Submitted by Shirley Knight, 2014.07.01

The Penneshaw CWMS Prudential Review has been received by council and is listed as an agenda item for this week’s Audit Committee meeting.

Given that a prudential review is in effect an audit of a proposed project to ensure that the project is sound, it goes without saying that the review itself must be thorough and review all direct and indirect risks associated with the proposed project.

A reading of the one put to council’s audit committee appears less than adequate in quite a few areas I will list here, but more importantly, if council is aware that the prudential review fails to adequately consider aspects it is meant to review and council proceeds with the project without assessing further those inadequacies in the report, it could be open to a claim of malpractice and referral to the Independent Commissioner Against Corruption.
The areas that may not have been adequately considered in the review are:
1) Project Compatibility with Council’s Strategic Plan.
The Strategic Plan clearly requires a project such as this to use the wastewater generated to be considered a resource and utilised to best advantage. The proposed project proposes to totally waste this resource and there are no geotechnical studies referenced to confirm that the dumping of wastewater on the ground near the treatment plant will work without additional future costs.
The Strategic Plan clearly requires the whole town to be serviced, not just a favoured few. There is only circa 40% of the town proposed to be included and there is no determination, proposal or plan for the remainder of the town as to what the requirements on them to address the many deficiencies identified with their current septic systems such as upgrading to modern on site treatment.
2) Town Development Plan Objectives
The town plan requires the existing attractive seaside town appeal to be retained. The potential to allow a trebling of development density on a random footprint of less than half the town is folly. There is little chance of the existing town charter being retained.
Consistent with council’s misadventures in trying to put a large dam on a steep hillside, it is now trying to locate the treatment plant and large dam as a non complying development in an attractive rural living zone. The Prudential Review in fact does draw attention to this misadventure and notes that a significant redesign will be required if non complying consent is not obtained.
3) Economic development and Fair Competition.
The Prudential Review fails to identify and address that the proposed servicing of less than half the township with a common sewerage system creates the green light for higher density development for only the 40% of the township effectively selected on no logical or planning basis. This is most likely a first for any community in this State. This is hardly addressing the need for fair competition.
4) Project and Future Costs of a town sewerage scheme.
The Life Cycle project costs cited in the review are inappropriately restricted in their scope to a bare-bones project. The cost/benefits of recycling the water for community use (or commercial sale) is not factored in the costs: neither is the obvious advantages of routing the reticulation and rising mains along the road reserves to allow ready connection of additional properties in future expansion of the scheme. Whilst the Review identifies the desirability of connecting more properties in the future it also identifies that council dimly does not have the financial capacity to do this. A proper review would address just how this is to be done, and if not to be done just what will ensure the identified poor standard of many existing properties outside the scheme will be addressed. One thing that has been clearly identified is that the injection of common sense into the considerations such as the obvious best practice self management options which have been advocated by more than myself for years now will not be a factor. One presumes that council will consider the 8 years the 100% of the town has been running rudderless, without policy on this essential service, is OK to continue for the remaining 60% of the town for another 8 years.
We can expect from the audit committee is to rubber stamp this obviously substandard Prudential Review and for council to accept that recommendation, and then we can watch as the administration manipulate the planning and development system to place the dam and treatment plant in a non conforming development zone.