2007 Site selection process

The site selection process conducted by the Water Corporation was a catastrophic failure. This statement is not made lightly. It is not a case of different people having a different opinion about which is the best site.  This statement is the result of a very detailed investigation into all aspects of the process. It is an accurate description of what occurred. The Water Corporation site selection process failed because throughout the process they made lots of errors each of which were big enough on their own to change the outcome.

The selection process had failed before the community consultation began

The consultation started with the wrong list of sites

The list of ‘possible sites’ offered to the community at the first community forum was taken from a 2002 map of possible sites. This 2002 map of sites was compiled for a different and particular purpose. As a result the list presented to the community consultation in 2006 included many sites that should not have been included and also excluded sites that should have been included.  Five of the six sites shortlisted in the 2006 consultation sites should not have been included and the sixth shortlisted site was not included until forum 6 of the community consultation.

If the DEC had acted according to their Key Performance Indicators and the nationally agreed Reserve Criteria, the DEC site would never have been made available for consideration.
The DEC had identified the site as Conservation Park in accordance with the following key performance indicators. These indicators direct the DEC to reject the Water Corporation’s offer.

KPI 23 The identification and protection of cultural heritage.

KPI 25 The protection of Heritage places through representation in reserves

KPI 26 Number, range and use of recreational/ tourism activities available by proposed land category in the plan area.

Moreover, any one of the Nationally Agreed Reserve Criteria is sufficient to afford the site reserve status. In fact all four of the criteria in section 4 direct the DEC to afford the site reserve status.

These KPIs and national criteria direct the DEC to reject the Water Corporation’s offer. The complicity of the DEC throughout the process is a cause for serious concern.

The site is within the Bibbulman Track Reserve

The DEC should have pointed out that some of the site was within the Bibbulmun Track reserve, which extends 200m either side of the track as it passes through the Perth Hills National Parks Centre.

The threat to the endangered Baudin’s Black Cockatoos should have excluded the site
The DEC manages Jacoby Park which is directly opposite the Mundaring Divisional Headquarters. Jacoby Park contains one of the largest and most important roost sites for Baudin’s Cockatoos. These Cockatoos are listed as endangered at the state and federal level and red listed.  (See environment). The DEC must have been aware of the existence of the Baudin’s Cockatoo roost opposite and should not have agreed to the inclusion of the site because it is a threat to an endangered species. They should have pointed out to the WC the threat to this endangered species from the outset.

The DEC do not own the land
The Water Corporation described the site as the DEC Land site because it believed the site was owned by the DEC and therefore suitable from the point of tenure. They were prepared to provide the DEC with new facilities in exchange for this  land. But most of the land is state forest and does not belong to the DEC. The DEC does not own this land any more than any other area of state forest.  It is not theirs to trade – it is ours!  And the land that does belong to the DEC has to be managed as state forest.

The DEC stated that the proposal was one for the Water Corporation to persue as their proposal. This does not excuse the DEC from failing to point out that the DEC  did not own the land.

The DEC were also prepared to waive their responsibilities to protect the heritage and environment in exchange for a site the DEC does not in fact own.

The site selection should have included the electricity substation
The WC has to commission a new substation to supply the power to the water treatment plant and the pump station at the base of the weir. This substation will almost certainly be built at the Firewood Rd quarry site. The aim of the site selection should therefore have been to identify sites for the Water Treatment plant and the associated electricity substation. The Firewood Rd quarry site is the only site with enough space to accommodate both of these facilities. Locating the WTP in the village will require additional powerlines.

The plan for the DEC site should have included the relocating of the DEC divisional headquarters and work areas

The WC proposal to locate the WTP on the DEC site should have included plans and costings for either relocating the DEC facilities elsewhere, or rebuilding the DEC facilities within the existing site alongside the WTP.

The selection process failed during the consultation

There was no reason to eliminate the Sawyers Valley Tank Hill site: The EPA offset had been agreed. The community amenity criterion (visual impact noise etc) would be minimal compared the impact the site will have in the village.  Two more large storage tanks must be built on Sawyers Valley Tank Hill. The WTP could be behind these tanks reducing any impact.

The site has strong engineering and cost advantages. The Water Corporation had given Community Amenity a weighting of 8%. The cost criteria alone (11%.) is enough to outweigh this.

The site summary information supplied to the community was biased

The Multi Criteria Analysis was incomplete: The Multi criteria Analysis did not include all the Criteria and Sustainability Principles identified by the WC for sites selection.

Many of the criteria were incorrectly assessed: None of the criteria used in the MCA now support the selection of the DEC site in the village. Many of the criteria, particularly those assessed by Water Corporation staff, were incorrectly assessed. A very detailed review of the site selection process reveals the Multi Criteria Analysis failed at nearly every stage.

The systems of scoring, weighting and processing data chosen by the WC were ill-conceived and unreliable.

The site selection process continued to fail after the community consultation

During the sites selection process, no site emerged as clearly the best. The WC selected the site in the village as their preferred site. The following subsequent realizations should have made the WC and the DEC reconsider their options.

The WC should have reconsidered when they:

  1. became aware of the errors in the selection process;
  2. became aware that the costs were incorrect;
  3. first became aware of the impact on the Baudin’s cockatoos: The WC announced the site selection in Feb 2008 and received the report on the threat to the Baudin’s Black in May 2008;
  4. realised that the concept plan was hopelessly inadequate: The plan has expanded from 8 to 14 ha. This has eliminated any buffers between the site, Mundaring Weir Rd, Allen Rd and the Heritage rail trail;
  5. they became aware that the impact on the Baudin’s cockatoos would be much greater than at the time of the report;
  6. knew that costs were a huge underestimate due to the extent of the earthworks necessary to contain the plant in the site;
  7. failed to find a new location for the DEC: This delayed the process for nearly two years;
  8. tried to accommodate both the Water treatment Plant and the DEC site in the same site: the DEC need to upgrade their facilities, but the earthworks required to squeeze both facilities into one site will greatly increase the cost of both facilities and greatly increase the visual impact. The water corporation still has no plan for this. The image prominently displayed on the Water corporation website is incorrect as it does not include the new DEC facilities.

The DEC should not have reconsidered the agreement when

  1. the impact on the Baudin’s Cockatoos was realized;
  2. it was realised that the prerequisite condition “That there should be no significant impact on the operation of the Perth Hills National Parks Centre and visitor amenity” could not be met.

The WC is now trying to force the plan through

Rather than admit that the site selection process failed, the Water Corporation are now trying to force the plan through in two stages. They plan to start work on the first stage without further consultation. The WC intends to clear and start work relating the DEC on 3 ha of land beside Allen Rd.  This part of the site is managed as state forest but held by the Executive Director of the DEC. Because it is held by the Director, it will be easier to proceed.

By the time detailed plans of the WTP are released for public comment, the 3 ha will have been cleared and it will then be too late to go back. This land is being used as a thin end of a wedge to drive the project through.

Incidentally, the WTP will be delayed by the construction of the DEC facilities . Work could start on the Firewood Road O’Connor site or Sawyers Valley Hill site without this delay.

The referral documents submitted to the Federal Department of Environment, Water, Heritage and the Arts, and to the State Environmental Protection Authority contain misrepresentations and omissions.

The questions about fauna in the referral forms are to determine whether the proposed development will have an impact on any endangered species. The Water Corporation’s replies evade this issue by referring only to the land that must actually be cleared. They do not mention the traditional roost site for up to 500 Baudin’s Cockatoo  in Jacoby Park and that the Water Corporation’s plans could have a significant impact on their survival. (See potential impacts page 15 of attached cockatoo assessment.)

The area of the site that must be cleared to relocate the DEC was not included in the referral documents. This part of the project will be presented as a separate, unrelated project in their submissions.

The Water Corporation also fail to mention that since the time of the cockatoo assessment the site now also includes the DEC facilities and the area of clearing required to accommodate the water treatment plant and the DEC facilities has increased from 8 to 14 ha. The development  now fronts directly on to Jacoby Park the home of the Baudin’s Cockatoo.

The impact of the WTP and associated infrastructure will be much greater than estimated.  The referral makes no mention of the effect of the noise, vibration and dust on the cockatoos resulting from the removal of the tens of thousands of tons of rock and soil.

The site selection process failed the Water Corporation and the community before during and following the sites selection process.

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