FAQ

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 also contains 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.

Click here to access the 2013 Interim Site Management Plan

Click here to access the 2017 Mandatory Auditors Report (2017 MAR)

2.1  Could the rest of the landfill site be used for other purposes?

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?

3.1  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?

4.1 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.

5.1  Would the City buy the power?

A 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.

6.1  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.

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?

In 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.

8.1  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.

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)?

Click here to view the Site Management Plan (SMP) 

Click here to view 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.

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.

11.3  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.

12.1  What is the process the Council proposes to engage in with the solar farm contractor?

The City will walk through construction methodology and construction and dust management plans (CMP/DMP) before issuing a building permit.  This will include, construction methods allowing panels sit on top of the site without disturbing ground, procedures for placing site anchors and fence posts (if required) and arrangements for briefing the community on the agreed management practices.

12.2  How will the City ensure the contractor works to ensure that no negative outcomes occur as part of the solar farm work on this site?

The City will engage an independent expert to provide oversight of the process.  The City is currently looking into who could do this.  We will also work with the City of Cockburn to ensure construction, dust and site management protocols are adhered to. 

12.3  A robust site-specific Dust Management Plan (DMP) is to be prepared and implemented by the contractor (as identified in Section 5.4.7 of the CEMP). Please explain the term “robust site specific DMP”. 

As mentioned under Question #1 a DMP is yet to be developed but the framework is set out in the SMP and CEMP.  For example, see Section 6.3 of the CEMP which includes a performance target stating “dust generation is not detectable at the boundaries above background levels during the construction works”.  Table 10 of the CEMP sets out various measures to address this. 

12.4  There is supposed to be a sand cap so why can I see things like old tyres poking through the surface?

In a recent (2019) review, GHD estimated an average (sand) cap thickness of 1.0 m over landfill waste at the Sandown Park area. The sand cap contains inclusions of refuse material which can become exposed at surface over time (such as building rubble, tyres, and possible ACM). In some instances, materials at surface may also have been due to historic illegal dumping during or after the sand cap was placed. As identified in the site management plan (SMP), significant disturbance of existing soil is not proposed to facilitate the solar farm redevelopment and the SMP includes management measures for minor disturbance below ground level which is proposed to be limited to the sand cap. 

12.5  If ground preparation work is not required, why is the term ‘excavation’ used in the site management documents?

The earthworks plan states the site will not be regraded or cleared and existing tracks will be used.  The term “excavation” in the SMP and CEMP is intended to cover very limited / shallow activities such as creating shallow holes for fence posts.

See also Question 6.1 which describes how construction could occur with minimal disturbance to the site  Further detail will be worked out once a contractor has been appointed.  The Concept Earthworks Plan can be found at appendix B of the CEMP, (at the end of the SMP).

Disturbance below ground level is proposed to be limited to the sand cap and will predominantly be associated with lateral ‘displacement’ (rather than open excavations, such as in the form of an open trench or pit). Lateral displacement will be undertaken during the installation of driven fence posts and for installation of ground screws for the solar array. Shallow, limited excavations will be undertaken during:

• Installation of oil containment area (lined gravel pit) below transformers (0.5 mBGL)

• Installation of high voltage underground power lines (0.85 mBGL to 1.2 mBGL). Backfill will comprise clean sand.

These excavations are not considered to present a management issue with respect to landfill gas and/or vapour; however, appropriate soil management will be required particularly in the event of unexpected finds such as fragments of bonded, non-friable asbestos-containing material [ACM]. In the event that such materials are encountered during ground disturbance, this will be managed in accordance with the Contingency Plan, Section 10 of the SMP.

12.6 What training/induction will contractor personnel receive and how will we ensure any fill in people get the same training?

The Contractor is required by the CEMP (Sections 6, 7 and 8) to provide training to all personnel, including any subcontractors as part of the site induction process. The training will include environmental management of the works to orientate personnel to the work areas and to explain the requirements of the CEMP. The CEMP requires the Contractor to maintain registers of personnel induction and associated training.

12.7  How will residents/community be informed if dust alarms go off and/or on site air quality monitors – indicate that toxicity levels are exceeded?

Residents will be informed via the contingency plan in Section 10 of the SMP. In the first instance, notification for any incidents, exceedances and other relevant matters will be undertaken directly by Epuron as identified in Section 10.9 of the SMP. Mechanisms for informing local residents could vary depending upon the information that needs to be communicated. The mechanisms used may include (but are not limited to) door knocking, advising residents of sampling results and community consultation sessions (as identified in Table 9 of the SMP).

Specifically in relation to dust alarms, further details will be detailed in the Dust Management Plan (to be prepared by the appointed Contractor using the requirements identified in the SMP and CEMP as a framework for developing the plan). Other triggers for contingency responses, including informing local residents and other third parties are also addressed in Section 10.

Once the contractor is appointed we can go through this with residents at the community briefing.

12.8  Is there an evacuation plan for residents if this occurs?

For the scale of development work to be implemented under the SMP, the risk profile of the Site is not expected to increase such that evacuation of residents would be necessary. The DWER and the Independent site Auditor have approved the management measures identified in the SMP (and CEMP for the construction phase) as appropriate and proportionate to the circumstances of the Site and scale of development works to be implemented.

With respect to dust management, further information concerning the specifics of dust management measures will be detailed in the Dust Management Plan (to be prepared by the appointed Contractor using the requirements identified in the SMP and CEMP as a framework for developing the plan).

12.9  Can the current testing/monitoring results be made public? 

In accordance with the Contaminated Sites Act (2003) (the Act) 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 Interim Site Management Plan prioritised monitoring of landfill gas. The latest risk assessment, documented in the Mandatory Auditors Report (2017) concluded that landfill gas was unlikely to pose a risk to off-site receptors while the site is in its current, undeveloped, land use.

The MAR August 2017 conclusions are based on the 2016 Offsite Landfill Gas and Vapour Investigations conducted by GHD and issued in March 2017. This report is available at the link above and in the document library. Please note before downloading that the report has been compressed but is still over 50MB.

The MAR August 2017 also recommended the City undertake further groundwater assessment and this work is currently being procured.

Management of Landfill gas and vapours in relations to the Solar Farm can be found in the CEMP Section 6.2 & Table 8.

12.10  Can trees be planted along the boundary as a visual screen?

Planting trees is unlikely to be approved because it would require excavation and disturbance of contaminated material to enable planting.  In any event, there is no water available to aid the establishment of young tress.  In addition trees could also shade solar panels and may contribute to fire risk.

12.11  What will keep asbestos containing materials (ACM) and other toxins controlled and avoid them getting airborne throughout the lease period (after ground leveling and removal of "limited vegetation")?

The solar farm has been designed to ensure minimal ground disturbance. Disturbance below ground level is intended to be limited to the sand cap. As described above, once the contractor is appointed we can determine specific construction methodologies and dust management activities. This may include, re-seeding and (seeded) hydro mulching.

In the areas where the limited ground disturbance is proposed, at a minimum stabilisation using approved hydromulch of completed earth worked areas is a requirement of the SMP (Section 8.2).

12.12  If workers are required to wear personal Protective Equipment (PPE) are there also special requirements for residents?  (PPE could include: safety boots, high-vis long sleeved shirts, masks, suits or respirators)

Table 20 in the Construction Site Environment management Plan (CEMP) states PPE may be required for workers (only) if they encounter potential asbestos containing material.  This would only be necessary for those in close proximity to or handling material.  We will confirm the detail of this once the contractor is appointed.

The contractor is also required to prepare an Asbestos Removal Control Plan (ARCP) to demonstrate how they will appropriately manage potential asbestos disturbance in soil during land disturbing work.

The contractor will be required to implement all measures necessary to effectively control all dust and windborne material emanating from the site to prevent it from being blown over or onto property outside the Site and develop a site-specific Dust Management Plan using the requirements identified in the SMP as a framework for developing the plan.

12.13  How will ongoing air quality monitoring be communicated to nearby residents and the wider community?

Mechanisms for informing local residents and others could vary depending upon the information that needs to be communicated. The mechanisms used may include (but are not limited to) door knocking, advising residents of sampling results and community consultation sessions (as identified in Table 9 of the SMP).

This will be determined in conjunction with the contractor and documented in the Dust Management Plan.

Once the contractor is appointed we can go through this with residents at the community briefing.

12.14  Please explain the term “stockpiles”.

These are the areas shown in Figure 2 of the SMP, east of the earth bund. We understand these are inert building materials and would be tested if required in accordance with site sampling protocols.

12.15  Section 8.2.3 of CEMP (SMP Appendix E) states - at a minimum, boundary air monitoring for asbestos fibres will be performed at regular intervals over the duration of the construction program (e.g. one day/month). 

As mentioned above, a DMP will be developed, and monitoring requirements will be determined in conjunction with the contractor.  Daily asbestos fibre monitoring and continuous monitoring for dust particulate matter (PM) can be undertaken during land disturbing activities; requirements for dust monitoring will be determined in conjunction with the appointed contractor and documented in the DMP.

12.16  The terrain at the site varies enormously, will we have panels sticking up above our boundary wall? 

The panels will sit on the low ground surrounded by the earth bund – which will remain untouched.  There will be no panels on top of the bund, which forms the high points of the site.

12.17  Please could you provide information on the risks associated with quarantine waste on the site?

Land disturbance associated with the solar farm development is not intended to disturb the landfill waste mass beneath the sand cap. All land disturbing activities associated with the solar farm will be limited to the overlying sand cap. In the event that inclusions of refuse material are encountered within the sand cap, these will be managed in accordance with the Contingency Plan in the SMP (Section 10).

Department of Health has expressed a view that even if excavation significantly disturbed the material, there is little or no risk of community exposure to pathogens from waste that was buried many years ago.

Notwithstanding Epuron will update the SMP to more clarify references to quarantine waste. 

12.18  How is an Appropriate Level of Protection (ALOP) against biosecurity risks, as stipulated by the Biosecurity Act 2015 to be ensured and would disturbance of the site be a Reportable Biosecurity Incident under Biosecurity Determination 2016?

Department of Health has expressed a view that even if excavation significantly disturbed the material, there is little or no risk of community exposure to pathogens from waste that was buried many years ago. 

Notwithstanding the City is checking whether there are any outstanding actions required to comply with these requirements.

(December 2019 update) The City has also checked with the federal Department of Agriculture regarding any obligations under the above legislation. The Department has confirmed that the site is not subject to Approved Arrangements site provisions under the Biosecurity Act 2015. The Department has stated that it will work with the Western Australian Department of Water and Environmental Regulation and the City of Fremantle in relation to this matter.

12.19  Should there be signage on site boundaries and entry points denoting the SFLS as a contaminated site (including quarantine waste)?

Signs are present at entry points. The signs are worded as follows:

This area is the site of the former South Fremantle Landfill Operation and is a RESTRICTED SITE.  The site contains waste material from households and industry. The area is not suitable for general use. Do not walk across the site. Do not dig, or remove any material from the site. Use only the footpaths, or designated walkways to cross the area.

12.20  Is there a glint and glare assessment? 

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). 

To demonstrate this, 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 most typically glare was found to come from bodies of water or the sun itself being low on the horizon.

Nevertheless, Epuron will explore the matter further.

12.21  There is a chance of methane gas leaking from various sides of the proposed site due to excavation, how will this be managed?

In relation to potential for increase in methane gas, the solar farm is essentially a light-weight form of development and therefore is unlikely to significantly influence surface venting of gases and vapours, as the proposed development does not comprise the introduction of a significant number of buildings (limited to the switchroom on eastern boundary), underground infrastructure (limited to high voltage power lines from the switchroom to the transformers) and/or hardstand areas/low permeability surfacing. The deployment of the solar farm arrays include voids for airflow beneath each unit; therefore, the enhancement of gas migration as a result of the deployment is not anticipated (i.e. in the absence of introducing low permeability surfacing).

Due to these characteristics, the risk profile of the Site is not expected to materially alter as a result of low sensitivity solar farm development.

12.22  The contents of site are largely unknown, so how can risks be managed?

The contents of the landfill have been determined to an extent which is sufficient for decision-making concerning requirements for management. Land disturbance associated with the solar farm development is not intended to disturb the landfill waste mass beneath the sand cap. All land disturbing activities associated with the solar farm is proposed to be limited to the overlying sand cap.

12.23  Why is there no Impact Assessment Report?

Previous assessment reports and the current SMP and CEMP have been reviewed and endorsed by an independent accredited Contaminated Sites Auditor and accepted by DWER and DoH to support the proposed development. No separate impact assessment report is required.

12.24  This is a City of Fremantle project but it affects many City of Cockburn residents; how will Cockburn residents be consulted?

Throughout the project, updates have been made available to the broader community through the local media (which reaches into City of Cockburn) and the City of Fremantle’s website.

The development application was made available for community comment by:

• letters to owners/occupiers of properties in both 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 – also distributed in the City of Cockburn.
• Notification to the South Fremantle Precinct Group
• Notification on the City of Fremantle website

A community information session was held in Fremantle Town Hall on 1 March 2018.  This was advertised on the City’s website and in the Fremantle Herald as well as notice given in the letter box drop (mentioned above) which included nearby Cockburn residents. 

The City also provided a briefing to a meeting of the South Beach Community group many of whom were also Cockburn residents.

Additionally the City updated this Frequently Asked Questions document to address issues raised during the community consultation period. Notifications of any updates to the website, including the FAQs, go to anyone who has registered on the My Say website.  Many City of Cockburn residents have registered for information in this way.

The City has also been liaising with City of Cockburn officers and councillors and will continue to do so during the course of the project.

All further updates and notification of future community information sessions will be provided through local media, letter box drop and the website as above.  Cockburn officers will also be notified so they can pass on information.

12.25  Could the project be relocated to a less contaminated site?

In 2014 the City called for expressions of interest for construction of a solar farm on the South Fremantle landfill site.  The aim was to explore if this would be a feasible way to activate a site which currently has very limited practical applications.

Epuron was engaged by the City of Fremantle in an exclusive working agreement to explore the solar farm idea specifically as a potential use for that site.