1 Site history and contaminated site requirements
1.1 Is the City aware the site is contaminated?
Yes. The former South Fremantle landfill site was operated as a waste disposal site between approximately 1930 and 1991.
According to Department of Environment Regulation (DWER)’s summary of records for this site:
The site is contaminated and remediation (such as the development of a site management plan, and further groundwater assessment) is required to reduce the risks of human health, the environment and environmental values to acceptable levels. Therefore the site is classified as ‘contamination – remediation required.’
The DWER stated actions require creation of a site management plan to outline long term management measures, including measures for managing asbestos and landfill gas. Further groundwater inspections are required and Department of Health also require regular inspections of accessible areas.
In accordance with the Contaminated Sites Act 2003 and the 2013 Interim Site Management Plan, the City has been conducting and will continue to conduct site investigation, monitoring and management activities with the advice and support of the DWER and the Department of Health.
1.2 The site is classified as 'contaminated - remediation required'. Why isn’t it being remediated?
The definition of 'remediation' in the Contaminated Sites Act 2003 is broad, and includes measures to manage contamination such as restricting access or use of the site, as well as active 'clean-up' measures such as treating, removing or engineered means of containing contamination.
The DWER does not expect the City to carry out active clean-up, for example, excavating and removing waste from the landfill.
DWER and the Department of Health require the City to develop a site management plan to outline long-term management measures for the entire South Fremantle landfill. That management plan includes regular inspections and removal of any asbestos materials from surface soils in accessible areas; further groundwater monitoring; management of landfill gas; and occupational health and safety measures for workers carrying out intrusive works or excavation, for example, utility companies carrying out works in the service trench for the gas main that crosses the site.This is in addition to the requirement for Epuron to develop a site management plan for the solar farm proposal, which is a condition of the company’s planning approval.
1.3 How contaminated is the former South Fremantle landfill site? Can it be remediated?
The site was operated by the City as a landfill between the 1930s and the 1990s. During that period, uncontrolled fill included domestic and industrial waste and fly ash was deposited on the site. The site is also thought to contain quarantine waste.
Under the Contaminated Sites Act 2003, the site is classified as 'contaminated - remediation required'. The community has expressed strong concerns over potential adverse health and environmental impacts if a clean-up of the site were to occur through a ‘dig out and dump’ approach. Quarantine waste would require particularly stringent removal practices. In any event, studies show this approach to remediation as not being financially viable.A management plan is currently in place which includes regular groundwater testing and monitoring of gases.
1.4 What does the City have to do to manage the site to meet DWER requirements?
The current site management plan is known as the 2013 Interim Site Management Plan. This prioritised monitoring of landfill gas. The risk assessment documented in the 2017 Mandatory Auditors Report (2017 MAR) concluded that landfill gas was unlikely to pose a risk to off-site receptors while the site is in its current, undeveloped, land use. Further groundwater assessment is required. The City is currently assessing proposals for groundwater monitoring.
The updated 2019 Mandatory Auditor’s Report (MAR) for the proposed solar farm confirms the requirements for further investigations under the 2013 Interim Site Management Plan.
Compliance with the 2013 Interim Site Management Plan and 2017 MAR will be required by the City whether the solar farm progresses or not.
1.5 Is the City’s management plan and monitoring information available to the public?
Yes. This information is contained in the 2013 Interim Site Management Plan and the 2017 MAR.
2 Possible uses for the South Fremantle landfill site
2.1 Could the rest of the landfill site be used for other purposes?
Any change of use would also require new planning and environmental approvals.
Anyone with ideas for future uses of the site should first familiarise themselves with the following documents which provide useful background regarding the state of the site and its constraints:
2.2 Could the site be used for public open space?
Under the definition of remediation, the City is required to restrict access to the site making it unsuitable for public open space. The use of the site for a solar farm is considered temporary and it could be removed in the future. If removal, destruction, or dispersal of contaminated material can be done in a low risk and feasible way in the future, then other uses including public open space could be considered at that time. Any future uses or development would be subject to proper planning, environmental and community engagement at that time
2.3 Why can’t the site be remediated and used for housing/urban development?
2.4 The South Fremantle landfill site is only a few hundred metres from the coast. Would wave, current technology for power generation be a better choice?
3 Benefits of putting a solar farm on the former South Fremantle landfill site
3.1 Why is this project important to the City of Fremantle?
The solar farm project is in line with the recommendations of the City’s draft energy plan and as well as its commitment to carbon neutrality for corporate emissions to 2020 and the aim of being 100% powered by renewables by 2025. The City continues to be a leader in sustainability, with the solar farm initiative recognised in the City’s One Planet Action Plan and future visioning projects.
3.2 How would the Solar Farm benefit the community?
4 Working with Epuron
4.1 Who is Epuron and how did they get to be working on this site?
Epuron is a Sydney based Australian company that has developed numerous renewable energy projects in Australia. Epuron has developed and operates several large scale solar and wind projects including operation of solar farms in 5 locations in the Northern Territory.
4.2 What happened to the City's first preferred proponent, First Solar?
In it's expression of interest, First Solar intended to develop a 10-12MW(ac) solar PV power plant. However, it was subsequently determined that the site’s topography would constrain the size to suit its approach. First Solar also cited difficulties in achieving a Power Purchasing Agreement.
In approving the preferred proponent the council agreed that a ‘standby proponent’, Epuron, could be approached if the first proponent withdrew. Epuron agreed to participate and signed its exclusive working agreement (EWA) with the City in October 2015.
4.3 Why does Epuron believe it can do this when First Solar couldn’t?
While there is no guarantee of success, Epuron’s business model is different from that of First Solar. Unlike First Solar, Epuron is technology agnostic, which means it is not tied to a specific type of solar panel. It will select the equipment that best fits the site. Epuron is also an experienced developer of smaller, utility-scale sites of the scale contemplated for South Fremantle, as demonstrated by its growing portfolio of operating solar projects which includes the 4.1 MW Uterne solar power plant at Alice Springs; the three off-grid TKLN sites in the Northern Territory which total 1 MW; and the 1.8 MW Yulara solar power plant which is currently under construction at Ayers Rock Resort.
4.4 I understood Epuron’s exclusive working agreement with the City was only for twelve months. Why are they still involved?
The original EWA with Epuron was signed in October 2015. The EWA allowed for extension as long as reasonable endeavours had been made. In 2016 Epuron requested, and the City agreed to a 12 month extension (to October 2017).
In June 2017, the City’s Finance, Policy Organisation and Legislation (FPOL) committee authorised the Chief Executive Officer to negotiate and agree the terms of an extended EWA with Epuron which included principles for negotiation of a long term lease for the landfill site. The revised agreement will expire in 24 months (27 August 2019) or on the execution of the lease - whichever is the longer.
In September 2018, in accordance with section 3.59 of the Local Government Act 1995, Council approved a Business Plan for the proposed South Fremantle Solar Farm with Epuron Projects Pty Ltd.
In addition, subject to satisfaction of the City’s DA conditions, and in accordance with the requirements of DWER with respect to leasing contaminated sites, Council approved the CEO entering into a lease based on the terms in the Business Plan.
The lease is currently being drafted.
5 Buying and selling power
5.1 Would the City buy the power?
large component of the City’s power needs is considered to be contestable (so
it has a choice of power retailer) Council has a preference to transition to
locally sourced green power rather than purchasing carbon offsets. When it’s up and running, the South Fremantle
Solar Farm will be a local source of green power and the City could buy this
indirectly through the retailer.
5.2 Will I be able to buy power directly from the solar farm?
Currently, all residential (non-contestable) customers must buy electricity from Synergy. If you opt for green power through your retailer, it is possible that a portion of the power you purchase will come from the Fremantle solar farm. That is, output from the solar farm could be purchased by an electricity retailer such as Synergy under a power purchase agreement and could then form part of the green power electricity generation mix that the retailer draws on to serve its customers.
5.3 What is contestable power?
Consumers within the South West Interconnected System (SWIS) which consume more than 50 megawatt hours of electricity a year (an average of 137 units per day) have the option of choosing their electricity retailer. They are known as contestable customers. Non-contestable customers, including most residential customers, must purchase their power from Synergy.
The SWIS covers an area of 261,000 square kilometres. It covers the south west within a line that stretches roughly from Kalbarri to Southern Cross and Ravensthorpe and includes a leg reaching east to Kalgoorlie. The SWIS is a self-contained network which meets the generation and transmission needs of electricity consumers within its boundaries.
6 Design of the solar farm
6.1 How will the panels be laid out and does the final design disturb the bund?
The solar farm will be limited to Lot 1 only in the first instance. The current layout of the solar farm is shown in Appendix B of the Site Management Plan. The existing earth bund will not be disturbed.
The solar farm will comprise pre-fabricated, continuous solar photovoltaic (PV) arrays. The array frames, including beams in the system, will be connected together and will not require anchoring individually as they achieve stability and wind loading requirements through the mass of the beams alone, which are likely to consist of pre-cast concrete. The arrays are essentially lightweight structures, which will not impose significant bearing pressures upon underlying soils.
Recycled rubber pads, or a similar material, may be required to level each unit and ensure ground clearance underneath each beam (each beam has 3 points of contact to the ground). The nature of the array includes provision for air flow beneath each unit (0.6 m) and between each solar module (set of panels).
Solar arrays will be secured to the ground at the end of each row via three ground screws driven to approximately to 0.5 m below ground level (mBGL) to 0.8 mBGL. These ground anchors are a minimal displacement anchoring solution in which soil is displaced rather than removed in the installation process. If ground conditions are deemed not suitable for use of ground screws, an alternative solution comprising larger ground beams (with a larger footprint area to minimise ground bearing pressures) at the end of each row will be utilised.
The panels will be laid in a continuous array format to circumvent the requirement of trenching for direct current (DC) cables (DC cables are ground-mounted via cable trays or similar) between modules.
Technical drawings of the proposed development can be found at Appendix B of the Site Management Plan.
The solar arrays will be transported to site in standard shipping containers. The arrays will be rapidly deployed using a five tonne telehandler (or similar). Site preparation and instalment of arrays are the key tasks which may cause ground disturbance however this is expected to take only around 5 weeks of the overall construction and commissioning program.
Completion of the project’s engineering, procurement, construction and commissioning is expected to take approximately 9 months, subject to Western Power’s connection schedule; approximately three months of this time will involve more intensive (localised) installation activities.
6.2 Will the solar panels be visible from nearby houses?
Structures would not be visible from the ground floor of neighbouring properties. The panels may be visible from upper floors just as the landfill site is visible from this viewpoint.
6.3 How will it affect the Hollis Park path?
The Hollis Park path way and the landscaping in that area will remain untouched.
6.4 Can planting be placed around the border to screen the panels?
No border planting is planned for the site. Any planting on the site would need to be lower than the height of the panels to avoid overshadowing the panels. This is unlikely to be any more effective as a screen than existing fencing.
6.5 Will there be any impact of bird life, wildlife and native vegetation?
As much of the site on which the solar farm would be constructed is contaminated, it is unlikely to be an appropriate habitat for native fauna. Also much of the existing growth on the site is weeds. Notwithstanding, plants, including weeds, are an effective way of helping to stabilise the soil and reduce wind born dust. Existing planting will be left in place as much as possible and additional ground covers provided to assist in reducing dust. Planting on Hollis Park pathway will be untouched by this proposal.
6.6 There are some heritage interests both Aboriginal and European surrounding the site, how will the Solar Farm affect these?
Lot 1 – the southern portion of the proposed site has no heritage listing. An application was made to include this area in the adjacent Hollis Park listing and put it on the state heritage register, however the Heritage Council of WA (HCWA) declined to list and the City agreed.
The three lots which form the northern part of the proposed solar farm site (possible future stages) are listed in the municipal Heritage Inventory as part of the Hollis Park listing and have landscape significance. The area is not listed at a state level. The site has historic significance for its former use running horses and access to South Beach, and for its associations with the marine/boat building industry in the South Fremantle area; it has social value for the local community. However due to its use as a landfill site; much of the landscape has been modified. In addition its classification means contaminated access to the site has been restricted for many years.
The use of the site for a solar farm will cause minimal disturbance and would be removable, leaving the site much as it is today.
The site is not registered as being of Aboriginal heritage significance.
6.7 How has the community been consulted on proposals for the South Fremantle Solar Farm?
In May 2015 the City called for expressions of interest from community members wishing to be part of a community reference group (CRG). A group consisting of eight people was formed. The objectives of group were to: raise ideas and concerns with the planning or operation of the solar farm, provide comment on layout concepts particularly in relation to local access and amenity.
The group met a few times and was provided with updates including notification regarding advertising of the Development Application (DA). However much of the period leading up to the DA involved Epuron’s dealings with Western Power, power retailers, and the environmental agencies which didn’t warrant community involvement.
Project updates were made available to the broader community through the local media and the City’s own communication channels including the City’s website at key milestones such as the change from First Solar to Epuron and the advertising of the development application.
The development application was made available for community comment by:
- letters to owners/occupiers of properties in the City of Fremantle and City of Cockburn within a 100 metre radius of the application site boundary
- Large signs on Cockburn Road, the intersection of Daly Street and the public path, and near the Hollis Park playground at the northern end of Keeling Way
- Notices in the City’s ‘Newsbites’ page in the Fremantle Herald
- Notification to the South Fremantle Precinct Group
- Notification on the City of Fremantle website
- A community information session held in Fremantle Town Hall on 1 March 2018 (advertised on the City’s website and in the Fremantle Herald)
Additionally the City updated the Frequently Asked Questions to address issues raised during the community consultation period.
Separate to consultation on the development application, Council advertised the draft business plan relating to the proposed lease of part of the site to Epuron Projects Pty Ltd.
The final site management documents have been approved and are available to the public in the document library.
7 Managing risks in building and operating a solar farm on the South Fremantle landfill site
See also FAQ Section 10.0 Site management requirements.
7. 1 Has a solar farm been built on a tip or contaminated site before?
Solar is under active development at several closed landfill sites in Australia including one owned by the City of Newcastle. There are several solar farms operating on closed landfill sites in the United States. Other sites in Europe and Japan are constructed or under development. These have ground-mounted panels similar to the design proposed by Epuron.
Developments of many other kinds have occurred on tip sites across Australia ranging from public open space to full scale urban development. In all cases, the proponents have had to comply with the relevant environmental regulations and to manage and mitigate the risks particular to that site.
In designing the solar farm and associated site management protocols, Epuron will need to demonstrate how it can manage and mitigate the risks with respect to the former South Fremantle landfill site and comply with relevant environmental conditions specific to that site.
7. 2 What risk analysis has been undertaken on the solar farm particularly with respect to its development on a contaminated site close to a residential area?
GHD, a consultancy with long involvement in the landfill’s management, was engaged by Epuron to prepare a Site Management Plan (SMP). The SMP’s purpose is to inform the design of the solar farm to avoid, mitigate and manage negative impacts and risks on surrounding residents associated with existing contamination as well as risks associated with the construction and operation of the solar farm. The SMP is a condition of the development approval and has been reviewed by a qualified contaminated sites auditor according to requirements set by the Department of Water and Environment Regulation (DWER).
7.3 Is Epuron qualified to manage the complex risks associated with the site?
order to assess and managed risks associated with the landfill site, Epuron
engaged GHD, a consultancy with long involvement in the landfill’s management, to prepare the site management plan and other documents.
7.4 What will be done to minimise site disturbance and dust, particularly in Fremantle’s windy climate and how will this be monitored and reported?
It is understood that previous redevelopment of former industrial sites adjacent to South Beach caused much concern and nuisance to surrounding residents particularly in the form of dust and potential airborne contaminants.
The development of a solar farm with structures which effectively sit on top of existing material will cause significantly less disturbance than the residential development of the 1990s and 2000s.
For further details on how dust will be managed for this project please see FAQ Section 10.0 Site management requirements.
7.5 How will risks around the potential presence of gas near high voltage equipment be managed?
Data suggests that gas levels at the site are not high in comparison to other landfill sites. Also the solar farm comprises few enclosed spaces where gas could accumulate. There is existing gas monitoring across the site and this will continue both during and after construction of the solar farm.
Nevertheless, some electrical infrastructure is likely to be housed within enclosures. Appropriate venting measures will be incorporated into design to minimise the accumulation of gas in these enclosures. Spark suppression measures to control ignition sources will also be implemented (see also Site Management Plan Sections 9.3/Table 14).
The final design shows all enclosed high voltage electrical infrastructure located a minimum 50 metres away from nearby residences on the site’s boundary.
7.6 Does solar panel reflectivity create a problem with glare? Does this affect aircraft?
Solar photovoltaic panels are designed to absorb rather than reflect light. They typically reflect less light than many other objects (e.g. water bodies, steel structures). Nevertheless, Epuron will consider reflectivity during the site development process.
Regarding aircraft, there are numerous examples of solar projects that have been installed in close proximity to airports. A comprehensive study of aviation incidents for which glare was identified as a principal cause, concluded that glare was typically found to come from bodies of water or the sun itself being low on the horizon. The South Fremantle solar farm is not be located close to an airport.
7.7 Will there be disturbance from the site?
There will be negligible noise or movement on the site once the solar farm is operational. However, there may be some disturbance during construction and a Construction Environmental Management Plan (CEMP) forms part of the site management requirements. This document contains provisions for managing and minimising dust, noise and other disturbances during construction phase.
For further details see FAQ Section 10.0 Site management requirements.
7.8 Will the panels track and does the tracking mechanism make noise?
The solar panels will be fixed in place. Use of solar tracking technologies which follow the sun's path throughout the day will not be used; but in any event, this technology is not noisy.
7.9 Could disturbance of soil be caused by rainfall, stormwater or changes to the micro-climate and wind patterns due to the presence of the solar panels?
No significant alteration to drainage characteristics of the site is proposed. Run-off from each solar panel is shed onto the ground surface and therefore will be limited and consistent across the site (that is, it is anticipated that there will be no area of concentrated runoff). Ground cover vegetation will be maintained to minimise erosion.
No specific testing of panels has occurred with respect to the micro effects of wind however any effects are anticipated to be negligible. Mitigation of the effects of windborne dust is described under FAQ Section 10.0 Site management requirements.
7.10 Will the solar farm produce electromagnetic radiation?
Exposure to electromagnetic radiation (EMR) occurs through the use of common “man-made” objects such as mobile phones, powerlines and computers. It also occurs via natural sources. The effect of EMR decreases rapidly as distance from the source increases and where materials (e.g. a wall) are present to shield the EMR.
Inverters and high voltage grid infrastructure are sources of EMR from the solar farm. This equipment will be centralised within the site, greater than 50 metres from the nearest residences. Other infrastructure will be similar in nature to a substation. Studies have shown that EMR becomes indistinguishable from the background due to other domestic sources within 5 metres of the source.
Inverter stations will conform to international standards and guidelines; known as Electromagnetic Compatibility standards. Finally, the project will connect to the existing Western Power network in the northern portion of Sandown Park or along Cockburn Road; only a short run of power-line will be constructed to achieve this.
7.11 Will there be noise emissions from the solar farm?
Operational noise emissions from the solar farm are being considered as part of its design. Inverters are the major source of potential noise and have been centralised within the site at a distance of greater than 50 metres from the nearest residences. Study work has confirmed that sound levels from solar inverters approach that of background levels at a distance of around 50 metres. Existing features such as fencing and trees, along with existing sources of ambient noise (e.g., traffic on Cockburn Rd) are expected to mitigate this further.
For further details see FAQ Section 10.0 Site management requirements.
7.12 Will the solar farm create an increase in temperatures or a bushfire risk?
Some heating of the panels themselves will occur as they are dark in colour. Any resulting heating of the air around the panel will fully dissipate or be indiscernible more than approximately one metre away from the panels.
Solar farm infrastructure will be constructed from non-combustible materials. Electrical infrastructure will be housed within enclosures with venting measures which will minimise the accumulation of gas and spark suppression measures will be implemented to control ignition sources. An internal access route will also surround the site providing a defensible setback. The site has been considered under State Planning Policy 3.7 Planning in Bushfire Prone Areas and a bushfire plan is being prepared.
7.13 Is Epuron aware that unexploded ordinance (UXO) has been found on the site and how will this be managed?
Generally the aim is to cause minimal disturbance to the site during construction. In certain areas minor ground disturbance is proposed. Where this is proposed the ground will require investigation to minimise the risk of disturbing potentially hazardous material including UXO. During operation there will be no disturbance to the site and so there will be no greater risk from UXO than currently exists.
For further details on unexpected finds protocol see FAQ Section 10.0 Site management requirements.
7.14 Are there any disease clusters associated with the landfill site?
The Site Management Plan was referred to the DWER as part of the assessment process. The DWER has conferred with the Department of Health WA (DOH). The DOH advice related to management of landfill gases. It's recommendations have been incorporated into the final Site Management Plan. DOH made no mention of concerns regarding disease clusters. You can view the DOH advice regarding the solar farm here.
7.15 Are the salt laden sea breezes likely to have a corrosive effect on structures? Is Epuron doing anything to mitigate this?
The project will be designed for a minimum 25-year useful life and this will take the effect of air corrosion into account. Numerous solar farms (and structures in general) have been constructed in similar environments. Solar panels are resistant to corrosion and structures incorporate materials that are similarly resistant, such as anodized aluminium.
8 Solar farm Business Plan
8.1 What’s a business plan?
Under the Local Government Act (1995) the City is required to prepare and seek community input on a business plan for a major land transaction. The business plan deals with the commercial aspects of the land transaction in this case a lease and the conditions of the lease. The Business Plan was advertised for 6 weeks closing 21 June 2018 and approved in September 2018.
8.2 Will the land be transferred to Epuron?
9 Approvals and conditions of approval
The development of the solar farm requires the following approvals:
- Planning approval - The City must approve the use of the land for the purpose of a solar farm. This was approved by the City in April 2018 subject to a number of conditions including environmental conditions. Click here to view the Development Approval Conditions.
- Environmental approval – in order to allow the use of the site for a solar farm, Department of Water and Environmental Regulation (DWER) approval is required. DWER approval/or not is based on the recommendations of an independent Contaminated Sites Auditor as documented in the Mandatory Auditor's Report (MAR). Click here to view the DWER approval.
- The Mandatory Auditor's Report (MAR) recommends the site suitable for the proposed use as a solar farm providing the Site Management Plan/Construction Environmental Management Plan (SMP/CEMP) is adhered to. DWER, the Department of Health (DOH) and the City of Fremantle have now accepted this advice. Click here to view the MAR.
- Business Plan – Under the Local Government Act 1995, the City is required to prepare a business plan for a major land transaction (in this case the lease) and advertise the business plan (seek community input) before finalising terms and signing the lease. The Business Plan was approved September 2018. Click here to view the Business Plan.
- DWER approval of the lease – As a registered contaminated site, DWER must approve the lease. DWER is likely to do this only if their environmental conditions are/can be met.
- Connections – Epuron must seek permission from Western Power to connect to the grid. They must connect to the grid if they are to sell the power they generate to a power retailer or any other buyer which is not an immediate neighbour.
9.2 The City has given the project planning approval. Are there any other checks and balances in place?
Planning approval for the solar farm was granted by the City of Fremantle's Planning Committee in April 2018. Planning approval does not give Epuron the ability to immediately go ahead with development. There are a number of conditions which must be satisfied prior to development commencing. Click here to view the Development Approval Conditions.
One of the conditions set by the City and the DWER requires preparation of a Site Management Plan (SMP) which must be reviewed and approved by a qualified (independent) Contaminated Sites Auditor.
The City has now received advice from the DWER and the independent accredited Contaminated Sites Auditor that the proposed details of works are satisfactory. This approval is documented in the MAR.
The City is now working through it's development application and construction conditions and requires DWER to approve the lease.
As stated by the Mayor at the council meeting on 18 April 2018: 'The City is not going to let development proceed unless it is satisfied it is safe to do so'.
9.3 Why wasn’t the project referred to the EPA?
The City and Epuron did not consider the project warranted referral to the EPA because it is already controlled and managed under the Contaminated Sites Act 2003 and the solar farm proposal will cause minimal disturbance to the site. Neither the DWER nor the EPA have requested referral.
9.4 I hear the Site Management Plan has been completed and the Auditor has reviewed it. What does the Auditor’s report say?
The Site Management Plan (SMP) has been completed and the site auditor, Senversa has reviewed it. The outcomes of this review are documented in the MAR.
The MAR Section 8.0 Auditor’s Conclusions and Recommendations states (the site is:)
"Suitable for use as solar farm or de-facto public open space as per the current land use.
The land use should be restricted to ‘solar farm’ as per the descriptions presented in the SMP (GHD 2019) or de-facto public open space as per the current land use.
The SMP (GHD 2019) should be adhered to for the development and operation of the proposed solar farm."
9.5 Can I access the Site Management Plan (SMP) and the Mandatory Auditor’s Report (MAR)?
These are available in the document library, along with other relevant documents.
A summary of key information and where to find it is provided in FAQ Section 10.0 Site management requirements.
9.6 What are the development conditions and how have these been met?
Development Approval (DA) was issued by the City on 4 April 2018. There are nine development conditions attached to the DA, many of which relate to environmental issues. Click here to view the Development Approval Conditions, which show what the development conditions require and how they will be/are being met.
9.7 Does the City still have obligations in managing the site? (See also Q 1.4)
In accordance with the Contaminated Sites Act 2003 and the 2013 Interim Site Management Plan, the City has been conducting and will continue to conduct site investigation, monitoring and management activities with the advice and support of the DWER and the DOH.
The MAR states that the City is required to undertake further assessment of groundwater to assess the risk to any off-site bore water users and the marine environment. This work is currently being procured.
The MAR also states these investigations would not preclude use of the site as a solar farm, noting that no groundwater abstraction would be allowed for the proposed development.
9.8 What documents are available, what is their purpose and how do they relate to each other?
South Fremantle Landfill Site Detailed Site Review - Document which draws together information from previous reporting to produce a ‘baseline’ understanding of the site.
DWER Contaminated Sites Database Record - Summary of records for the South Fremantle landfill site prepared by DWER as a requirement of the Contaminated Sites Act 2003.
2013 Interim Site Management Plan (GHD April 2013) - The 2013 Interim Site Management Plan sets out a programme for actions required to address data gaps to be implemented in a staged approach assuming the site remains in its current undeveloped form.
2017 Mandatory Auditors Report for the South Fremantle Landfill Site (Senversa) – Confirms appropriateness of Interim Site Management Plan and recommends further investigations.
South Fremantle Landfill Site solar farm development - Site Management Plan, GHD May 2019. The SMP is provides a framework to manage potential risks from existing contamination for the development and operation of the solar farm at the site.
Mandatory Auditor’s Report (MAR) proposed solar farm (Senversa – 28 May 2019) Confirms appropriateness of the SMP for solar farm development and recommends further investigations under the 2013 Interim Site Management Plan for ongoing City of Fremantle obligations under Contaminated Sites Act 2003.
10 Site management requirements
10.1 What does the Site Management Plan (SMP) for the solar farm development aim to achieve?
Although contaminated due to previous use as a landfill, the objectives and targets for the site’s management for the construction and ongoing use as a solar farm, have been prepared on the basis of ensuring no increase in the risk posed to people working on the site and people (residents) living off-site, than there would be if the site was left as is.
Risk thresholds and management targets for site management are set out in Section 5.1 Table 8 of the SMP.
10.2 The Site Management Plan (SMP) is quite a large document, where can I find the information I’m looking for?
The SMP provides the framework for management of the solar farm in such a way as to avoid, mitigate or otherwise manage potential negative impacts in the design, construction and ongoing use of the solar farm.
Under this framework, a Construction Environmental Management Plan (CEMP) has been prepared specifically to manage risks at the construction phase. The CEMP is provided in Appendix E of the SMP. The CEMP provides guidance to the contractor concerning the management measures it needs to implement for construction of the solar farm.
Questions below address how airborne contaminants and dust specifically will be managed.
A summary of key information and where to find it is provided below:
10.3 I’m particularly concerned about dust and airborne contaminants affecting my family during construction. How will this be prevented?
Under the framework of the SMP, the appointed Contractor is specifically required to prepare and implement a Dust Management Plan (DMP) in accordance with relevant state guidelines. The SMP and CEMP provide guidance to help the Contractor to do this. In particular:
Management of asbestos (if encountered) is set out in the CEMP section 6.13 and Table 20. This includes provisions (if encountered) such as wetting and avoiding breaking asbestos pieces which would minimise the likelihood of airborne particles occurring.
Landfill gases (e.g. methane) will be monitored during the construction process using the existing network of landfill gas monitoring bores.
At the completion of construction, ongoing landfill gas monitoring will be undertaken for an initial period of three months (fortnightly monitoring). After the initial three months, monitoring will be undertaken once per month for a period of nine months to verify that the SMP has been implemented appropriately.
10.4 How will you monitor to ensure there is no increase in dust and airborne contaminants during construction?
Prior to any work occurring at the Site, the contractor will conduct a risk assessment in accordance with relevant state guidelines and undertake a baseline air quality check prior to the commencement of works which will determine the specific requirements for monitoring and placement of dust monitors.
The Contractor will prepare a site-specific Dust Management Plan (DMP) using the SMP and CEMP for guidance. The DMP will detail all of the dust and air quality monitoring requirements during construction. The City will make this available on its website.
Dust levels will be monitored through the construction process. Automated alarms will be fitted which will directly alert the Contractor if a dust particulate exceedance occurs so that appropriate action in accordance with the DMP can be undertaken.
The Contractor is also required as a minimum, to undertake boundary air monitoring for asbestos fibres during any activity which could potentially generate airborne asbestos fibres.
The Contractor will be required to report on dust monitoring weekly and these reports will be made publically available
10.5 What should I do if I believe contamination has affected my property?
Section 10 of the SMP sets out contingency response measures to deal with unexpected situations that could occur during the management of the site, and to specify procedures that can be implemented to manage such situations and prevent adverse impacts to human health and the environment.
All complaints should be directed to the Principal’s nominated representative in the first instance (refer to Section 10.2.1). Contact details will be available on the City’s website and on site signage once the contract has been let.
On receiving a complaint, the Principal shall investigate to make observations and seek to determine the source/cause of what has been identified.
The auditor’s role is to audit the implementation of the SMP/CEMP and report on its compliance to the Department of Water and Environmental Regulation (DWER). The auditor will maintain an ongoing role in reviewing documentation related to the implementation of the SMP during the construction and operation of the solar farm.
10.6 Does the City have any obligations under the SMP?
In accordance with the Contaminated Sites Act 2003 and the 2013 Interim Site Management Plan, the City has been conducting and will continue to conduct site investigation, monitoring and management activities with the advice and support of the DWER and the Department of Health.
The 2013 Interim Site Management Plan prioritised monitoring of landfill gas. The risk assessment documented in the 2017 Mandatory Auditors Report concluded that landfill gas was unlikely to pose a risk to off-site receptors while the site is in its current, undeveloped, land use. However further groundwater assessment is required.
The 2019 Mandatory Auditor’s Report (MAR) also states that the City is required to undertake further assessment of groundwater to assess the risk to any off-site bore water users and the marine environment. This work is currently being procured.
The 2019 MAR for the solar farm states that these risk will not change through development of the solar farm.
11.1 Where to from here?
Based on the Auditors report, the Site Management Plan (SMP) has now been approved by the Department of Water and Environmental Regulation (DWER). The City has had considerable input into the preparation of the SMP however it would not sign off the conditions of the Development Approval which relate to the SMP until/unless the DWER had issued its approval. Now DWER approval has been received, the city is working with Epuron to proceed in clearing the remaining DA conditions. Click here to view the remaining Development Approval Conditions.
DWER has issued its approval and (once any required changes have been made) the City will arrange information sessions for the community where it (and Epuron) can explain the management measures and answer any questions that might arise.
In the meantime the Site Management Plan and the Mandatory Auditor’s report are available in the document library.
See FAQ section 10.0 Site management requirements to help explain the site management measures therein including cross references to the document itself.
Meanwhile the lease is being finalised and Epuron is working with potential customers to cement a Power Purchasing Agreement (PPA.)
Once Epuron has a PPA in place it can confidently proceed to signing the lease and issuing construction contracts late in 2019. It is important to note that construction contracts will include detailed design and ordering of equipment, and it will be a number of months after contracts are let before there is activity on-site. Completion will be in the second half of 2020.
The contractor will need to produce a dust management plan and contact protocols (in line with the SMP/Construction Environmental Management Plan [CEMP]) prior to issue of the building permit.
11.2 How will Epuron be held to account for the site management conditions?
The SMP/CEMP defines how the site is to be managed or monitored to ensure the risks from contamination remain at an acceptable level. DWER require a statement from Epuron acknowledging awareness of the SMP, agreeing to its content and agreeing to abide by it.
Epuron and its contractors must comply with all conditions or work will be stopped.
11.3 When will the solar farm be completed?
Assuming construction contracts are let in late 2019, activity will commence on site in the first half of 2020. Completion will be in the second half of 2020.
It is important to note that construction contracts will include detailed design and ordering of equipment, and it will be a number of months after contracts are let before there is activity on-site.
11.4 Who will manage the site before approvals are issued?
With or without a solar farm, the City will continue monitoring and management activities in accordance with its obligations as a landowner under the Contaminated Sites Act 2003.