Merimbula Sewage Treatment Plant Upgrade and Ocean Outfall

I object to this project.
The proposed treatment upgrade is minimal and will not remove pollutants including pathogens, micro plastics and heavy metals.
These pose an ongoing risk to marine flora and fauna described in the marine assessments attached to EIS.
A higher standard of treatment to remove these pollutants would be far less a risk to marine life and would expand re-use options for BVSC.
Higher grade treatment will allow more agricultural use which, at proposed level will continue the necessity to dump effluent rather than reuse.
Re-use options other than those proposed during the Community Consultation period 2010 have not been updated or considered.
The decision for an ocean outfall is based on out of date data/material and ignored technology advances that can significantly improve viability of alternate uses for high grade treated sewage.
BVSC have failed to consider alternative re-use options available and incorporated NOW into many regional councils effluent re-use programmes.
Earlier options were ruled out, not re-costed or updated.
The effluent disposal point is not the least risk averse.
Of the four disposal points the one further to sea carried the least risk of effluent being carried back into bay.
The chosen dispersal point by BVSC still carries risk to marine ecosystems and biodiversity, and while it may be considered a better option than the beach face outfall it is still not far enough out from the Bay area to prevent effluent dispersal of polluted material into Merimbula Bay.
In summary my objections are based on :
1.Insufficient upgrade to treatment
2.Pollutants being dispersed into Merimbula Bay that can impact marine flora and fauna
3.No up to date assessment of alternate re-use options

I wish to object to BVSC's proposal because it is outdated due to lack of water conservation. We should be getting a better water purification plant then pumping this water to Lochiel for farmers to use it and store it in case of fires or drought instead of having to cart water as we recently had to do!!! This would be cheaper than polluting the ocean as is currently the case. We need this water and in a flood any excess could just run down the creek/river systems if it had been cleaned 1st. Other Shires manage to do this!!!

The BVSC has recently become a member of the Circular Economy Management Committee to steer this visionary policy initiative by Bega Cheese, for the regeneration, recycling, reusing and repairing and restoring the natural environment for the wider Bega Valley.
This project to dump sewerage waste into the sea off Merimbula, via an ocean outfall pipe, is completely contradictory and will undermine this BVSC policy. We need to develop and fund a longterm solution, to create a healthy, sustainable environment.

I acknowledge the need to improved treated effluent discharge from the Merimbula wastewater treatment plant for both environmental and public health protection.

However, by ruling out any major new water recycling projects on cost/technical grounds, the EIS and upgrade project has missed a great opportunity to boost the sustainability and farming sector of the Sapphire coast region.

I helped develop the Shoalhaven Water water recycling project (REMS), which also arose from an ocean outfall proposal. The REMS project/concept had considerable support from community and stakeholders. The addition of a water recycling system/network increased the cost of the project by around 30%, a sum which the community indicated they would be willing to pay for via a modest increase in sewerage rates.

The REMS project was able to meet environmental objectives, follow community preferences and provided an enormous boost to the dairy farming sector in the Shoalhaven. A recent study (SCIBUS, 2020) found that the water recycling project generated nearly $11m per annum in additional regional income and an increase in around 80 full-time jobs when compared to the case of not having the project. The benefit-cost ratio for the water recycling project was estimated be around 2.5:1.
By putting substantial new water recycling options in the too hard/too expensive basket, the Merimbula upgrade project misses a major opportunity to support the local farming sector and the flow-on benefits to the regional economy.

Wet weather storage and pumping costs are indeed factors in transferring treated effluent to sites further from the treatment plant. However, I understand there were options put forward to utilise existing farm storages which would reduce public infrastructure costs and also allow for more cost-effective pumping/transfer options to be considered.

I would urge BVSC to take a more practical and wholistic long-term view of its wastewater management.

Yours sincerely

Walter Moore
Moore Environmental & Community Consulting
P: 0409 810 375
E: [email protected]

The Mayor
Russell Fitzpatrick


Dear Russell


As a Ratepayer and Resident of Merimbula I was concerned withe the approval to proceed with the Outfalls into Merimbula Bay particularly since the Bushfires which followed many years of drought, our need for water to green our pastures and fight fires has become even more critical. A lot has changed in this area since mid 2019.

Our need to keep our oceans in pristine condition is imperative to protect our main industry TOURISM. Should our oceans be contaminated in anyway all our recreational activities become compromised.

Knowing other Shires have approached this issue in other successful ways - even though they had the option to use the ocean but decided to do what was best for the environment.

I understand that they feel the outfalls will seldom be used - even more reason not to spend $40 plus million, when it could be spent on a method that would benefit continually,

I did try and put through a Submission on the Webpage they suggested but despite lots of approaches I was unable to do so.


Yours faithfully


Maureen Penrose

The Mayor
Russell Kilpartick

Proposed Ocean Outfalls - Merimbula Bay

Dear Russell

I have been a Resident and Ratepayer of Merimbula for over 50 years and raised our family in this beautiful part of the BVSC some of who still live and work here.I am deeply concerned regarding the necessity and cost of this Ocean Outfall which has been researched for over 10 years and has now caused so much controversy in the Merimbula, Pambula Community. The available data explains much of the detail required to construct this 2.7 klms Outfall but the unknown behaviour patterns of the Oceans have been treated lightly.The risk and consequence chart over a 100 years lifespan of the Outfall is full of supposition and leaves many elements unexplained. This Outfall will permit huge volume of treated waste water to be WASTED and the possibility of entry into our local estuaries and lakes, all of which is unnecessary. An alternative to the Outfall is readily available if BVSC is willing to investigate further options and should not involve a further 10 years of wasted research, There are many Towns in NSW who have successfully processed their sewerage without Ocean Outfalls being considered. As a suggestion - the Council could identify and construct a main pipeline corridor West to South West of the Merimbula STP supported by branch lines to various farms, crown land holdings etc. Solar powered pump stations, release and save storage tanks for wet and dry situations could all be included.

I have experienced difficulty in submitting this material and kindly request that you submit on my behalf.


Thanking you

Yours sincerely
John Penrose

I wish to lodge a submission against the proposed upgrade.
• I have been visiting Merimbula regularly for over 60 years. It has always been, and remains an extraordinarily special, beautiful and healing place. Nature is its wealth. The local economy depends upon fishing and tourism. So any proposal to pump sewerage into the bay represents an unacceptable risk to the environment and the very industries the local economy depends upon.
• Please treat the effluent to the highest tertiary standard possible, put in place a high quality exfiltration system, and pipe it to the farmers in the surrounding areas. The summer of 2019/2020 demonstrated all too graphically why the treated wastewater would not have been wasted on farms.
• If you really must have an outfall pipeline, then the effluent still needs to be treated to the highest tertiary standard, and then the pipe can be as short as possible to allow for discharge if and when needed. The proposed 3.5 km pipeline should not be implemented. The cost savings can be better spent with benefits to the environment and local industries.
• I encourage the BVSC to take the opportunity to demonstrate leadership in this area and not make a determination that reflects outdated thinking and may be detrimental to the entire South Coast.
• In making this decision, please consider what Merimbula's future will be if you destroy the very assets its economy relies upon.

In addition I support the points made by SWAMP below:
• 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.

I live in Millingandi with my wife Marianne who has been working hard as President of SWAMP to enlighten our council of the benefits of recycling treated wastewater. The proposed $40M outfall is an outdated solution to wastewater management. We can do so much better as Melinda Pavey states in her recent media release 16th September 2021. We need to become leaders in water innovation and efficiency. Investment in harvesting and reusing wastewater will provide many benefits for our community and for our environment. With increasing drought and less rainfall predicted, we simply cannot afford to throw this resource into our over polluted ocean. The money spent on the 2.7km pipeline can be put to better use by providing a 500m pipeline for discharge in extreme rainfall while the remainder of the funding can go towards solar pumps for sending this water to our farmers in the Bega Valley and to Bega Cheese one of our biggest employers.
SWAMP introduce the Cochrane farmers to the EPA and to BVSC who agreed that higher reuse is a great idea. This evidence of third party who have invested in three generations of farmers should have been part of the EIS as part of the community consultation process but it was not. The information used to draft this EIS was from 2009. We now have the black summer fires to use as our learning. Not to waste water. We can do better.

I/we wish to lodge a submission against the proposed upgrade.
I am opposed to the proposed upgrade.
I am no water/waste expert but I would prefer the council set up a long-term solution to recycling all the waste water in the shire instead of pumping it into our oceans. I know this is expensive but many other councils are doing it around the world and given our previous history of drought and climate change bringing with it the added threat of more droughts, this money would be well used, for our farmers, producers, gardeners, tourism, flora and fauna and for our oceans. Please let’s choose a long-term solution that factors in climate change and its upcoming dangers. And let’s protect our natural beauty in the process. There are so many possibilities with water use and reuse if we do invest in a proper long-term recycling centre, and we could become leaders in innovative technology, climate action and circular economies. If this position is not possible I have borrowed a friend’s main points below that seem to be a fitting compromise.
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.

I wish to lodge a submission against the proposed upgrade to the Merimbula Sewage Treatment Plant & building of new deep ocean outfall.
SSI - 7614 EXH - 26691965

After hearing about much investigation about alternative solutions by SWAMP group members, and these people bringing huge amounts of research about other solutions to the Bega Valley Shire Council (BVSC) I am very strongly opposed to the current project going ahead as is. And I am convinced that there are much better solutions available that benefit the local community, much more than to simply spend a large amount of money, simply to waste this precious resource.

Minister for Water, Property and Housing, Melinda Pavey, recently released a new 'NSW Water Strategy' blueprint, focusing on innovation, new technology, long term water management, efficiency, research and development including a focus on recycled water opportunities for industrial and agricultural uses.
With the government's promise under this strategy, to invest in supply options, including stormwater harvest and water re-use.

This strategy is an excellent vision and promise, and it is clear that the BVSC's current approach is not fitting in to this vision.

The current STP upgrade & deep ocean outfall project was conceived many years ago, prior to the current knowledge we have about how microplastics effect marine animals. In that time also, many wonderful new technologies have also been developed for sewage treatment.

It has been apparent all along, since I became aware of this project, that most people in the local community were completely unaware of it, even despite the council's box being ticked of including community consultation. SWAMP organised a petition, which is where I learned about this proposed project, and I assisted with the circluation of this petition. During that time it became clear to me, that no-one had even heard of this project, several years in to it's development, and we gathered a very high number of signatures of local people who could see that surely, we ought to be re-using this resource, not wasting it.

The BVSC does have, as part of it's targets with this project, a plan to increase re-use, however, on attending meetings with AECOM and BVSC members, it was made clear that the amount of increased water recycling that was going to be able to occur was going to be very minimal. I don't see how that is an acceptable outcome.

One of the main reasons that the re-use was not going to be increased by a great deal, was that the options were limited as to where this water could safely be re-used. This is why I object to the project going forward, as is. I would like to see the money being spent on improving the treatment of the sewage to a very high standard, preferably to potable levels, which would mean that anywhere the water is expelled (some in to the ocean, some on to land) the pollution is minimal. This would greatly increase the options of where this water was safe to be used and allow for versatile re-use options.

SWAMP group members have brought numerous viable solutions to BVSC including a farmer with a massive dam capacity that can currently take 50% of the annual water that is expelled in to the ocean, and they are willing to build another dam, of equal capacity that could see one site able to receive 100% of currently wasted water.

The group also found a company who was willing to have Merimbula Sewage Plant as a pilot project for their new technology that would treat the sewage to a high level, and fit the bill for incorporating new innovations and technologies in to the future directions for environmental care and water resource protection and management.

There are also options to incorporate things like solar powered pumps to enable the water to be directed on land rather that out to sea. Seeing as the BVSC's main reason that they have decided the ocean outfall was the most viable solution, was the difficulties faced with the topography of this region. However, yet again, the research done by SWAMP members, has shown that it would in fact be possible to pump the water inland.

All of the above solutions in fact, add up to a much lower expense than the current proposed plan.

Further points for my submission are as follows.

The outfall pipe can be made much shorter than whatever length options are currently being looked at.

Reason for shorter pipeline (approx 200 - 500m) is that the funds could be put to better use toward increasing recycling, providing farmers with valuable water & keeping microplastics and pollutants out of the already stressed marine environment. (AECOM 5.0 conclusions dot point 4, page 16 of 39. Appendix A Dilution required calculations & 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 Million plus expenditure for a 3.5km pipleline. (Figures 26 & 27 AECOM Merimbula Sewage Treatment Plant Upgrade & Ocean Outfall Appendix Q - Dispersion modelling report D-5)
a shorter outfall than location 1 will also have similar dispersions while satisfying the need to discharge, but at a substantial savings of funds.

TREATMENT & DISCHARGE: Additional treatment, as stated by AECOM (Merimbula STP Uprage & Ocean Outfall Appendix P - Climate Change Risk & Adaptation Assessment Technical Report page i) begs the question why we need to waste funding for such a long pipeline if treatment is increased, where a shorter pipeline would suffice?

CLIMATE CHANGE: Given latest information on increased drought scenarios, this wastewater should be harnessed at 100% levels for every year possible. As mentioned above, farmers willing to take more than this STP produces, have made contact with the EPA and BVSC in December 2020.
It is very irresponsible to simply waste this valuable resource when we could use it as a way to add value to our local economy and environment.

Along with agricultural uses, these massive dams available on the farmland I have mentioned, are also big enough that they could potentially be another location for firefighting helicopters to access water for bombing fires. Given the recent massive bushfire events across Australia, including locally, having another location convenient for helicopters to access water, when time and distance covered are essential in stopping bushfires from spreading, would be another much needed avenue for the water to be available for.
I don't know if you have experienced bushfire threat, but it is an extremely scary event, taking people years to recover from, both in rebuilding and psychological/emotional recovery. Many people in the Bega Valley, are still not going well. Partly because the future threat is still there, and climate change predictions are telling us that drought and bushfires of much more extreme severity and danger are likely to be more a part of life. Surely having more water as a highly valued resource could be of benefit in so many ways.

DROUGHT IMPACT: "Drought is likely to impact operation of the STP through changes to inflow, resulting from water restrictions & reductions in groundwater infiltration (through lowering 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 & ocean outfall discharge." (4.3.5. AECOM Appendix P Climate Change Risk & Adaptation Report)
SWAMP urges BVSC and AECOM to reconsider the expensive deep ocean outfall pipeline & opt for a considerably shorter version.

For all the reasons above. I urge those making decisions regarding this matter to please, not allow the project to go ahead in it's current form. There is significant research available, that has been done for free, by SWAMP members, passionate locals who care deeply about our region, that could be utilised by BVSC.

I urge you to listen to us, and I am speaking on behalf of the many people I personally encountered who think it is ridiculous to spend money, merely to throw away a precious resource. In this day & age, with all we know about climate change, our experience of drought and bushfire, our growing knowledge about polluting the ocean, it seems seriously below par to accept this project as it stands.

My name is Maree Hawkins an I reside at Millingandi NSW Greenpoint Road.

My property adjoins the Pambula Merimbula golf club where the existing treatment works are situated.

I am born in Pambula an feel very strongly about our pristine beaches, and the future generations ability to be able to experience the continuation of such.

I support upgrading the treatment work, but not for the extended outfall option.

I wish to express my thoughts on the Merimbula outfall project please.

I have previously lodged a submission but have not received a reply yet.

I do not agree with the outfall proposal, as also stated in Written submission at the Pambula town hall meeting several years ago.

I however support the ideas for inland diversion to outlying farms in pambula, & nearby.

As Barry Moffat presently utilises this water piped to Oaklands property, It would be cost beneficial to extend to Mr Whitby’s farm.
I wish to also comment on the fact, the EIS has not included the Wolumla Area farmers in the consideration of redistribution & redirection of wastewater.

Please note farmers have offered to finance the construction of holding dams & pipework to utilise this waste effluent.


The utilisation of this water for reuse in farming practices is Environmentally sustainable, without the damages incurred pumping the treatment waste into the ocean.

The north coast has successfully managed to complete these projects with water distribution inland.

I mention,
that previous submissions by Pambula-Merimbula golf club to increase holding dams an treatment capacity was also
not accepted.


I therefore, urge the council an those involved to think very carefully in the considerations of the sewerage risk management.

I wish to express my thoughts on the Merimbula outfall project please.

I have previously lodged a submission but have not received a reply yet.

I do not agree with the outfall proposal, as also stated in Written submission at the Pambula town hall meeting several years ago.

I however support the ideas for inland diversion to outlying farms in pambula, & nearby.

As Barry Moffat presently utilises this water piped to Oaklands property, It would be cost beneficial to extend to Mr Whitby’s farm.

The utilisation of this water for reuse in farming practices is Environmentally sustainable, without the damages incurred pumping the treatment waste into the ocean.

The north coast has successfully managed to complete these projects with water distribution inland.
I therefore, urge the council an those involved to think very carefully in the considerations of the sewerage risk management.

Thankyou

Sincerely

Maree Hawkins
Pambula

Thank you for the opportunity to provide comment on the Merimbula STP Upgrade and Ocean Outfall project EIS report.

The EIS report is comprehensive and successfully describes the potential environmental (natural, cultural and social values) impacts of the proposal, and outlines the mitigation and management measures to address these impacts.

Comments from a NPWS perspective as follows:

Marine and coastal processes
- NPWS requests ongoing consultation with the development of the CEMP in relation to establishing and using beach access for construction
- NPWS supports the proposed tertiary sewerage treatment option, noting the report falls short of fully committing to this treatment method. The STP upgrade should include tertiary treatment so as to minimise impact to the marine and coastal environment.

Terrestrial ecology
B1
- NPWS requests ongoing consultation with the development of the CEMP in relation to flora and fauna management plan.
- ‘undertaking pre-construction targeted surveys at the Pambula Beach construction access proposed, to ensure the affected areas are not being used by threatened shorebirds’ – noting there is no mitigation measure described to manage the presence of shorebirds if they are detected in the activity area.

B2
- As above re shorebirds
- ‘pre-construction targeted surveys should be undertaken prior to the decommissioning of the STP effluent pond to ensure the pond is not being used by threatened amphibians and particularly the Green and Golden Bell Frog’. Noting there is no mitigation measure described to manage the presence of threatened amphibians if they are detected in the STP pond.
B3
- As above re shorebirds
B4 -B11
- NPWS requests ongoing consultation with the development of the CEMP in relation to flora and fauna management plan.

Landform, geology and soils
- NPWS requests ongoing consultation with the development of the CEMP. Specific area of concern is spills mitigation management in activity area, including access routes e.g. Pambula Beach, Jiguma Beach (Ben Boyd NP), Merimbula Beach; and the marine construction area.

Traffic and transport
T4
- NPWS requests ongoing consultation with the development of the CTMP.
- Specific concern is pedestrian safety along Pambula/Jiguma Beach during construction. High tides and sea surge can significantly reduce available beach to allow shared pedestrian and construction vehicle access. The CTMP will need to satisfactorily address this risk.

Social and economic
SE3
- Continued pedestrian along Pambula beach, Jiguma and Merimbula beaches is supported. Pedestrians along the section of Jiguma beach along the eastern boundary of Ben Boyd NP are effectively Park visitors.
- NPWS requests continued consultation on any potential impacts to park visitor access along Pambula/Jiguma beach. NPWS will also inform the public through its own channels – e.g. public website notifications.

Thank you for referring SSI 7614 to Port Authority for comment and to provide advice on recommended conditions.

We note that the project is located outside of port limits (Port of Eden). However, the proposal makes reference to potentially transporting equipment and materials, including pipe lengths, via the Port of Eden using barges and tugs, and the potential for the delivery of construction materials and equipment in containers to the Port of Eden. Whilst not specified, it is expected that these activities would occur at the Port Authority owned facility in Snug Cove (Eden Cruise Wharf).

Port Authority therefore requests:
• the proponent be required to consult with Port Authority and the Harbour Master for any proposed use of the Port of Eden and of Port Authority owned facilities; and
• that any post approval management plans that include works out of, or use of, the Port of Eden and/or Port Authority owned facilities are prepared in consultation with the Harbour Master.

Thank you for your email below requesting feedback from the Civil Aviation Safety Authority (CASA) on an Environmental Impact Statement (EIS) for the Merimbula Sewage Treatment Plant Upgrade and Ocean Outfall Project, SSI-7614 refers.

CASA has reviewed the information provided and notes that most of the Sewage Treatment Plant site is under the Merimbula Airport Obstacle Limitation Surface (OLS) known as the Transitional Surface, which increases in height towards the south east away from the extended runway centre line. At the beach, the height of the OLS, known as the Inner Horizontal Surface, is RL 46m.

CASA recommends that construction cranes or high construction equipment used at the site be referred to Merimbula Airport for assessment.

During construction, the emission of airborne particulate may impair the visual conditions and aircraft systems. CASA notes there is dust mitigations at EIS Table 22-5 and Appendix N Table 8-1 Mitigation and management measures – Air quality.

During construction, Bird and animal attractors should be avoided, and the design of the facility should minimise bird attractors. Consideration should be given to storing waste in closed containers, avoiding the use of trees and shrubs attractive to birds and bats, avoiding bird perching opportunities, and the dispersal of wildlife by the removal of food or the use of spikes, wire, or nets. Guidance for managing bird and animal activity is provided in National Airports Safeguarding Framework (NASF) Guideline C: Managing the Risk of Wildlife Strikes in the Vicinity of Airports and CASA Advisory Circular 139-26 (0) Wildlife Hazard Management at Aerodromes.

Certain lights may cause confusion, distraction or glare to pilots in the air. Ground lights may cause confusion or distraction by reason of their colour, position, pattern or intensity of light emission above the horizontal plane. For example; flashing lights are sometimes used to indicate system failures. Further guidance is provided in NASF Guideline E Managing the Risk of Distractions to Pilots from Lighting in the Vicinity of Airports. Note the four light control zones: A, B, C and D. It is expected that most of the Sewage Treatment Plant site would be in zone A; requiring zero light measured at 3° above the horizontal.

The design of permanent facilities at the sewage treatment plant should consider the possibility of a future runway extension. CASA recommends that Merimbula Airport be consulted regarding any impact on a future runway extension.

Thanks you for consulting with the regional office on the proposal. The regional office does not oppose the Merimbula Sewage Treatment Plant Upgrade and Ocean Outfall Project and has no comments/advice on the proposal.