delivery, the operation and maintenance of our network is my responsibility. So thank you for the opportunity to speak here today. After ensuring the protection of public health and the natural environment our most important priority is enabling economic development that allows communities to thrive. I'm here today to convey our very clear and very strong position that we do not support this development in its proposed location. To be clear we are not opposed to growth in the new growth at Noosa Springs just the proposed location which is too close to the existing Noosa sewage treatment plant. I'll explain our position and what we're asking this committee and Council to do. Sewage treatment is an essential community service that has been lawfully carried out on the site under Council operation since the mid 1970s. The STP was fully upgraded in 1997 and transferred to Unitywater on the 1st of July 2010. The STP operates under a Department of Environment and sciences environmental approval and to meet all of its licensed conditions. The 1995 environmental impact statement commissioned by Noosa Council notes in section 3.10 buffer area. Substantial buffer precincts exist around the existing and proposed STP. Nearest housing is more than 400 metres to the north of the existing STP northern boundary. The STP will be augmented to the south of the existing facility, increasing the buffer from the centre of the proposed STP augmentation by approximately 300 metres. The proposed Noosa Springs development, 400 metres to the west and south-west of the proposed STP, is protected against noise, odour and visual impacts by the intervening ridgeline. There's some key points to note in that EIS. Council made a conscious decision to shift the plant a further 300 metres to the south, away from sensitive receptors, then 400 metres to the north. Key odour generating sources are located to the south west of the STP site in order to maximise the distance from these sensitive receptors and the 1997 STP was designed with consideration to this 400 metre buffer land to the then proposed Noosa Springs development. This proposed development now sees sensitive receptors located approximately 200 metres from the STP, significantly closer than the 400 metres considered in the design of the current STP. The development encroaches up the ridgeline noted in the 1995 EIS as providing protection and this development knowing places sensitive receptors within the 2.5 odour unit contour line. Council's actions and decisions in the EIS were appropriate and in keeping with the principles outlined in part E of the current state planning policy, which still seeks to protect STPs from encroachment by incompatible development. Therefore, approving the proposed development is not only in conflict with council's own earlier decisions to minimise the potential impact of the nearby land uses, but also in conflict with the intent of the State planning policy. It's true to note there have been few complaints about odour from the post-1997 upgraded STP, firstly, and this is a result of two Unitywater deliberately operating the plant in ways that aim to minimise odour events and therefore impacts on our neighbours. And of course, geography and the buffer zones. So while we operate the plant to minimise odour, there to what we can do. The STP comprises of mechanical equipment that can fail over time or can have power supply interrupted because of weather or electricity network events. We should also note the catchment volumes are increasing, meaning that while we are within licence limits, the plant is treating more sewage today than when it was built and the original buffer lands were contemplated. And while it's true the oasis community of permanent residents is located approximately 300 metres to the west of the STP, this community is afforded some shelter from the ridgeline running north-south between these properties and the STP. The Noosa Springs development shifts development north along the ridgeline, reducing this available protection. Unitywater note proposal that the resort manages odour complaints internally, but we know this is not how it works in practice. The Department of Environment and sciences is the regulator in this space and regardless of any good intent from the proponent, responsibility cannot be transferred. Unitywater note the reference to the 2.5 odour unit limit, however DES do not take this into account when investigating odour complaints and issuing enforcement action. In fact, the application of general environmental duty, environmental harm nuisance is and very open under the Environmental Protection Act 1994. So this means that odour complaints made to the regulator will be investigated and could result in action against Unitywater that may lead to prosecution and costly plant modifications. And for reference, Unitywater installed odour control equipment at the Murrumba Downs treatment plant in 2010 as a result of urban encroachment and the cost of that was $38 million in 2010. It's also our view that this outcome is more likely to happen as a result of the proposed approval condition 13 that would see all guests being advised of the potential odour from the sewage treatment plant. Actively drawing attention to a potential odour source will drive guest perception of odour and trigger an automatic assumption that any perceived odour relates to the STP Unitywater source will drive guest perception of odour and trigger STPs as catchments grow to ensure ongoing, compliant sewage treatment. Upgrades at the treatment plant will change the odour contours used in the modelling. A future DA application by Unitywater will need to consider sensitive receptors. Only 200 metres from the STP as a result of this proposed development. And again, I refer back to the Murrumba Downs treatment plant example where odour control equipment cost $38 million in 2010. In closing, while we support cost $38 million development, in 2010. So in closing, while we support development that promotes sustainable economic growth, we do not support this development in its proposed location because it locates new sensitive receptors closer to the existing treatment operations. Proposed the development would impose reverse amenity obligations on Unitywater that cannot be transferred and could unnecessarily cost Unitywater customers tens of millions of dollars and limit our ability to meet future growth in the region. It is our view that approving this proposed development would be at odds with the 1995 EIS and the current state planning policies the conditions proposed to be applied in an approval with good intent actually further increase risk to Unitywater and our customers and this risk could be avoided if the proposed development is not approved in its currently proposed location in the first place so Unitywater are asking this committee and Noosa Council to not approve the development in this location and in thinking about this scenario we can't help but wonder about a reverse situation would a new sewage treatment plant be approved 200 metres from existing luxury accommodation with significant facilities.