The CoM has a woeful record of mismanagement and, shall we say, “oversights” the 20 years on the Tims Thicket Waste Site – see our evidence-based list of misdemeanours. We are particularly concerned that very recently (Mar 20 - during Covid-19 restrictions) there was a restructure of the Directorship of the City of Mandurah where the Director responsible for the Environmental Department of 17 years standing has been made redundant and the Environmental Department now reports to the Works and Services (now renamed Built & Natural Environment) Director who also has responsibility for Waste Management – we perceive this as a serous conflict of interest! During its 20-year management tenure there is documented evidence that CoM Works & Services Dept have: 1. Failed to rectify the illegal dumping by CoM, or subsequent removal, of contaminated waste on adjacent reserve 24198, set aside for conservation & passive recreation and outside the waste facility reserve, from 1995-1998 (photos supplied to CoM rangers & DWER in 1997); NOTE that water table flows through this site on the way to the ocean!

2. Failed to act on bore water monitoring results showing increasing levels of ground water contamination since 2006 to 2018 (including 3 years after closure of the septage facility)

3. Asked Council to renew the Cleanaway waste management contract for Mandurah in Jun 2012 while knowing the increasing levels of contamination occurring at Tims Thicket operated by Cleanaway. 4. Failed to fully & correctly inform councillors on 3 known occasions upon which decisions regarding the waste facility have been made: (i) 2013 councillors vote to reopen facility but not advised of known water table contamination as per above charts. (see item G.21/12/13 of Council minutes 17/12/13) (ii) 2015 councillors deferred vote to upgrade of septage facility requesting further information on environmental impacts and are provided with incorrect water monitoring graphs; (see Kyle Boardman memorandum of 22/6/15) provided to councillors containing graphs below which show only a small portion of the actual water monitoring graphs and only bores 1-5)

(iii) 2016 councillors vote to upgrade septage facility however the Report 5 from Director Works and Services To Council Meeting of 26 July 2016 outline plan; - bears no mention of irrigation field being outside waste title on 24198 just mentions (adjoining reserve) “20. Installation of pump to Storage Pond and associated pipework to irrigation field (adjoining reserve), includes new sand filter and chlorination equipment to treat final effluent prior to dispersal to the sub soil irrigation area.” - or that it is over previous contaminated waste site as (identified in 1. above) - or that DWER have already notified (2015) that this is an unacceptable solution

5. Failed to notify Tims Thicket and Melros beach users of the faecal contamination above the recreational water limits in 2011 & 2012 (as per CoM 2010- 2014 Recreational water report) compliled by the City of Mandurah Environmental department when headed by outgoing director!; Note that Melros beach had one instance at 300 organisms per 100ml but Tims Thicket beach had 10 median readings of over 35/100 out of 17 readings i.e. 58%. 6. Failed to continue to monitor ocean water quality, instead shut down the recreational water monitoring in those locations Of the 17 ocean sites only 4 were shut down 2 of which were directly affected by the Tims Thicket liquid waste facility at a time when the water monitoring reports were showing increased ground water contamination. (as per CoM 2010- 2014 Recreational water report); “During the period of July 2010 to April 2014, there were 16 monitoring sites along the coastline of Mandurah, from Madora Bay to Tims Thicket; as indicated by arrows on the map in Figure 3.1. These sites were divided into two categories based on their frequency of use by the public for water-based recreational activities during the bathing season:” 7. Failed to comply with license conditions, stockpiling waste from 2010 for 7 years prior obtaining a crushing licence in 2016 (as shown by aerial photos); Feb 2008 – Area clear prior to stockpiling Feb 2010 – Stockpiling begins. Feb 2011 – Stockpiling continues Feb 2014 – Stockpiling now large amounts Q1 2015 – Licence issued for crushing Nov 2016 – Crushing begins 8. Deceptively obtained a crushing licence outside of Ministerial Conditions MS375 by failing to adhere to required licence application conditions, resulting in licence grant by DWER in Jul16, causing noise pollution to residents of William St in Melros; 9. failed to monitor, admit or rectify multiple breaches by the operator to licence conditions as shown in DWER licence L6860/1995/11 update of 4/6/15 culminating in the removal of the licence for the liquid waste facility - excerpts from licence as follows: “Removal of Category 61 liquid waste facility and Investigation of potential Impacts from pond leaks. Septage wastes were previously accepted and treated via three anaerobic ponds, a facultative pond and an aerobic pond. Treated septage wastewater was discharged into an infiltration area adjacent to the oxidation pond. The infiltration area was constructed so that in the event of an overflow or emergency discharge, the treated wastewater would be directed to the infiltration area and then allowed to infiltrate onsite soils. Although the site is no longer accepting liquid waste, there is liquid waste stored in the wastewater treatment system. DER has reviewed groundwater monitoring results for the site. Groundwater flow is indicated to be in a westerly direction. There are 9 monitoring bores in total, with 3 located up-gradient (MB1, MB2 and MB9), 2 in close proximity to the treatment ponds and infiltration area (MB1 and MB2), and 2 located down-gradient of the ponds (L1 and MB5) Groundwater monitoring results indicate that there is an increasing trend in the presence of contaminates compared with up-gradient samples. TCL decided on 1 November 2014 to cease accepting liquid wastes as they were approaching their annual limit and until a thorough investigation of the ponds integrity can be carried out. Inert Landfill The inert landfill receives inert waste and construction and demolition waste from building Sites The site accepts up to 65,000 tonnes of Inert Waste per annual period. Tile inert waste is used to backfill a limestone quarry. It has been identified in previous inspections that the site has had on-going issues with accepting non. conforming waste. An improvement condition has been Included that requires the Licensee to submit a Waste Acceptance Procedure to DER, to ensure that suitable management practices are in place to prevent non-conforming waste being accepted and buried on sire Ministerial Conditions The premises were assessed under Part IV of the Act and are bound by Ministerial statement: 375. Previous Compliance inspections at Tim's Thicket have identified non-compliances with licence conditions in the past, specifically with maintaining the wastewater treatment ponds and acceptance of non-conforming wastes for the inert landfill.” 10. failed to complete any of the actions from BCCG/Com meeting of Dec 17, including actions: 1b) review of new liquid waste proposal with BCCG prior to submission 4a) to put up all the water monitoring results on the CoM website 5) review of new liquid waste proposal with nearby residents 11. failed to implement the vesiture change of land use for adjoining reserves from Camping & Recreation to Conservation and Passive Recereation despite being formerly reminded to do so in 2015 and again in 2017: “The balance of the excised portion of the reserve 21271, the balance of reserve 24198, and Reserve 33139 will be retained in its natural state and managed by the City for Conservation and Passive Recreation…” By doing this the city has effectively removed an area of public conservation (national park) and subjugated it for their own purposes, contrary to their own proposal and the direction of the minister. For this error nobody has been held accountable. 12. failed to implement 7 of the original 1998 adjacent reserve management plan actions (3.8,3.17,4.3,4.4,4.5,4.6,4,9), mostly relating to monitoring the adjacent reserves; 13. Failed to carry out any recent detailed environmental study of the adjacent reserves detailing flora & fauna since CER report of 1998 since which time a number of local species have been added to the endangered flora & fauna list. 14. failed to monitor, with the resulting impact on the environment of rampant weed growth of the Brazilian Pepper tree growth in the weed pit west of the site and death of protected Tuart tree copse situated south of the site in Yalgorup National Park (see photos); Note that Brazilian Pepper growth is significantly enhanced in soils with high levels of phosphorus - see Fire Effects Information System info sheet 15. Dumped potentially contaminated sand in 2017 on reserve 24198 outside their licence provisions adjacent to a newly placed pieziometer marked with a blue cross; 17. Failed to consult with local residents on any of the proposals put to DWER

18. Failed to look at any other alternative solutions such as: • Alternative waste sites in a less sensitive area and not on Tamala limestone • Alternative methods of disposal such as the Remondis method already in use at Henderson • Vigorously pursue WA Government for Sewerage infill for the 4000 septic tank properties (4%) in Mandurah