EPA guidelines say Don’t

Further confirmation that the Doncaster Sewer plant is proposed in the wrong place… this was sent in by Stephen.

Reading Yarra Valleys Waters application to the EPA (dated May 2012) seeking approval for the Doncaster Hill Treatment Plant, raises more questions, than answers. Buffer zones are designed to protect inappropriate land uses from colliding. Nothing could be a perfect example of this as the case of sensitive  residential land uses and a sewerage treatment plant and yet, Yarra Valley Water have ignored even the EPA guidelines with scientific gibberish to skirt around distance requirements. Even the EPA in their document (Recommended Buffer Distances from Industrial Residual Air Emissions, July 1990) states (page 1) “ Even with good pollution control technology, there may still be unintended or accidental emissions which must be anticipated and allowed for. …it is recognised that even “state of the art” technology is not always capable of achieving this goal without fail”..

 It would be hard to imagine Council or the EPA approving this one.



Stephen O’Brien

Town Planner, Candidate for Koonung Ward (Manningham City Council), Phone 044 8147 238, “Because the residents of Koonung Ward deserve much better”


Stephen also wrote the following letter to the Minister, dated: 14 July 2012 “for the Attention of the Victorian Minister for Environment and Climate Change (Hon Ryan Smith)

Dear Minister,

I draw your attention to the Yarra Valley Water application to the EPA (dated May 2012) for approval of a Treatment Plant located within Tram Road Reserve, Doncaster.



  • YVW is planning a water recycling scheme to produce and distribute Class A water via a dual pipe to the Doncaster Hill development precinct.
  • Source water for the scheme will be sewerage drawn from the local sewerage system by way of a sewer mine.
  • Treatment facilities will be established on site. YVW claim that this is a “state of the art facility” that will overcome odour, noise, discharge and visual aesthetics.
  • The proposed facilities will be located within Tram Road Reserve, Doncaster (north of Koonung Creek and the Eastern Freeway). The land is owned by Manningham City Council.
  • YVW are seeking a permit from Council to establish the facility as well as approval from the EPA to obtain works approval.


EPA Buffer Guidelines & Non Compliance with the recommended Buffer Distances

Minister, your attention is drawn to your departments’ July 1990 publication “Recommended Buffer Distances for Industrial Residual Air Emissions” wherein the following statement is made :-

“..even with good pollution control technology and practice, there may still be unintended or accidental emissions which must be anticipated and allowed for. While it is an objective of the Authority and the State Environment Protection Policy that such emissions should be eliminated, it is recognised that even “state of the art” technology is not always capable of achieving this goal without fail”.  Equipment failure, accidents and abnormal weather conditions are among the causes which can lead to amenity reducing emissions affecting properties beyond the boundaries of the source premises”.

 Under your departments guidelines who are assessing this application, the recommended buffer distances for Sewerage Works is 200 metres (for the installation of a treatment facility with a capacity of less than 5,000 person, this application is to service a planned population of 1,950 persons).

The following Google Earth Map of the proposed facility demonstrates that homes are well within the 200 metre buffer zone , in fact the closest residence is only 25 metres.

Minister, I urge that regardless of YVW submission not meeting your departments buffer zone requirements, this application for works should also be refused on the following grounds :-

YVW have not adequately demonstrated that other alternative sites have not been thoroughly investigated wherein sensitive land uses are not in direct conflict,

  1. The YVW submission does not adequately address how surface and ground waste water will not be contaminated.
  2. The submission doesn’t not adequately address if this facility is to take additional population how buffer zones to existing residential is to be dealt with (and the submission does mention that in time the facility may take additional capacity).

Minister, I believe that even your own department must apply the recommended buffer distances when assessing development proposals to ensure that incompatible land uses are located in a way that minimises impacts caused by odour, noise and polluting air emissions.

I will make contact with your office on Monday (16th July) and would propose to meet with your Senior Ministerial Policy Advisor to discuss this application and the non-conformity with your own departments guidelines.

Yours sincerely

 Stephen O’Brien

Town Planner




  1. Joanne Georgakopoulos says:

    Brilliant article. My house is only 25 metres from this proposed sewerage plant. We need to stop this nonsense once and for all. Rules/compliance are set for a reason. Too risky to residence if this stupid idea goes ahead. Love your work!!!!!!

  2. Barbara Carlisle says:

    Despite major initiatives in recent years to boost Melbourne’s water reserves, the introduction of sewage plants to produce recycled water, should not be discouraged, providing they are planned in advance and appropriately located.
    The plant proposed for the Tram Road reserve, sited only 25 meters from established dwellings, is entirely ad hoc, an afterthought and contravenes the buffer zone guidelines of the EPA.
    While metered recycled water will increase revenue for Yarra Valley Water and help showcase Council’s Doncaster Hill, there will be of no benefit whatsoever for ratepayers of Manningham, the very reason why Whitehorse Councillors declined the same sewage plant previously proposed within their boundary.

    •The agreement to introduce a sewer plant was made between Manningham Council and Yarra Valley Water in 2008, the middle of the drought, and 12 months before the go ahead for the Wonthaggi Desalination Plant.
    •Its annual maximum output of recycled water from the Tram Road plant 127,750 kl would be approximately 12% of one gigalitre,
    •The Desalination plant will deliver 150 gigalitres with a capacity to produce 200 gigalitres if required, almost 50% of Melbourne’s total consumption.
    •The annual water consumption for Melbourne is approximately 420 gigalitres.
    •Re-commissioning of Tarago (Connected in June 2009) – 15 gigalitres will also be available annually.
    •The Sugarloaf Pipeline – up to 75 gigalitres annually from Goulburn River if required.

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