community and

stakeholder
engagement
findings Summary
Proposal to treat and reuse soil
from the West Gate Tunnel Project

HI-QUALITY GROUP 1 JULY 2020

Prepared by i.e. community for Hi-Quality Group

PURPOSE
This document is a summary of Hi-Quality's Community and Stakeholder Engagement Findings Report that
was provided to the Minister for Planning's office in July 2020. It provides a summary of the engagement
program undertaken by i.e. community on behalf of Hi-Quality Group on the proposal to treat and reuse spoil
from the West Gate Tunnel Project (the Project) at the Sunbury Waste Management Facility located at 570-650
Sunbury Road Bulla. 

To read Hi-Quality's responses to the key community concerns, please see the Closing the Loop: Community
Feedback.

OVERVIEW
This phase of engagement was undertaken from March 2020 to May 2020. We received contributions via an
online survey, questions posted to the online engagement hub and conversations via the project phone line
and email. We also held detailed briefings and had ongoing conversations with community organisations,
property developers and regulatory authorities to provide information, capture concerns and answer
questions. The engagement was supported by a communication campaign, including a letterbox drop,
newspaper and online advertising, and outreach to community groups.

The purpose of the engagement was to understand and respond to community and stakeholder views on the
proposal. This information was then summarised and provided to the Minister for Planning's office for their
reference as they review the proposal.

The process was adapted in response to COVID-19 social distancing requirements and stakeholder needs.
Activities that would have been held face-to-face under normal circumstances were conducted online, over the
phone, or via video conference.

As well as providing insights into community views on the proposal, the engagement found significant concern
and confusion in the community surrounding the West Gate Tunnel Project and the Hi-Quality proposal. Much
of this is being driven by misinformation in the public sphere. It is also the result of conflicting narratives about
potential impacts of the proposal from advocates, including the West Gate Tunnel Project and Transurban, and
from those who oppose the proposal. Many people we spoke to don’t know who to believe.

There are significant concerns about potential impacts on the local community and environment, largely
relating to fears of PFAS contamination. More broadly, opposition to the proposal is driven by confusion
between Hi-Quality and the nearby Bulla Tip and Quarry, along with concerns about rapid development in the
region and the loss of rural character.

While concerns were raised about the extent of the engagement on the proposal, many people we spoke to
appreciated the opportunity to speak to the team in detail about the proposal and have their questions
answered, often leading to ongoing dialogue. While not necessarily supporting the proposal, we found that
once people understood what Hi-Quality is proposing, they were generally less concerned about potential
impacts to the community.

Engagement has been ongoing since May 2020, and the Q&A section of the online engagement hub site and
project phone line remain open. We encourage anyone with questions about the proposal to reach out at any
time.

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ENGAGEMENT PROCESS
HOW WE ENGAGED
Stakeholder engagement

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When: 26 March - 22 May (2020)

Who: Stakeholders including adjacent landowners and

businesses, developers, community groups, local
government, regulatory and statutory authorities.
INTERACTIONS
How: Phone conversations, emails, briefings and
submissions

Online calls and briefings were held with stakeholder groups including adjacent landowners and businesses,
developers, community groups, local government, regulatory and statutory authorities. These briefings were
an opportunity to engage in an in-depth conversation about the proposal, understand concerns and address
any questions.

Online engagement

When: 29 April - 22 May (2020)

Who: Residents, property owners and all interested

parties
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CONTRIBUTIONS
How: Online survey and Q&A 

We set up an online engagement hub to let all residents, property and business owners in the local area
have their say via a survey or Q&A. The hub is still open and we want anyone with thoughts about the
proposal to be able to provide feedback and have their questions answered.

Project phone line

When: 29 April - 22 May (2020)

Who: Local residents 

How: Phone conversations

8CONVERSATIONS
a phone line was established to provide another way for the community to share feedback and discuss
the proposal. Interested parties could call the phone line, leave a message with their details, and receive
a call back within three business days. The phone line remains open.

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PROMOTING THE ENGAGEMENT
To raise awareness and encourage participation, the following activity was undertaken:

Newspaper advertising Project postcard and letterbox drop

Ads promoting the engagement were Approximately 2,000 postcards were

in the Sunbury & Macedon Ranges delivered to properties in a 2.5km
Star Weekly over two issues and radius of the Eco-Hub, as well as to
online. residences in parts of Sunbury and
Bulla closest to Hi-Quality.

Direct outreach
All the stakeholders and groups
we had briefings with were
encouraged to promote the
project through their networks.

ENGAGEMENT MATERIALS AND RESOURCES

The Hi-Quality team aims to provide the community and stakeholders with detailed, up to date
information about the proposal. To support this, the following materials and resources were produced:

Online engagement hub Proposal website

An interactive site was developed to
be the main hub for online Providing information about the project,
engagement. It contains the online including frequently asked questions
survey, Q&A tool, information about (FAQs), fact sheet, infographic and
the proposal and an option to sign directions to the online engagement
up to receive updates. hub.

Briefing presentation Factsheet and detailed FAQs

Providing an overview of the proposal,

A comprehensive presentation about responses to anticipated questions and
the proposal used in briefings with all concerns, and contact details for the
interested stakeholders. online engagement hub and phone line.

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KEY FINDINGS
The engagement identified a range of concerns about the proposal, largely driven by fears around potential
impacts of PFAS contamination on the local community and environment. It also identified issues relating to
the operation of a major waste treatment facility in a growing urban area.

Based on the feedback provided by Hi-Quality through the engagement process, the majority of issues raised
have been taken into account in the design of the proposal. Community members and stakeholders with an
existing relationship with Hi-Quality have a more favourable view of the proposal than those who are
unfamiliar with the company and the Sunbury operation. This reflects Hi-Quality’s strong reputation and
commitment to building local relationships.

As expected, we saw the level of concern grow through the engagement period as people became more
aware of the proposal, particularly through media coverage and discussion on social media. However, the
level of concern in the Sunbury and Bulla communities has not reached the levels seen in relation to the
proposal for Bacchus Marsh.

Across all activities, a number of key themes emerged as outlined below.

Community impact
Concerns around the impact of the proposal on people’s health and quality of life in the
area. These concerns largely relate to fears around PFAS, along with the impacts of
construction and operation of a major new industrial site in the area. There are
concerns that the proposal will negatively impact property values and generally impact
the highly valued rural character of Sunbury and Bulla.

Roads and transport

The local road network is considered congested and unsafe, and there are significant
concerns that additional traffic generated by the proposal will make things worse.
Concerns include the proposed route, increase in truck movements, safe transport of
contaminated soil and the safety and cleanliness of local roads more generally.
Sunbury Road and Bulla Bridge are of particular concern.

Environmental impact
Potential impacts on the natural environment, particularly concerns about PFAS
contamination of groundwater and waterways, are of major concern. Stakeholders and
the community are seeking reassurance, from independent sources, that the local
environment will not be put at risk by the proposal.

Handling of PFAS
The details of how PFAS would be transported, treated, stored and disposed of are of
major interest to the community. Given concerns raised in the media and on social
media, many in the community are doubtful that PFAS can be handled safely and
would prefer the contaminated material was treated elsewhere.

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 Future development
Many of the people we engaged struggled to understand how a proposal of this nature
could be considered given the increase in residential development in the area. An
understanding that Hi-Quality has been safely treating contaminated materials at the
site for more than 10 years went some way to addressing these concerns. Local
property owners, particularly residential developers, are concerned about the impact
on property values and their ability to sell their land.

Transparency and engagement

The need for transparency and the engagement process are also common concerns
raised, particularly via online channels. There is a clear view that more needs to be
done by all parties, including the State Government and the West Gate Tunnel Project,
to inform the community about the proposal, provide independent evidence and
respond to community concerns.

In addition to specific concerns about the proposal, a number of key factors driving the response to the
proposal were identified.

Confusion with Bulla Tip & Quarry (BTQ)

The confusion between the two sites, both being waste management facilities on
Sunbury Road, is a major factor driving concern around the Hi-Quality proposal. Many
in the community believe that Bulla Tip & Quarry, rather than Hi-Quality, is behind the
proposal to accept contaminated waste and are concerned a facility with such a
checkered environmental record could even be considered.

Community concerns from other sites

The level of concern and media coverage related to the Bacchus Marsh proposal is a
major factor in influencing the concerns of the Sunbury and Bulla communities. While
Hi-Quality was able to address some concerns by explaining the difference in the two
proposals, the opposition in Bacchus Marsh is seen as an indicator that there are major
risks associated with the proposal.

Not being able to tell between fact and fiction

With conflicting messages about the safety of the proposal, people are fearing the
worst or are struggling to know what to make of it. There is strong demand for the
release of technical reports and the independent verification of the level of PFAS
contamination.

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WHO WE HEARD FROM
We engaged with stakeholders representing the following groups:

Community and business groups

Emergency services
Local Government
Local property owners and businesses
Local residents and property owners
Property developers
State Government and statutory authorities
Traditional Owners.

Engagement with the wider Sunbury and Bulla community was undertaken via an online engagement hub.
Most of the people who responded to the survey are local residents, and we also heard from local property
owners (7 percent) and business owners (3 percent).

Localresident
Local resident

Localbusiness
Local business owner
owner

Localproperty
Local property owner
owner

Member
Member of general
of the the general
public public

Other
Other

There was also a great balance in the age and gender of people who provided feedback.

Under
Under 25 25

25-34
25-34
Male
Male
35-44
35-44
Female
Female
45-54
45-54
AAdifferent
different identity
identity
55-65
55-65

Over
Over 6565

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QUESTIONS AND ANSWERS
Across all engagement activities similar questions were asked repeatedly. The most frequently asked questions
and the answers are provided below.

Why does the soil need to come to Sunbury? Why can’t it go to a remote location?

The reason the site is being considered is because it is one of only a small number of locations in Victoria
that can safely handle contaminated soil and has been identified by the State Government as a key site for
the treatment and disposal of soil for major infrastructure projects, such as the Metro Tunnel and West
Gate Tunnel.

Hi-Quality has been operating the Sunbury Eco-Hub as a major quarry, landfill and resource recovery facility
since 2003 and has all the required EPA licences. The site’s operations include wide buffer zones to ensure
minimal impact to neighbouring properties.

How can you be considering bringing it to Sunbury?

The Hi-Quality Sunbury Eco-Hub occupies a large landholding of more than 348 hectares, and the site is
largely surrounded by farms and bushland.

It is approximately five kilometres from the Sunbury town centre and more than two kilometres from the
nearest existing residential community. Future development will need to comply with the existing 500
metre buffer between the landfill and residences.

What about the proximity to nearby developments?

While there is a lot of development planned for the area, this has been planned with the full knowledge that
the Eco-Hub will continue operating on the site for decades to come.

The Eco-Hub site sits within the Sunbury South Precinct Structure Plan, which means it is likely that
residential areas will be developed closer to the site over time. However, the site’s operations incorporate
wide buffer zones to ensure minimal impact to neighbouring land users.

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With housing development and urban growth getting closer to the area, what are the potential risks to
people moving into those areas in the future?

While there is a lot of development planned for the area, this has been planned with the full knowledge that
the Eco-Hub will continue operating on the site for decades to come. The site's operations incorporate wide
buffer zones to ensure minimal impact to neighbouring land users.

The long-term plans for the Eco-Hub includes industrial and employment use, and Hi-Quality’s owners have
land surrounding the site earmarked for residential development in the future. To protect the surrounding
community and these long-term plans, Hi-Quality has put forward a robust solution to the treatment of the
contaminated soil.

If you're interested to know more about the plans, take a look at the Sunbury South Precinct Structure Plan
here: https://vpa.vic.gov.au/project/sunbury-south.

How can you consider taking the soil, you already have piles of rubbish and smells contaminating the
district?

We think you may be confusing our site with Bulla Tip and Quarry at 500 Sunbury Road, which is a
completely separate waste facility with different owners.

The Sunbury Eco-Hub's operations are not visible from Sunbury Road, based down alongside the quarry,
and we have been operating without any significant visual or environmental impacts since 2003.

What is the contaminant in the soil?

PFAS, or Per- and poly-fluoroalkyl substances are a group of synthetic chemicals that are resistant to heat,
water, and oil. Testing at the West Gate Tunnel site has shown low levels of PFAS contamination in some of
the excavated soil which is why it needs to be transported to be tested and safely processed.

We understand community concerns in relation to PFAS, however, based on tests done to date, the levels of
PFAS in the material from the tunnel boring machines is extremely low.

I live near the site with my family. Can you offer some kind of guarantee that our health will not be
impacted by having PFAS so close to our home?

We understand your concerns. The Victorian Government takes a conservative, safety-focussed approach to
managing contaminants such as PFAS. The fact that PFAS has been detected in the soil, even at such low
levels, means that it needs to be tested as it comes out of the tunnel to confirm if it is contaminated and, if
so, at what levels.

The volume of soil produced by the tunnel boring machines is so great that it needs to be taken elsewhere
for testing and to be treated safely. To a large extent, the proposal put forward by Hi-Quality is a holding
and testing facility, followed by treatment to remove the PFAS.

The soil coming from the tunnel will be very wet and the PFAS is contained in the water, rather than the soil
itself. Our proposed solution involves the safe storage of the wet soil in specially designed containment
bays from which the water will be extracted and put through a purpose built water treatment plant to
remove all the PFAS.

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 All studies undertaken to date show that the storage and reuse of the soil will not cause any significant
impact or leave any detrimental environmental legacy, either onsite or to the local community.

What happens to the remaining PFAS once the spoil has been treated?

Once the soil has been treated, it will be tested and evaluated against the Hi-Quality Landfill Licence. If the
results indicate the remaining material is within our approved levels, the waste will be contained in the EPA
Licensed Landfill onsite. The remaining PFAS and any soil that is not able to be contained at the Hi-Quality
facility will be transported to a facility approved to handle the material.

Is Hi-Quality already receiving trucks containing contaminated soil? If so, how are you storing the soil as
the containment facility has not been built yet?

Hi-Quality has been operating the Sunbury Eco-Hub as a major quarry, landfill and resource recovery facility
since 2003. The existing facility includes purpose-built landfill cells to store contaminated waste, including
soil with low-levels of PFAS contamination.

In our discussions with community members and stakeholders about the current proposal, we have been
open about the fact that we have been accepting contaminated soil from the West Gate Tunnel project for
more than 12 months in our existing facility. This soil has come from other works as part of the project,
such as road widening, and not from the tunnel boring machines, which is the subject of the current
proposal.

The reason the containment bays are required for the soil from the tunnel boring machines, is because the
soil will be wet (approximately 40 to 50% moisture content) and needs to be stored, tested and treated
before re-use or disposal. As the PFAS is contained in the water, rather than the soil itself, our proposal
involves the safe storage of the wet soil in specially designed containment bays from which the water will be
extracted and put through a purpose built water treatment plant to remove all the PFAS. These bays will
also capture any surface water run-off, preventing it from entering waterways and ensuring it is processed
through the water treatment plant.

How are the PFAS materials going to be contained on the site to prevent leaching into the surrounding
soil and groundwater?

The protection of waterways and groundwater has been one of the key issues we have considered in
designing our proposed solution.

We will use specially constructed soil containment bays to control seepage to the underlying groundwater.
These bays are made of high-strength materials with a leach-proof lining to capture any surface run-off,
preventing it from entering waterways. The lining system design for the containment bays and all other
areas are designed to the highest environmental standards. These bays will also capture any surface water
run-off, preventing it from entering waterways and ensuring it is processed through the water treatment
plant.

We have undertaken detailed environmental impact reviews which showed storage and reuse will not leave
any detrimental environmental legacy, either on site or to the local community. The Hi-Quality
Environmental Management Plan also requires regular testing on Emu Creek both upstream and
downstream, in accordance with EPA verification and approval, to ensure that no leaching occurs.

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How will stop the airborne spread of the soil on windy days?

The soil will have a consistency of sludge when it arrives on the site, with 40-50% moisture content. While
the risk of airborne dust is considered extremely low, measures will be taken to control dust at all times.

What will be the increase in truck traffic? How will you manage this increase in truck traffic on local
roads?

It’s estimated that there will be an average of around 15 trucks per hour travelling to the site during peak
periods, around 350 a day. While the facility operates 24 hours a day, the trucks are likely to be less
frequent during peak periods to reduce impact on traffic.

To improve safety, traffic lights will be installed at the entrance to the site and the planned speed reduction
on Sunbury Road to 80km an hour will be introduced.

What is the proposed truck route?

The trucks will travel along approved arterial roads as assessed and agreed by VicRoads. The primary route
is likely to be via the M2 Tullamarine Freeway and C743 Sunbury Road.

There are already too many trucks on Sunbury Road. How will you manage the increase in trucks and
ensure safety of commuters?

While the facility to treat the West Gate Tunnel soil is operating, there will be an increase in the number of
trucks traveling to and from the site on Sunbury Road. At the entrance to the site new traffic lights will be
installed and truck trips distributed to reduce trips at peak periods. This will help minimise any impacts of
increased truck movements and improve safety.

We understand that truck movements will be monitored by the West Gate Tunnel Project, drivers will be
fully trained and GPS technology in the trucks will allow driver behaviour to be monitored to ensure truck
routes are adhered to.

How will you ensure that the roads from the facility are clean and not covered with dirt and hazardous
materials?

While VicRoads is responsible for maintaining Sunbury Road and the roadside, we understand how
important it is that trucks are as clean as possible when leaving the site. We have put a number of measures
in place, including truck cleaning, installing a wheel-wash and sealing 1 kilometre of roads within the site.

All trucks that transport soil from the West Gate Tunnel Project worksites are fully covered so that no dust
or soil is dropped along transport routes to the waste management facility. Other safety measures include
hosing down the truck and its wheels before it leaves the site and loading the truck in an enclosed shed.

We understand that all relevant EPA Victoria and WorkSafe Victoria requirements will be met during
transportation to protect the community and workers from any risk of exposure. More information on the
measures the West Gate Tunnel Project is taking to safely transport soil can be found here:
ttps://westgatetunnelproject.vic.gov.au/construction/soil-management/fact-sheet

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When will a decision be made if the soil will be going to Sunbury?

Hi-Quality will be preparing a draft planning scheme amendment in next month or two. We will then need
to wait for the Minister for Planning to make a decision and for the West Gate Tunnel Project contractors to
award the tender. We expect a decision in the next couple of months.

Does Hi-Quality have the necessary licences for the project?

Hi-Quality requires EPA approvals for the testing and drainage area, containment bays, water treatment
plant and disposal of Non-Prescribed Industrial Waste.

We will use our existing Landfill and Prescribed Industrial Waste Licence for the project. Once the waste has
been treated, if the levels of contamination are allowable within Hi-Quality's current licence, then it will
remain onsite and no additional licences or permits will be required.

Based on tests done to date, the levels of PFAS in the material are extremely low and fall within our current
EPA Victoria licence. We have been safely managing contaminated waste under this licence since 2003.

How can the public support this proposal if basic environmental measures, which are detailed in the
Environment Management Plan (EMP) and technical studies remain secret?

It's a fair question, we understand there are concerns about potential impacts to the environment and why
you are seeking reassurance that our proposal is sound. The reality of the situation is that we are in the
middle of a tender process and our proposal and supporting technical reports are not public documents at
this stage.

If you would like to know more about the anticipated levels of PFAS for the project, please visit the West
Gate Tunnel Project's website using the link below, where you can find more information about the
projected levels of PFAS compared to national health and safety guidelines and an explanation from Dr
Jackie Wright from environmental assessment services provider, EnRisks.

https://westgatetunnelproject.vic.gov.au/construction/soil-management/expected-pfas-levels.

While we understand that we haven’t fully answered your question, we hope it goes some way to
addressing your concerns.

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