Merimbula Sewage Treatment Plant Upgrade and Ocean Outfall

I strongly object to the ocean outfall offshore of Merimbula, For years we have endured the effluent pushed down the coast from Sydney and also the discharge from Merimbula sewage works. We as a nation are concerned with Climate Change and Air Pollution on the people of this planet, yet we happily pour sewage into our oceans. I understand that the waste water to be discharged after treatment from Merimbula will still carry bacteria, viruses and heavy metals into the waters around Merimbula. On this point as a recreational angler do not want to consume any fish containing heavy metals and as a Government, that by law has a Duty of Care to protect the people and their well being should take all stops to prevent this. Also we have a unique position that allows Tourist Operators to take visitors Whale Watching during that season. We also have thousands of Dolphins that frequent these waters and as Mammals are they not at risk of contracting harmful bacteria's or viruses or indeed ingesting heavy metals and long term have disastrous affect on those populations and heavy metals have associated with Whales Beach Stranding's. As I readthrough the Reports I noted in most risk assessments that they were classified as "Minimal, Moderate or High" I could NOT find the description NO RISK. So the report its self expects risk which in it self is unacceptable as there are alternatives to this proposed Ocean outfall

Why are we still so backward and continue to pour our shit, literally, into the environment and then deal with consequences for years later. Surely in one of the driest continents on Earth we can value the precious water more. And don't get me started on the valuable nutrients that could be recovered and used as natural fertiliser and reduce the chemicals we are now being force fed though agricultural practices.

I support the Merimbula Sewage Treatment Plant Upgrade and Ocean Outfall.
Great work, now get on with it before the costs explode

I've grown up on the Far South Coast of NSW as an active member of the community.
I frequently spend my time in the beautiful Pambula-Merimbula Bay as a Surfer, Ocean Swimmer, Recreational Fisher, Sea Kayaker, Surf Life Saving Club member, and Surfing Instructor for Coastlife Adventures.
I've noticed during the warmer months of the year a disgusting algae can form in the bay. Often with the summer NE trade winds, this algae gets blown into my home beach - Pambula Beach. Tourists from all over NSW, come to spend their holidays at our stunning beaches. When the algae is present in the water, it's disgusting to spend time in. Tourists, locals, and I find it unpleasant, and gross.
I believe it's a result of the release of wastewater into the Pambula-Merimbula Bay.

I care deeply about the health of our ocean, the community, the tourists I take surfing, the marine life I'm lucky enough to interact with (and sometimes harvest for dinner) and would LOVE to see the Bega Valley Shire Council build a shorter pipe, use the funds saved to upgrade the wastewater treatment plant to Tertiary Standard, and actively pursue the reuse of treated effluent.
Thankyou for your time.
Kind regards,
Toby

Merimbula Sewage Treatment Plant Upgrade and Ocean Outfall  SSI-7614   EXH-
26691965 
I wish to lodge a submission against the proposed upgrade.
As a local community member who has been following this issue closely for a number of years, I have severe reservations regarding this project.
BVSC has said they "are 100% committed to water reuse". However , they continue to ignore requests from local farmers to meet and discuss reuse options.
BVSC were given contact details of farmers who are committed to taking %100 of treated effluent from Merimbula STP.
BVSC employees attended a meeting with farmers, farm consultants and EPA in December 2020, but have consistently made excuses re any follow up.
I suspect BVSC attended the meeting so BVSC could tick the 'community consultation' box on the EIS.
Alternatives such as inland pumping have consistently been dismissed as "unviable", despite examples other NSW and Victorian LGA's achieving %100 reuse on land.
I find BVSC attitude to water reuse short sighted in the extreme.
As a ratepayer I do not want to leave this outdated 1960's style solution to a 2020 issue to future generations.

Main points:
 The outfall pipeline needs to be as short as possible to allow for discharge if and
when needed. Length to be considerably shorter than the proposed 3.5 km
pipeline.
 Reasons for a shorter pipeline of approximately 200m – 500m are to use funds
towards an increase in recycling, provide our farmers with valuable wastewater
and to keep microplastics and pollutants out of our marine environment. (AECOM
5.0 Conclusions dot point 4 page 16 of 39. Appendix A Dilution Required Calculations and
Water Quality Assessment)
 DISPERSION: In comparing the existing beach face outfall with location 1, seems to be little
difference in the dispersion to warrant the $30+ M expenditure of a 3.5km pipeline.
(figures 26 & 27 AECOM Merimbula Sewage Treatment Plant Upgrade and Ocean Outfall
Appendix Q – Dispersion Modelling Report D – 5) A shorter outfall than location 1 will also
have similar dispersions while satisfying the need for discharge at a substantial saving of
funds.
 TREATMENT AND DISCHARGE: Additional treatment as stated by AECOM (Merimbula
STP Upgrade and Ocean Outfall Appendix P – Climate Change Risk and Adaptation
Assessment Technical Report Page i) begs the question, why do we need to waste funding
on such a long pipeline if treatment is increased when a shorter pipeline would suffice?
 CLIMATE CHANGE: Given the latest information on increasing drought scenarios, this
wastewater should be harnessed at 100% levels for every year possible. Farmers willing to
take more than this STP produces have made contact with the EPA and BVSC ( December
2020). Very irresponsible to throw this valuable resource away when we have the means to
add value to our local economy, environment and social welfare with this one resource.
 DROUGHT IMPACT: “Drought is likely to impact on operation of the STP through
changes to inflow resulting from water restrictions and reductions in groundwater
infiltration (through lowering of the water table), as well as an increase in
dust/particulate infiltration into the STP screens. From a positive perspective, increased
incidence of drought would support the increased re-use of treated wastewater,
minimising the need to use the diffuser and ocean outfall for discharge.”(4.3.5. AECOM
Appendix P Climate Change Risk and Adaptation Report) SWAMP urges BVSC and AECOM
to reconsider the expensive 3.5km pipeline and opt for a considerably shorter version.
Yours for the circular economy,
Russell Jennings

To spend $40m on sending a valuable resource to further pollute the ocean instead of returning it to the ever dehydrating land is a complete waste that doesn’t make sense.

Merimbula Sewage Treatment Plant Upgrade and Ocean Outfall
SSI-7614 EXH-26691965
I wish to provide my submission against the sewerage treatment plant upgrade. I have been following this development closely for many years now and have had real concerns about what is being proposed.
Australia is the driest continent on earth and this proposal is wasting good treated effluent when it could be much better reused on the land. The Bega Valley Shire Council has said they "are 100% committed to water reuse". Hmmm well this so does not apply to what is being said here and to ignore requests from local farmers to meet and discuss reuse options is so wrong on so many levels.
Alternatives such as inland pumping have consistently been dismissed as "unviable", despite examples other NSW and Victorian LGA's achieving %100 reuse on land. I am appalled by the lack of vision and future thinking of the Bega Valley Shire in this regard
I find BVSC attitude to water reuse short sighted in the extreme. Given the latest information on increasing drought scenarios, the BVS commitment to declaring a Climate emergency, this wastewater should be reused on land. Farmers willing to take more than this STP produces have made contact with the EPA and BVSC ( December 2020). It is irresponsible to throw this valuable resource away when we have the means to add value to our local economy, environment and social welfare with this one resource.
As a ratepayer I expect the current council to choose reuse on land as the option to choose moving forward so that future generations do not have to deal with this archaic system that they are proposing..
Main points:
# • The outfall pipeline needs to be as short as possible to allow for discharge if and
when needed. Length to be considerably shorter than the proposed 3.5 km
pipeline.
• Reasons for a shorter pipeline of approximately 200m – 500m are to use funds
towards an increase in recycling, provide our farmers with valuable wastewater
and to keep microplastics and pollutants out of our marine environment. (AECOM
5.0 Conclusions dot point 4 page 16 of 39. Appendix A Dilution Required Calculations and
Water Quality Assessment)
• DISPERSION: In comparing the existing beach face outfall with location 1, seems to be little
difference in the dispersion to warrant the $30+ M expenditure of a 3.5km pipeline.
(figures 26 & 27 AECOM Merimbula Sewage Treatment Plant Upgrade and Ocean Outfall
Appendix Q – Dispersion Modelling Report D – 5) A shorter outfall than location 1 will also
have similar dispersions while satisfying the need for discharge at a substantial saving of
funds.
• TREATMENT AND DISCHARGE: Additional treatment as stated by AECOM (Merimbula
STP Upgrade and Ocean Outfall Appendix P – Climate Change Risk and Adaptation
Assessment Technical Report Page i) begs the question, why do we need to waste funding
on such a long pipeline if treatment is increased when a shorter pipeline would suffice?
• CLIMATE CHANGE: Given the latest information on increasing drought scenarios, this
wastewater should be harnessed at 100% levels for every year possible. Farmers willing to
take more than this STP produces have made contact with the EPA and BVSC ( December
2020). Very irresponsible to throw this valuable resource away when we have the means to
add value to our local economy, environment and social welfare with this one resource.
• DROUGHT IMPACT: “Drought is likely to impact on operation of the STP through
changes to inflow resulting from water restrictions and reductions in groundwater
infiltration (through lowering of the water table), as well as an increase in
dust/particulate infiltration into the STP screens. From a positive perspective, increased
incidence of drought would support the increased re-use of treated wastewater,
minimising the need to use the diffuser and ocean outfall for discharge.”(4.3.5. AECOM
Appendix P Climate Change Risk and Adaptation Report) SWAMP urges BVSC and AECOM
to reconsider the expensive 3.5km pipeline and opt for a considerably shorter version.
Yours for the circular economy,
Wendy Wait
Resident of Pambula Beach
Social Justice Advocate – Environmental Convenor

I strongly object to this project as the research done to support it is out of date, and the process for community input was disjointed and also out of date. Technologies have changed since this project was first investigated, as has our climate. To waste water of any kind when farmers are willing to reuse it is a misguided and irresponsible action by government. With less spent on this pipeline, and the use of solar power to pump it to where it is needed, this water no longer needs to be wasted and our oceans remain free of potential risk.

Annually 1350 gigalitres of water is discharged into the Australian aquatic environment. That is nearly 3 Sydney Harbour's worth of (hopefully treated) waste water. There are currently 181 ocean outfalls around Australia.
This is 2021!!!
We can do better, instead of building more outfall pipes, we should be reducing them and not waste precious water.
Every drop needs to be saved to counteract Climate Change, droughts, sea level rise and fires.

For that much money we can achieve far more by upgrading water treatment to a higher standard where it can be reused on land for farming and firefighting (with a backup pipe like the existing one in case of emergency flooding that won't cost $40 million)

If Melbourne is able to run their waste water through filtration beds, growing green vegetables… our shire can as well.

Building a new outfall pipe would also warm and pollute our oceans, which would be disastrous for ocean life and microbiology because of toxins which are hard to remove like Fluoride, Medication, phosphorus and pesticides.
Our whale watching industry = tourism plus aquaculture industries e.g. oysters rely on clean water!
Surfers don’t like to swim with turds and in a chemical cocktails either.
Please reconsider this new outfall pipe and find a better use for $40 million dollars.

I have lived in the area for over 20 years and have not objected to proposals previously but feel that this is an extremely important issue and warrants comments on my part. In this day and age I am amazed that $35 million is being spent to dispose of water that could be utilized at great benefit to the area. Such a valuable resource should not be wasted but used to maximum benefit. Particularly in light of climate change and the terrible cost of droughts and fires. I well remember the effect of the most recent drought on the area. Other regions have used their water much more efficiently and have reaped substantial benefits, we need to make the most of this opportunity to do something positive and constructive for this beautiful area and it’s future. Please reconsider the decision which seems so archaic.

Dear Reader,
I am objecting to the current proposal titled "Merimbula sewerage treatment plant upgrade and ocean outfall"
The project description is described as
1. upgrade to the STP
2. Decommissioning of the beach face outfall
3. Decommissioning the two exfiltration ponds
4. Support the increase in reuse
5. Build a ocean outfall pipe of up to 3.7 km in length away from sensitive areas
6. Continuation of the current on land practices
In addressing the proposal I would like to make the observation as to the vast disparity in resources offered up by a large public organization (Bega Valley Shire council) to support a position determined in 2011 over 10 years ago, compared to that available to a private individual. A situation exacerbated by the failure of the council to adequately consult with the local stakeholders including ratepayers. Examples include :,
a. Dismissal of the original stakeholder focus group after dissenting with council approach to consultation and no subsequent general focus group established.
b. In the 10 years of the project no direct communication to Ratepayers ( for instance notifications attached to rate notices) given the high proportion of non resident ratepayers ( >10 percent based on proportion of private rental properties) this appears inappropriate.
c. In the last 12 months no face to face consultation was offered to residents within the shire. A phone survey was conducted however again this did not involve non resident ratepayers and though the published outcomes identified subgroups namely ratepayers and residents (both collectively ratepayers and non ratepayers) it neither identified that some of the people phoned would be tourists, no non resident ratepayer contacted and the sample size ( from memory 500) is to small to provide statistically relevant statements for these subgroups.
In relation to the submission
1. I fully support the upgrade of the STP and would like to make the following points
a. EPA and environmental guidelines are becoming more stringent as we pay closer attention to how our activities impact on the environment. The current upgrade is required irrespective of disposal method. However the degree of treatment profoundly effects acceptable disposal methods. For example if treated to portable standard then an ocean outfall may not be required at all as the water can be drunk. Current treatment ( now considered substandard) allows land use even in its current form this could be expanded. However council has not to date engaged with any of the entities that have offered land use ( see SWAMP submission)
b. The council has not in the 10 years of this process considered other disposal methods given upgraded treatment. This include.s increasing awareness of the impact of ocean discharge, microplastics and working examples on reuse elsewhere in Australia including biomass and artificial wetlands.
c. The council itself is promoting circular closed loop development yet the use of an ocean outfall is an example of the opposite
2.Decommisioning of the beach face outfall
I support this however I would make the observation that the council provides scant detail as to the current legal, environmental, cultural and community impact of the present arrangement. Within its own documentation. the assertion that it contributes to algae bloom is antidotal. One might also suggest given higher waste treatment a shorter less expensive pipe may be acceptable to all concerned parties including the EPA.
3.Decommisioning the exfiltration ponds. These ponds are simply 2 shallow holes in the ground from historical extraction they appear as rural dams ( photos not attached as you only accept PDF files) there is no intact infrastructure other than the discharge and inflow pipes. I support the decommissioning of the ponds in their current derelict condition. However it would be perfectly feasible to establish and artificial wetland in this strip of degraded coastal bushland. Alternatively the land could be used in a similar fashion to both the golf course or Oaklands for dispersal. On this topic the observation of local dieback is only "local" in the sense that the condition and dieback of vegetation is found all the way from Pambula to Merimbula ( photo could not be uploaded) was not surveyed and may or may not be due to too little water as too much. The presence of Phosphates nitrogen and no pathogen could in the former be because of operational practice and neglect the later due to the efficiency of soil and its microbes to destroy pathogens ( E Coli). Something that is not a subject but pertinent to the council proposal. As to the indigenous concern re the presence of these ponds I would note their equal concern for the marine environment ( see current Yuin native title claim which includes 5km to sea).
4. I support reuse and in support I would draw you attention to the considerable interests by local entities both public and private in obtaining the treated effluent even offering financial assistance in developing the pipe network and funding their own storage facilities. Such facility development is supported by NSW grants in relation to Fire prevention, fighting and drought proofing commercial broad acreage farms. At this time despite these parties providing their details to council ,council has not responded.
5. I don't support the ocean outfall pipe. In answer to my letter advising council of my opposition I received a generic letter that compared the STP without an ocean outfall pipe too a bath without an overflow. I don't hesitate to point out that baths are not required to have a plumped overflow. I presume the manufacturers and government regulators assume the owner to be sufficiently responsible enough to ensure the bath is not filled beyond its capacity. Secondly any accidental overflow is immediately observed and corrected to avoid damage to the bathroom. This is would not be the case with an out of sight submerged ocean outflow pipe approximately 2.5 km offshore.
6. I support the continuation of current land dispersal practices and suggest they can be expanded at a significantly lower cost than that associated with building the ocean outfall pipe. Estimated price of which has risen 40 % since inception and is currently estimated at 30million dollars (Not including STP upgrade). This expense is by a shire council area with the highest rates ( top 25% rates) and lowest medium income ( lowest 25% income) for the state ( per NSW local government compared site). We also have at last count >9 active SRV ( special rate variations). For example my residential property rates are 3500 dollars per annum, My sister's residential property in the Bass shire council is $1800. Though the initial capital works may be funded by state government ongoing cost including cost blowouts are not ( Merimbula airport upgrade cost blowout approximately 1/2 million dollars from council funds.) This council by its own admission and 2020 audit shows a significant deficit" Council has faced trenchant criticism from some quarters of the community due to its most recent audited financial statements showing a net consolidated deficit of $8.92 million and a net operating deficit of $14.092 million for the 2018-2019 financial year( source Bega district news.)

In summary I object to elements of ( as outlined above) this proposal on the following grounds
1. No science data is provided for the last 5 years, nor has recent advances in treatment and management including practical examples been investigated by council> proposal short sighted and flawed.
2. the council did not from inception allow a full range of options be considered including the possibility of improved treatment, greater land use and a shorter pipe or wetlands development.> failure to investigate all options and comparative costs
3. Though the initial estimated cost in full "might" be forthcoming from other entities the on going cost and and blowouts will be the responsibility of council and therefore ratepayers. Neither the affluence of the council or it constituents justify this belief. The council should not be allowed to burden the rate payers with another SVR or rate hike to support the cost associated with this project in its current form.> financially irresponsible
4. Spending 30million dollars to build an ocean outfall which the council hopes and anticipates to be little used compared to an onland distribution network that will be increasingly used is without sense or logic.> not cost effective or logical when forward thought.
5. Lack of consultation and clarity with no continuum of focus group or local community representative, inadequate information to non resident ratepayers, statistically invalid phone survey.
6. The data on dye dispersal to date do not demonstrate that the proposal protects Merimbula lake, Pambula river or beach amenity.> misinformation to community
7. Scant data on the composition of current outflow and projected outflow following STP upgrade or the impact this may have on the options for disposal.
8. No effort by council to engage the stakeholders interested in supporting land use > prejudicial too proposal and outcomes.
9. No data on microplastics and in there submission the appearance of considering ocean dispersal to be "less sensitive" than land> inappropriate judgement of capacity and value of the resource (land compared to ocean) by the community.
10. Hijacked and misuse of indigenous input, including the current native land claim by the Yuin people that includes the ocean.>mis-appropriation of support
11. Insufficient analysis of waste dispersal patterns and impact on the close artificial reef and fish breeding, Merimbula lake and Pambula river. > insufficient scientific leading insufficiently or suspect assertions as to the benefits of the proposal.

Yours Sincerely
Robert Geary

I object in part, to the project

We object to some parts of this project

Dear Sir/Madame,
I am opposed to the building of a deep ocean outfall in Merimbula Bay. I believe the proposal is ill conceived, outdated and short sighted.

This proposal was not given due process in the beginning. Experts were only consulted after the decision to build an outfall was made. We need to start over with a 10 year water management plan, with environmental engineers consulted at the beginning of the proposal to properly consider all options for the future.
In the context of 2021 this proposal is outdated. Water is a valuable resource. We should be treating our effluent thoroughly and aiming to recycle 100% if it. The impacts of climate change have arrived and experience has shown our region that we need to secure all available water. It does not make sense to pump this valuable resource into the bay and risk upsetting the marine environment, when we desperately need water on land. The marine environment here is pristine and at the centre of our community's economic security. People live and visit here for the clean and natural environment.

My parents built a home on Long Point Merimbula Bay in 1975. The council quotes unidentified old locals as saying algal bloom is a natural event. I'm sure it is at times. However, also confirmed on the council website is the fact that nutrient rich effluent causes algal bloom. At the end of summer, after effluent has been pumped into Merimbula bay for weeks, algae blooms. The north east wind blows it into the beach and lake and we finish summer with algae in our ears. Many old locals will attest to this.
The studies done on marine currents would need to be redone. Since that time we have had the Black Summer fires, very big changes in the shape of the Merimbula Bar and the entrance to the lake and an artificial reef put into Merimbula bay. This meant at times last year, boats were unable to get in and out of the lake. I believe that the sand dune restoration is an important initiative but the water attached to it is just as important.
This is significant infrastructure. I do not think it makes sense to spend +$35 million of council funds, on a secondary option or something we "use as a backup". Let's use that money towards a primary solution. Let's treat effluent throughly, reuse the water, spend money pumping it to a constructed wetlands or other designated areas. We have so much thirsty land around us.
I grew up in Merimbula, I am 50 years old. Many families here have lived off the grid with their own septic tanks, solar power and rainwater tanks. The council has great ideas with FOGO, sand dune restoration and the sewage treatment feeding the golf course all these years. This decision is so vital to get right.
The decision made in 2009 is not relevant in 2021. Ocean outfall's are an outdated concept and I have lived through the problems attached to them in the Eastern Suburbs of Sydney.
I returned to Merimbula 14 years ago to raise my 3 daughters. We live on Long Point overlooking Merimbula Bay. It is an incredible, world class, destination that deserves to be protected and preserved.
Please reconsider this proposal.

In summary, the MBGLAC believes that the EIS and works that have lead to the current proposed solution are incomplete and fail to embrace both responsible conservation practices and opportunities whilst also imposing an unnecessary heightened risk to the marine environment. Detail response to issues are contained in the attached detail response.

I do not support the proposal in its current form. There is a definite need to utilise the waste solids and treated water from the Merimbula sewage treatment plant. In a time of major climate change resulting in the need to recycle water to a dairy industry so important to the circular economy of our valley, it is inappropriate to waste this precious resource by disposing of the water into the ocean. Lets revisit this proposal to utilise this resource in a more productive way. The ocean outfall is yesterday's solution to disposal of sewage effluent and treated water. Lets follow the lead of others in our region as outlined in my attached submission.
Many thanks for the opportunity to make comment.

While I support the objectives of the proposed project, we cannot continue to discharge wastewater from the beach outfall. I do object to the proposal of a 2.7km deep ocean outfall discharging valuable water given the evidence of current information informing us of climate change: increased incidence of drought, rising sea levels, extreme weather patterns, fossil fuel impacts and higher incidents of bushfires.
Consideration of alternatives.
The EIS considers a number of alternatives to the project with regards to the disposal of wastewater generated by the STP. These alternatives were developed in 2009 and are now outdated. A key viable alternative was presented to the EPA and the BVSC on the 1st December 2020 in the form of a face to face meeting of 20 people including two farmers and their agricultural consultants. These farmers are prepared and able to take the entirety of wastewater generated by the STP. This particular farm has a storage dam of 380ML to offset the volume of wastewater in high rainfall events. Both farmers have offered to finance the construction of another 380ML storage dam. The Shoalhaven REMS scheme has been in operation for 19 years and directs water to 14 dairy farmers in the North Shoalhaven region. The Scibus report (attached) estimates the annual return from the investment to the farmers and community, averaged for 2017-2019 is $A11.3million. BVSC should be following their lead in supporting our farmers with this ‘waste’ product.
The Pambula and Merimbula Golf Course had applied in 2020 to construct a 250ML wastewater storage dam for irrigation and to cater for wet weather events. Both of these feasible alternatives were not considered in the EIS.
I support the full beneficial re-use of wastewater generated by the STP.
I note that the Minister can approve an application for State Significant Infrastructure subject to such modifications as the Minister may determine (EPA Act, s.5.19(3)). If the Minister is minded to approve the project, I would ask the Minister to do so subject to modifications that require the full beneficial re-use of the wastewater to avoid the expensive ocean outfall component of the proposed SSI.
Melinda Pavey - Minister for Water, Property and Housing.
See attached Media Release September 2021: Ms Pavey states, “We’ll also look for opportunities to invest in research and development, and new technologies, including recycled water opportunities for industrial and agricultural uses.” The EIS has not looked at any such uses.

Beneficial re-use schemes.
The Benefits of irrigation by wastewater are documented in the ‘Use of effluent by irrigation’ Department of Environment and Conservation (NSW). We have the opportunity now with our STP upgrade to harness this valuable resource and reap a range of benefits. See attachment Scibus. Bega Cheese is our largest employer and without an increase in recycled water, Bega Cheese runs the risk of moving to Victoria. We cannot afford to lose this industry in our valley.

Justification of the project.
The EIS justifies the implementation of the project in the manner proposed by comparing it to the status quo. The status quo is clearly unacceptable but at the same time, it sets a very low benchmark. The community deserves better than the current situation however, the proposal is not the best alternative on the table. I support alternatives which are underpinned by the circular economy principles of re-use and recycle rather than the linear model of use and discard.

Consultation
SWAMP, a local community group has invested time and energy over the past 3 years in advocating for a more sustainable solution to the $40M+ proposed outfall. In particular, in consultation with Janine Goodwin and Nigel Sargent ( both from the EPA NSW,) organised a meeting with the BVSC and relevant stakeholders. Industries represented included: fishers, surfers, tourism, farming and ratepayers while statements from the following industries were presented: retail, recreation, business and hospitality. This vital session of community consultation was not inclueded in the EIS.

Recommendations.
• Approve the upgrade component of the STP as described in the State Significant Infrastructure application. BETTER TREATMENT.
• Severely shorten the ocean outfall component of the SSI application and thereby saving a considerable amount of funding which could fund recycling and pipes.
• Modify the SSI application so that the wastewater generated by the STP is fully and beneficially re-used on local farms and the golf course.
• Harness solar energy to help offset running costs.
• Adhere to Melinda Pavey’s ‘INNOVATION AT HEART OF NSW WATER STRATEGY’ attached.
• Agree to more wet weather storage holding dams.
Thanking you, Marianne Kambouridis 8 Correa Close Millingandi 2549 NSW

I have been the local Rural Financial Counsellor for over 10 years and also been operating my own farm in the Bega Valley for approx. 16 years. During this time, I have personally experienced the impacts of a devastating Drought and Bushfire, but also seen the impacts (both financial and personal) these have had on almost all farmers in the Bega Valley.
In view of the above any opportunity to gain greater access to water (especially reliable wastewater which would be pumped out to sea) would significantly improve the long-term sustainability and resilience of farmers (who are able to access this water) in the Bega Valley.
There are several potential benefits this additional water would bring to the agriculture sector in the valley:
• Increase sustainability and resilience of the Agriculture industry in the Bega Valley and mitigate the impacts of drought and bushfires
• Enable increased on farm feed production (reducing the requirement for brought in feed at a higher cost) and increase off farm employment due to the use of contractors. Many dairy farmers in the Bega valley incurred annual feed bills more than $500,000- pa during the recent drought, this type of reliable water supply would reduce this bill by at least 50%.
• The additional water especially in the dairy sector would help increase employment both on farm (due to growth in dairy herd) in the Bega Valley
• Help sector secure and grow the milk supply within the Bega Valley and ensuring ongoing supply to a key manufacturer Bega Cheese
• Support the long-term viability of the dairy industry in the Bega Valley and key manufacturer being Bega Cheese
• It is also felt that based on current cattle prices, the beef industry in the Valley would also be very interested in gaining access to this water to increase productivity and provide greater resilience and sustainability.
I fully support any sustainable water reuse options that have the potential to provide substantial economic and environmental benefits for the Agricultural industry in the Bega Valley.

Please see the attached submission.

The proposal to discharge effluent into Merimbula Bay is a risk to marine ecology as detailed in AECOM assessments.
The diffuser point is still within Merimbula bay such that disposed effluent will still be dispersed within Bay Area.
Note that the option of a longer pipe and dispersal into oceanic waters further out, which had the LESSER ENVIRONMENTAL RISK, was not the chosen dispersal option chosen by BVSC.
Discharge will still contain pollutants such as pathogens micro plastics and heavy metals and these can be damaging to marine life and marine ecosystems around Merimbula and Haycock headlands.Such pollutants can cause stress in abalone and cause perkinsus olsenii outbreaks capable of killing abalone stocks as has occurred near outfalls around Sydney and north to Port Stephens and south to Jervis bay.
Any loss of abalone stocks would reduce the sustainability and viability of the valuable fishery in southern NSW.
The EIS does not address compensation if this were to occur which contradicts the relevant Acts providing compensation for loss of public resources such as abalone sea urchins and valuable commercial species that inhabit the environs of Merimbula Bay.
Catch data from this area was available to AECOM as mentioned in EIS however this is not acknowledged in terms of losses from pollutants contained within the partially treated effluent.
TREATMENT
AANSW acknowledges the improvements to treatment as per the details within the EIS however these are minimal.
This level of treatment is not sufficient to minimise contaminants AS LISTED ABOVE from disposed effluent.
Treatment will not facilitate greater reuse such as on farmland parks etc so the treatment upgrade is NOT SUPPORTED at this level.
TREATMENT should be to an A+ standard being a far safer level for disposal and offers up more re-use options.
ALTERNATE RE-USE OPTIONS
Although covered within consultation process dating back 10 years the advancements in power and recycling options that have been greatly improved over the last ten years have not seriously been considered let alone costed.
BVSC has relied on data and reports that are at least ten years behind current options.
In short, options for other uses have not been considered ion enough detail in the EIS and instead Merimbula Bay discharge will mean these options will never be considered and the polluting option of discharge into the ocean will continue, along with associated risks.
MERIMBULA OUTFALL is contrary to Government policy on NSW water strategy, announced by the Minister for Water,Melinda Pavey,in a Media release dated 16th September 2021:designed to"deliver resilient and sustainable water resources.."
...underpinned by cutting edge climate modelling..."

...'opportunities to invest in research and development"

The EIS does not consider the future planning within NSW (as summarised in media release) and locks the BVSC in to a long term unsustainable outfall option.

The Abalone Association of NSW is the peak industry body for the NSW abalone and the NSW Sea UrchinT urban Shell (SUTS) Fisheries.These fisheries support over 100 participants as well as many employed on the south coast within the transport and processing sector.
AANSW would support inland re-use,a higher grade of treatment with only a short ocean pipe to allow for times when reuse is not available such as during wet weather.