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1
REPORT ON A PUBLIC CONFERENCE UNDER SECTION 20B OF THE
ENVIRONMENT PROTECTION ACT 1970.
CONFERENCE HELD IN RESPECT OF
THE WORKS APPROVAL APPLICATION RELATING TO
BARWON WATER’S NORTHERN WATER TREATMENT PLANT.
Report prepared by the Chairperson:
Geoff Brown - Tangent Consulting
Section 20B conference venue:
Norlane Neighbourhood House
Rose Ave, Norlane
Date of Section 20B conference:
Thursday 24th June, 2010.
Date of Chairperson’s report:
12th July 2010.
2
Table of contents
1. INTRODUCTION …………………………………………………………………………. 3-4
2. REVIEW OF PUBLIC SUBMISSIONS …………………………………………………. 5
3. PROCESS AGENDA FOR THE SECTION 20B CONFERENCE …………………… 6-7
4. ISSUES RAISED IN CONFERENCE AND THROUGH PUBLIC SUBMISSIONS .. 8
4.1 Concerns raised ………………………………………………………………….. 9-11
4.2 Questions raised …………………………………………………………………. 11-12
4.3 Summary of main topics in public submissions ……………………………. 12
4.4 Points of clarification requested ………………………………………………. 13
4.5 Other requests and resolutions ………………………………………………... 13
4.6 Next steps …………………………………………………………………………. 13
4.7 Participant feedback …………………………………………………………….. 14
5. CHAIRMAN’S CONCLUSIONS AND RECOMMENDATIONS
5.1 Conclusions ………………………………………………………………………….. 15
5.2 Recommendations ………………………………………………………………….. 15-16
ATTACHMENT ONE:
QUESTIONS, ISSUES AND CONCERNS RAISED IN CONFERENCE ………………….. 17-19
ATTACHMENT TWO:
ADDITIONAL PUBLIC SUBMISSIONS ACCEPTED THROUGH
THE 20B CONFERENCE PROCESS …………………………………………………………. 20
3
1. INTRODUCTION
This report contains the community questions, issues and concerns raised at a 20B
Conference (conducted under Section 20B of the Environment Protection Act 1970) in
response to a works approval application by Barwon Water for the proposed Water
Treatment Plant, to be located on industrial land east of Station Street in Corio.
This report has been prepared by Geoff Brown, chairman of the 20B community
conference and staged with 26 participants (including 14 community members) at the
Norlane Neighbourhood House on the evening of Thursday, 24th June 2010.
A wide range of groups were invited including:
Figure 1: List of groups invited to the 20B Conference
Barwon Water states, in it’s Work’s Approval Application (Executive Summary), that the
water treatment plant “will treat a combination of domestic sewage from the catchments
of Corio West and Oyster Cove, and process water (trade waste) from the Shell refinery.
The treatment plant will be located in the Corio area, north of Geelong, next to the
refinery. The refinery currently utilises a significant amount of potable water for its boilers,
which the NWP will substitute to fit for purpose, Class A recycled water, which will
provide an immediate reduction of 2000 ML/a (5 per cent) in Geelong’s drinking water
use.”
4
Barwon Water also states the strategic objectives for the project (2.1 Project Overview):
Barwon Water to:
– meet growth in North Geelong
– balance water supply
– manage wet weather flow to comply with State Environment Protection Policy
(Waters of Victoria) (SEPP)
– meet reclaimed water use targets
Shell to:
– reduce reliance on potable water
– increase treatment of trade waste.”
EPA Victoria accepted the works approval application on 10th May, 2010. EPA received
public submissions from 7 people and one petition signed by 62 people. As with all works
approval applications, an opportunity for further community input was publically
advertised and organised for 24th June 2010.
This 20B conference was designed to capture and further understand the key concerns,
questions and issues raised by participants. The conference also allowed EPA to hear
from other voices in the community who may not have provided a written submission.
The independent chair is appointed to ensure that all parties, particularly those who have
not made their views known before the conference, are heard and communicated in a
report to EPA that includes recommendations on the proceedings.
5
2. REVIEW OF PUBLIC SUBMISSIONS
7 public submissions and 1 petition (signed by 62 people) were received by EPA Victoria
in response to the advertised works approval application. The submissions (with all
identifying information removed) were reviewed by the conference chairman after the 20B
conference was staged. This review provided the chair with an opportunity to compare
the community concerns raised at the conference with those presented in the
submissions.
A few of the main issues raised in the public submissions are incorporated into the review
of the information captured at the 20B conference – sections 4.1 and 4.2.
Note: Appendix 1 provides a detailed account of the feedback provided by
participants during the small group and whole conversations.
6
3. PROCESS AND AGENDA OF THIS 20B CONFERENCE
3.1 Background and context
The 20B Conference was part of the works approval process for the proposed Northern
Water Treatment Plant. The key milestone dates of this process include:
Figure 2: Key milestone dates
3.2 Conference Design
The 20B Conference was designed by Geoff Brown (Chairperson) in consultation with
Clare Marsh of EPA Victoria. The workshop was designed to meet the following goals:
• Participants have equal opportunity to share and discuss their concerns, issues
and questions with each other;
• Participants are able hear and better understand the concerns, issues and
questions of others;
• The key concerns, issues and questions are captured in written form and in the
words of participants.
7
The 20B Conference agenda is summarised in the following table.
Time Agenda
Item
Process Description
5.45 to
6.30pm
Arrivals Participants welcomed
Tea/Coffee
6.30pm Welcome &
Introductions
Participants sitting in a circle of chairs
*Each person introduced self and the group they represented
*Gavan Mathieson (Manager EPA Vic. Geelong Office) provided the
official welcome and outlined the purpose of the 20B Conference.
6.50pm Context
Overview
*Naren Narenthiran then provided brief background of the works
approval process and a snapshot of the main themes to come from the
public submissions.
7.00pm Concerns,
Issues &
Questions -
Group
Discussion
The conference chair then invited participants to form small groups and
discuss the issues, concerns and questions that matter most.
2 conversations with different groups followed. At the conclusion of the
2nd conversation, each group (of 4 or 5 people) then captured as many
of their key issues and questions on separate sheets of paper.
7.55pm Evening Break
& Supper
Conversations continued throughout the break.
8.05pm Concerns,
Issues &
Questions -
Group Analysis
The Conference chair worked with the whole group to draw out each of
the written issues/questions/concerns from the pre-break discussions.
Each topic was taken in turn and posted on a wall. The chairperson
allowed the participant to find the natural groupings and a range of
different themes emerged. The authoring group of each topic was
asked to clarify their contribution.
8.45pm Next Steps
Evaluation
Whole group discussion to consider next steps and decide how we
continue to engage on the unanswered questions and concerns.
9.10pm Close
8
4. ISSUES, CONCERNS & QUESTIONS CAPTURED AT THE 20B CONFERENCE
In facilitating the 20B Conference workshop, the chair used a group process that allowed
all participants to share and discuss concerns, issues and questions. These were
captured in a written format and shared with the whole group. Most of the concerns,
issues and questions were discussed and clarified with the chair.
The participants assisted the chair to group their written responses in to themes.
ATTACHMENT 1 contains a direct transcription of what was written by participants and,
in some cases, additional notes were added (in brackets) by the chair when clarifying their
response. The heading for each group of responses (themes) was created by the Chair
when analysing the outputs after the conference.
This section of the report presents the broad themes that emerged from participants at
the 20B Conference. The section titled ‘20B Issues’ attempts to summarise the key
concerns that were discussed and captured. The section titled ‘In Submissions’ briefly
highlights the commonly identified concerns in the public submissions.
This chart represents a summary of the key concerns and questions raised at the 20B
conference along with the main themes identified by the EPA in public submissions.
Figure 3: Key concerns & questions
9
4.1 Concerns Raised
There were many concerns raised at the 20B conference and in public submissions. Some
of these issues are relevant to the works approval application and some go beyond EPA’s
role. In section 5 (Chairman’s Conclusions and Recommendations) this is discussed
further.
*The number in the (bracket) indicates the number of individual concerns raised at
the 20B Conference that relate to the stated theme.
Access to recycled water (6)
20B Issues
This theme overlaps with ‘Shell’s benefit from the plant’ and featured prominently in both
written feedback and in group conversations. The key concerns raised here related to fair
and equitable access to the plant’s recycled water by industry and community. The
perception at the conference is that Shell will be the sole beneficiary at the expense of
other industry (e.g. MC Herd) and community (e.g. Steadpark).
In Submissions
• The main concern was that Shell is perceived be the sole beneficiary of recycled water
from the plant;
• It was alleged that early in the project the communication indicated that industry and
community would benefit from the recycled water and that it appears Shell will now be
the sole beneficiary;
• A fear that home owners and other water users will be expected to pay higher prices for
the water was also raised.
Shell’s benefit from the plant (5)
20B Issues
In addition to the ‘Access to recycled water’ theme, the perception from many at the
conference was that Shell’s responsibility for dealing with waste is being handed back to
the community through Barwon Water. The other concern related to corporate welfare -
the public funding private industry.
In Submissions
• Similar concerns were raised with a perception that the “business relationship between
Shell and Barwon Water is problematic” and that this project does not equate to good
value for money.
Results from the Pilot Plant (5)
This group of concerns are also linked closely to the questions relating to ‘Design and
Best Practice of the Plant’ in 4.2 below.
20B Issues
The subject of public access to the pilot plant results at Oyster Cover appeared to be
contentious and was the subject of a Resolution later in proceedings. At the core, the
10
community participants were questioning the validity of the pilot plant results and have
concerns that ‘worst case scenarios‘ have not been factored into the design.
In Submissions
• Lack of access to pilot plant results was also identified in many of the submissions.
Barwon Water’s community engagement processes (4)
20B Issues
The key concern appeared to relate to differences between the initial planning permit
application (to City of Greater Geelong) and the current works approval application.
Participants felt that these changes in ‘scope’ of the project had not been communicated
effectively during the consultation process.
There was also a perception that the works approval application had already been
approved when participants attended a Barwon Water community forum in March, 2010.
In Submissions
• The same concerns were raised with examples provided such as, “notably an open
storage lagoon is contained in the planning permit application”.
The Works Approval process (4)
20B Issues
Like in the public submissions, the core perception is that this works approval application
is not in accordance with the principles in the Environment Protection Act 1970. The
accountability of the project was raised as a concern regarding the overall costs,
environmental factors and a lack of balance between Shell’s needs and community
needs.
In Submissions
• Again, the perception is that the works approval application fails to conform to the
intent of principles contained within the Environment Protection Act 1970. These
principles are listed in detail within many of the submissions.
Ownership of the Land at the site of the plant (3)
20B Issues
The core concern related to public infrastructure should be located on public land and not
private land.
In Submissions
• Of further concern was the possibility that Shell’s funding component may be
withdrawn if a new owner is found for the Shell site.
Contamination (3)
20B Issues
The first issue here relates to the existing contaminated soil and groundwater at the
proposed site and questions were raised about how that will be managed.
11
The second is a concern is about heavy metals and other contaminants in the industrial
wastewater from Shell that will be treated by the proposed treatment plant.
A third issue discussed here and in submissions related to commitment that Shell cease
it’s discharge of water into Corio Bay.
In Submissions
• It was felt that the works approval application lacked information about soil and ground
water contamination;
• Concerns that in the recycling of Shell’s waste, there is a lack of information about how
heavy metals are to be handled.
4.2 Questions Raised
In addition to broader concerns, more specific issues were raised and questions asked
that relate to the detail of the works approval application and the plant design and
location.
Odour, Noise and Flood Risk (7)
20B Issues
The key concern here related to the possible odour and air emissions from the uncovered
Lagoons. This also relates to personal health concerns in the local community,
particularly in relation to storm and flooding events. A recommendation was made by 1
group to tackle this issue:
• “EPA to address odour concerns raised by residents by EPA being involved in the
development of a Neighbourhood Environment Improvement Plan (NEIP).”
In Submissions
• There was a concern that the works approval application lacked research into the
impacts of possible sea level rise;
• Concerns that the health of local community will be affected negatively and the
information provided in the design does not go far enough.
Questions about design and ‘best practice’ of the proposal (5)
20B Issues
The key question from participants was, “Is this plant an example of best practice?” The
concerns related to the design and location of the proposed plant:
• Lack of detail in relation to the technical design;
• Has the proponent researched and visited other plants?;
• Location was an issue due to its proximity to the refinery, and a long distance from
future residential development and location in the floodplain.
In Submissions
• Concerns that no plans for the recycling of stormwater;
• Questions raised about flow rates and bio-reactor digestion;
• Concerns about how the plant will handle shock loads and wet weather;
• no pilot plant results from Oyster Cove
12
Links with the Master Plan and future expansion plans (4)
20B Issues
These concerns were broadly about future water security in Geelong. Participants also
identified that the Northern Water Treatment Plant was not included in the Central Region
Water Strategy and their question was “how does it qualify as part of the master plan in
providing sustainable water for our future?”
In addition a number of groups asked if the plant could be scaled up or expanded to
meet future growth.
In Submissions
• Concern that this plant does not require Shell to cease discharges into Corio Bay
Value for Money (4)
20B Issues
These concerns were closely tied with the theme ‘Shell’s benefit from the plant’. There
were questions relating to a perceived lack of detail on the cost of the project and value
for money.
When clarifying this group of concerns, the chair summarized the core question as, ‘if this
is how much money we have, is it the best use for the outcomes being delivered? Is this
proposed project the best ‘bang-for-buck?’
Energy use of the plant (3)
20B Issues
This was the one theme where other opportunities were identified. Some participants
expressed a desire for alternative energy sources (e.g. solar, wind, tidal) to power the
plant. Another opportunity was to tap the wasted energy from Shell Refinery processes
(e.g. flare energy) and use it to power part of the plant. It was pointed out that any use of
alternative sources should be in addition to existing renewable energy targets.
4.3 Summary of the main concerns received by the EPA in public submissions
EPA Victoria provided the chairperson with a summary of the main concerns contained in
the public submissions they have received. During their analysis of these submissions,
the main topics that emerged included:
• Odour and VOC emissions
• Insufficient design information
• Difference between planning permit application and works approval application
• Public health and environmental impacts
• Location of the treatment plant in flood plain
• Existing potential soil and groundwater contamination
13
4.4 Points of clarification requested by community participants
4.4.1 EPA role in land use planning process
At the beginning of the 20B Conference, a few community representatives
were concerned about some information written under the heading “EPA does
not have the power to do something about”. The information related to EPA’s
role in the land use planning process through the planning permit referral
process.
4.4.2 EPA Role in assessing the cost of the project
Throughout the 20B Conference, there were comments and questions about
the EPA’s role in assessing the cost of the project. When questioned further, it
appears that some community representatives believe that the EPA, under
section 1B, should take into account social, environmental and economic
values when considering the works approval application.
4.5 Other requests and resolutions
4.5.1 Request for an update
An update was requested from Shell and EPA Victoria on the implementation of
Shell’s Water Master Plan.
4.5.2 Request for more detail
Provide community with a more detailed description of the Water Treatment
Plant display. What do the various terms like Type 1, 2 & 3 water in display?
4.5.3 Resolutions
Three resolutions were moved by Sue McLean (supported by Peter Linaker and
a majority in favour)
That the applicant/proponent (Barwon Water) provide:
i. the results of the pilot plant trials to the community
ii. the results of the sewerage study from 2009
iii. an explanation of the Barwon Water modelling It is not clear what is
being requested
The community requested that this information be provided by Barwon Water
at least 2 weeks prior to the next meeting on August 3, 2010.
4.6 Next Steps
June 2010
Chairperson (Geoff Brown) to collate and review the 20B Conference outputs and
summary of submissions
• Any additional submissions from the community via email or Bang-the-Table will also be
included
Early-Mid July 2010
Chairperson to prepare and complete the 20B Conference Report and Recommendations
August 2010
Follow Up 20B Conference
• This workshop will aim to resolve specific concerns and questions from conference #1
14
4.7 Participant Feedback
Participants were provided with 2 options to rate their experience of the 20B Conference.
Option 1: Evaluation Dartboard - this technique allows participants to rate the event
based on 4 criteria (see table below). Participants place a sticky-dot on the dart board to
indicate the extent to which their expectations were met.
*A dot placed inside the small circle = Exceeded Expectations
*A dot placed inside the large circles = Met Expectations
*A dot placed outside the large circle = Missed the mark & did Not Meet Expectations
Evaluation Question
(Criteria)
Exceeded
Expectations
Met
Expectations
Did not meet
Expectations
Level of satisfaction with the
way the meeting was run
0%
n=0
75%
n=6
25%
n=2
The process used in helping
me to understand the issues
12.5%
n=1
50%
n=4
37.5%
n=3
Confidence that the EPA have
heard all the issues
12.5%
n=1
12.5%
n=1
75%
n=6
Level of satisfaction that the
process used identified key
issues & concerns
33.3%
n=3
33.3%
n=3
33.3%
n=3
Option 2: Conference Feedback Form: A 2 page, 8 question form was also provided for
those participants who wanted to provide more detailed feedback on the 20B Conference
and provide suggestions for the second conference in August.
15
5. Chairman’s Conclusions and Recommendations
5.1 Conclusions
Many of the concerns and questions raised at the public conference related to issues that
sit outside of EPA’s role in making a decision on the works approval application. As we
discovered early on in group discussions, the clarity of EPA’s role in relation to many
issues is clouded and needs further guidance.
Given the complexity of these issues and roles, it was clear that a second public
conference would be required and this was agreed to during the course of the evening.
The group also mapped out a series of activities needed to prepare for the second public
conference in August. Many of these steps listed in 5.2 Recommendations.
It should also be made clear that sufficient opportunities to communicate concerns about
the proposal have been provided through the public submission process and the first 20B
Conference. The 20B Conference was designed to assist all participants to understand
the context and details behind all concerns. It was not the intent of the first 20B
conference to specifically address the wide range of public questions and issues.
The major issues of concern to the community are numerous and wide ranging. High on
the list priorities are concerns about access to recycled water and a perception that
Shell’s private benefit is coming from public funds. Access to pilot plant results was
requested by the community in a resolution. The extent to which this works approval
application conforms with specific principles under the Environment Protection Act 1970
was questioned at the conference and in all public submissions.
Through the submissions it was clear that concerns about adverse health and
environmental impacts are related to questions about the plant design, it’s location and
the results from the pilot plant. These came out clearly in section 4.5 above.
As Chairperson, I am satisfied that the follow up steps identified at the 20B conference
(and communicated in this report), will achieve its intent of providing an opportunity to
hear community concerns and, where possible, provide them with additional information.
5.2 Recommendations
In preparation for the second 20B Conference:
• EPA Victoria provides clear guidance on which of the issue captured at the 20B
conference (and in public submissions) are relevant to the works approval process and
which issues are for other agencies to tackle;
• The EPA again invite specific agencies to participate in the second 20B Conference so
that issues outside of EPA’s role in the works approval process can be tackled by the
relevant agencies;
16
• That EPA respond to a request from 1 group at the 20B Conference who requested that
a Neighbourhood Environment Improvement Plan (NEIP) be considered in relation to
concerns about odour and possible adverse health impacts.
• That the EPA clarifies the intent and meaning of the ‘Powers table’, particularly in
relation to landuse zoning;
• EPA clearly defines and explains its interpretation of section 1B (Principle of integration
of economic, social and environment considerations) of the Environment Protection Act
1970 as it relates to EPA’s role in assessing the cost of the project;
• EPA clearly defines and explains its interpretation of other principles in the Environment
Protection Act in relation to this works approval application. At the 20B Conference and
in most of the public submissions, the intent of many of the principles in Section 1B
were the subject of discussion.
In relation to the 3 resolutions were moved and supported:
• That Barwon Water respond to the supported resolutions captured at the 20B
Conference which states:
“That the applicant/proponent (Barwon Water) provide the community with:
i. the results of the pilot plant trials to the community
ii. the results of the sewerage study from 2009
iii. an explanation of the Barwon Water modelling”
• The community requested that this information be provided by Barwon Water prior to
the next meeting in August.
At the second 20B Conference on August 3rd, 2010:
• That a second, follow up workshop be staged to attempt to resolve community
concerns and, where possible, provide answers to more specific questions outlined in
this report. Two specific requests from the community include:
i. An update from Shell and EPA Victoria on the implementations of Shell’s
Water Master Plan;
ii. Provide the community with a more detailed description of the Water
Treatment Plant display. What do the various terms like Type 1, 2 & 3 water
on the display mean?
17
ATTACHMENT ONE:
QUESTIONS, ISSUES AND CONCERNS RAISED IN CONFERENCE
The participants assisted the chair to group their written responses in to main themes.
ATTACHMENT 1 contains a direct transcription of what was written by participants and,
in some cases, additional notes were added (in brackets) by the chair when clarifying the
their response.
Barwon Waterʼs community
engagement processes
Questions about the design
and ʻbest practiceʼ of the
proposal
Results from the Pilot Plant
Disappointment in how Public
Relations replaces engineering
The Barwon Water CIB in Feb
2010 incorrectly states Works
Approval application was open for
comment in Feb 2010 - this was
provided to participants at
Barwon Water community forum
in March 2010, implying the
Works Approval application had
already been approved
(this gave the impression to some
in the community that the Works
Approval application had been
completed)
Is this best practice - location and
design?
(*has a plant like this been built
before and has it been done
effectively and was it cost
effective?
*has the proponent
researched/visited international
equivalent projects?
*location is a real issue because
this plant is neighbouring the
Shell Oil Refinery and is distant to
new and future development
*has the risk of sea level rise and
inundation been adequately
researched?)
Test Results
*was it adequate?
* did the Oyster Cove Shutdown
affect the results?
*can the test results be released
to the community?
*the community are questioning
the validity of the pilot because
Shell was shut down for a % of
the duration of the pilot and the
ʻworst caseʼ scenario remains
untested
Consultation - Barwon Water only
reporting good news, not
community concerns
There is a lack of detail available
on the technical design
Disclosure of and interest in
seeing the Pilot Plant results.
Where is the commitment from
Shell?
Is this best practice?
What were outcomes of the pilot
plant testing?
Change in scope (of the Works
Approval application) not
communicated to the community
adequately
Site location for plant - is this a
Floodplain?
Is the process/combination
proven?
Have rising sea level impacts
been addressed?
(the community) ... Need
clarification on process & the
security against risks - e.g.
Shellʼs salt water getting into
mains water
18
Shellʼs benefit from the plant The Works Approval process Access to recycled water
Is Shell just delegating (or
abrogating) responsibility for
waste to the community?
*heavy metals
*petroleum
*(in other words ... Shellʼs costs
are being handed back to the
community through Barwon
Water)
Under the principles of the EPA
Act, the accountability of the
project is a concern:
*regarding the overall costs
*environmental factors
*lack of balance between Shellʼs
needs and community needs
Supply of water to other industry
(e.g. Ford, MC Herd) is limited
*in the Barwon Water Sewerage
Strategy (2005) is states “Drought
proofing of neighbouring sporting
grounds and other industry”)
* (the community expectation that
the water would have a broader
benefit to other industry and
community)
Have environmental
considerations been addressed
(e.g. Hydrocarbons)
Works Approval is not in
accordance with EPA Act
principles
Can the recycled water have
other uses other than Shell and
Steadpark
A low % of the reuse water is
going to the community
Value for Money? - Shell the only
benefit
Government and Statutory bodies
not listening to community
concerns
*(and the community is made of
people with expertise)
We need to identify who else
benefits apart from Shell
Parity of access and benefits What can be put in place by the
EPA to ensure they (i.e. Shell)
comply with the License?
Are there opportunities for others
to access the recycled water?
Concern about corporate welfare
- public funding private industry
- Private Partnerships - who
benefits & who pays?
The Recycled Water Project
should benefit all
industry/community and not just
Shell
Value for Money? Links with the Master Plan &
future expansion plans
Energy use of the Plant
There has been a lack of detail
on the cost of the project - value
for money?
(has a cost-benefit analysis been
done?)
(if this is how much money we
have, is it the best use for the
outcomes?)
(Is this the best ʻBang-for-Buckʼ?)
Water Security in Geelong. How
does this fit in the master plan?
(The Northern Water Treatment
Plant was not included in the
Central Region Water Strategy
and ... how does it qualify as part
of the master plan and in
providing sustainable water for
our future?)
Value for Money? Water Security - there are many
different meanings for this term
and depending on the meaning
being used, this project either
does or doesnʼt improve security?
(secondary question was: “Do
Barwon Water understand the
concept of water security?)
Energy use of the plant is a
concern and can ʻflareʼ energy be
used to power the plant?
(Given Shell uses and wastes so
much energy in itʼs processes,
can this excess energy be used
to power the plant?)
19
Value for Money? Links with the Master Plan &
future expansion plans
Energy use of the Plant
Value for Money? - shell the only
benefit
Can the plant be expanded on
the current site?
Can alternative energy sources
be built into this project?
(e.g. wave, tidal, wind, solar)
(also important that is this is done
it is over and above renewable
energy targets)
Cost of water produced - is this a
way of Shell just getting rid of
waste?
Is the site big enough for current
and future expansion?
How do the ʻtonnes of GHG
produced per litre of water at this
project compare to other water
sources?ʼ
*links with Best Practice
Can this plant be scaled up -
upgraded in future to cater for
COGG growth
Ownership of Land Odour, Noise and Flood Risk Contamination
Ownership of the land is an issue:
*currently Shell land and not
public
*what happens if Shell refinery is
sold and the viability of the
MWP?
(The feeling was that public
infrastructure should be on public
land and not private land)
Odour. Concern about plant
upset during storms, huge
flows/storage (in uncovered tanks
called Lagoons)
Soil and groundwater
contamination and remediation?
What about the long term, secure
ownership of the land?
Flood risk at Plant with
overflowing
What will the land contamination
at this site from shell? (Is this a
risk?)
Ownership of site - public should
own it
Concern about odours/toxic air
emissions - Lagoons not fully
enclosed
This plant doesnʼt stop Shell from
discharging water to the bay, or
sucking water from the bay.
EPA to address odour concerns
raised by resident by EPA being
involved in the development of a
Neighbourhood Environment
Improvement Plan (NEIP).
Odour from storage lagoon
Health concerns/impacts with
open ponds (lagoons)
What will the noise levels be from
the plant?