J. WYNDHAM PRINCE CONSULTING CIVIL ......J. Wyndham Prince Consulting Civil Infrastructure Engineers & Project Managers Document: 110350_3_Elara P6 SW Compliance Letter.docx 4 of 9

CONSULTING CIVIL INFRASTRUCTURE ENGINEERS & PROJECT MANAGERS

ABN 67 002 318 621

PO Box 4366

PENRITH WESTFIELD, NSW 2750 ISO 9001:2008 – Quality P 02 4720 3300 AS/NZS 4801:2001 - Safety

W www.jwprince.com.au ISO 14001:2004 - Environment

E [email protected]

J. WYNDHAM PRINCE

Our Ref: 110350_3_Elara P6 SW Compliance Letter.docx

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17 November 2017 Blacktown City Council PO Box 633 Blacktown NSW 2148

Attn: The Development Engineer

Subject: Elara Precinct 6 Subdivision Development Application;

Stormwater Strategy Compliance Letter

Dear Sir/Madam,

This letter is to support the proposed Elara Precinct 6 subdivision Development Application. The water quality treatment devices proposed as part of this development are generally in accordance with the “Marsden Park Residential Precinct – Post Exhibition Water Cycle & Flood Management Strategy Report” (JWP, July 20131) developed to support the overall Marsden Park Precinct development.

1. BACKGROUND

The Elara Precinct 6 development is approximately 44 ha in size and is located within the Marsden Park Residential Precinct. The eastern portion of the Elara Precinct 6 development will discharge to a trunk drainage channel (ML 1.12, ML 1.15, and ML 1.18 formerly known as TC01) which will convey the stormwater runoff to the Marsden Park Contributions Plan No. 21 (CP21) regional detention basin (ML 1.0 – previously known as Basin 3) and regional raingarden ML 1.1 for stormwater quantity and quality management. Plate 1.1 provides an overview of the site locality.

The western portion of the development was represented as a 13.9 ha catchment (D_13) in rezoning strategy1. Stormwater runoff from this catchment was to be managed from a water quality and quantity perspective in regional detention Basin ML 5.0 (previously known as Basin 2). The subsequent subdivision design to deliver a continuous rising grade out of the Marsden Park Precinct for flood evacuation purposes has resulted in the flood evacuation route (future Shanes Park Road) being at a level that no longer permits this portion of the development to naturally drain to the regional detention basin ML 5.0.

It should be noted that as part of the rezoning strategy, the regional detention basins servicing the Elara Precinct 6 development compensate for bypassing (unmanaged) catchments elsewhere in the precinct, and as such localised flow increases were anticipated within the un-named tributary to the west of Elara Precinct 6 due to development further to the west.

1 Marsden Park Residential Precinct – Post Exhibition Water Cycle & Flood Management Strategy Report, J. Wyndham Prince July 2013.

http://www.jwprince.com.au/

J. Wyndham Prince Consulting Civil Infrastructure Engineers & Project Managers

Document: 110350_3_Elara P6 SW Compliance Letter.docx 2 of 9

In January 2017 J. Wyndham Prince assessed the impacts of discharging Elara Precinct 6 (west) directly to the adjacent tributary without detention. It was found that there was a very minor local flow increase at the discharge location in the 0.5 EY (2 year ARI) storm event. However, there were no peak flow increases in the larger 1% AEP (100 year ARI) storm event and there were no peak flow increases at the confluence with Little Creek. This assessment was presented to Blacktown City Council for their concurrence and their response (Email Georg Eberl 22 February 2017) was that there were to be no peak flow increases up to the 1% AEP storm event in the tributary adjacent to the Elara development as it was to remain in private ownership.

Council suggested that a low flow pipe to Basin ML 5.0 for water quality treatment purposes could be up-sized to ensure that there were no peak flow increases in the adjacent tributary. Details of this assessment and correspondence with Blacktown City Council are provided in Appendix A.

Now that the design grading of Elara Precinct 6 is better understood, J. Wyndham Prince has updated the catchment areas and re-visited the assessment to determine the low flow diversion pipe size necessary to meet both the water quality treatment requirements (i.e. 2 EY flows to GPT) and the flow management requirements in the adjacent tributary. The western portion of the Elara Precinct 6 development now has a catchment area of 14.82 ha.

Details of the assessment are discussed below. Plate 1.1 provides an overview of the site locality and reporting locations.

Plate 1-1 Site Locality and Reporting Locations



2. STORMWATER MANAGEMENT

To support the Development Application submission to Blacktown City Council we have undertaken additional investigations to confirm that the current development layout and catchment areas presented on engineering drawings 11035003/DA01 to DA130 are relatively consistent with the original Water Cycle Management Strategy which supported the precinct planning approval.

The eastern portion of the Elara Precinct 6 development will discharge to a trunk drainage channel where stormwater runoff will be conveyed to the Marsden Park Contributions Plan No. 21 (CP21) regional detention basin ML 1.0 and regional raingarden ML 1.1 for stormwater quantity and quality management. Please refer to the Elara, Marsden Park Section 94 Concept Design Report (JWP November 2017) submitted as part of a separate approval process.

An existing swale within Air Services Land adjacent to southern boundary of the development has limited capacity, and previous hydrologic assessments have assumed that this swale could be filled in at some point in the future and flows enter the Elara Precinct 6 development.

For the western portion of the site, existing ground contours indicate that stormwater runoff from the upstream catchment will not discharge through the site, rather it will travel overland to the west into an un-named tributary of Little Creek.

For the eastern portion of the site this upstream stormwater runoff will enter the site. A pit and pipe system will collect flows from the upstream catchment and manage them through the development to the receiving waters. A small wall will divert flows to a pit that has been sized to capture discharge up to the 1% AEP event. A number of surcharge pits are located within the Elara Precinct 6 development where flows in excess of the 10% AEP event will be forced overland via the road network to localised 1% AEP sag locations. The 10% AEP discharge will be managed via the street drainage system as per Council’s Engineering requirements.

A low flow diversion pipe will convey 2 EY (6 month ARI) discharge from the eastern portion of the development to CP21 GPT ML 5.3 and regional bio-retention raingarden ML 5.1 for stormwater quality management. Appropriate scour protection and velocity management will form part of the future Construction Certificate design in order to manage flows in excess of the 2 EY event that will discharge directly to the un-named tributary of Little Creek.

Details of the diversion pipe arrangement are provided on Figure 1 in Appendix B and are shown on engineering drawings 11035003/DA58 and DA59.

2.1 Hydrologic Assessment

A review of the rezoning assessment was undertaken with the existing and developed conditions rezoning XP-RAFTS models run to determine the peak flows within the un-named tributary to the west of the Elara Precinct 6 development. Results of this assessment are provided in Table 2-1. Note that these flows consider a 15% increase in rainfall intensity to reflect anticipated climate change conditions.

Table 2-1 Little Creek and tributary flows – Rezoning models (Bx = 1.0)

Table 2.1 indicates that a 2% flow increase within the unnamed tributary was anticipated as part of the rezoning process.



The current modelling for the Marsden Park Residential Precinct, documented as part of the Elara, Marsden Park Section 94 Concept Design Report (JWP November 2017) reflects current climate rainfall and the current Elara Precinct 6 catchments (east/west). A developed conditions catchment plan is provided in Figure 1 in Appendix B.

To maintain consistency with the hydrologic modelling methodology from the Marsden Park Precinct assessment, current climate design rainfall intensity-frequency-duration (I.F.D.) data for the site were obtained using methods set out in Australian Rainfall and Runoff (A.R.R.) (1987), and are presented in Table 2-2 below. All other parameters are consistent with the modelling approach documented in the rezoning strategy1.

Table 2-2 Marsden Park Current Climate IFD Data

To provide an understanding of the peak flow increase due to the Elara development, the XP-RAFTS model was updated to reflect the Elara Precinct 6 (west) development discharging directly to the adjacent tributary without detention. Results of this assessment are provided in Table 2-3.

Table 2-3 Little Creek and Tributary Peak Flow Summary – Elara P6 Discharge to Tributary Without Detention

Table 2-3 indicates that minor peak flow increases (in the order of 1%) upstream of CP21 Crossing ML 10.8 will occur. Additionally, the minor flow increase (+0.06 m³/s) at CSim13 is also partially due to the diversion of a portion of upstream catchment CSim140 into the unnamed tributary. However, there are no observable impacts at the confluence of the unnamed tributary and Little Creek.

Notwithstanding the above, the water quality treatment for the Elara Precinct 6 (west) development is provided in Basin ML 5.0. The current contributions plan CP21 provides for a single Gross Pollutant Trap (GPT) ML 5.3 to service the Newpark Precinct 6 development and the Elara Precinct 6 (west) development, therefore there is a need to deliver a minimum 2 EY (6 month ARI) treatable flow to this device to comply with Blacktown City Council’s Section 94 Infrastructure Design Guidelines.

Based on the preliminary 12d drainage design of the Elara Precinct 6 development, we have determined the 2 EY treatable flow that needs to be delivered to the GPT is approximately 1.45 m³/s. Therefore, the governing factor in sizing the Elara Precinct 6 diversion pipe will be the delivery of this treatable flow to the GPT. This diversion will also adequately address the minor flow increase in the unnamed tributary previously reported in Table 2-3 above.

The XP-RAFTS model was amended to reflect the diversion of 2 EY flows to CP21 Regional Detention Basin ML 5.0. A summary of peak flows at key reporting locations is provided in Table 2-4.



Table 2-4 – Little Creek and Tributary Peak Flow Summary – Elara P6 Discharge to Tributary with 2EY Diversion to CP21 Basin ML 5.0

Flows in excess of the diverted 1.45 m³/s to Basin ML 5.0 from the Elara Precinct 6 (west) development will discharge directly to the adjacent tributary without detention. Appropriate scour protection will need to be provided to manage these flows up to the 1% AEP within the tributary. Table 2-4 indicates that this low flow diversion arrangement will ensure that there are no peak flow increases in the unnamed tributary of Little Creek due to the eastern portion of the Elara Precinct 6 development.

2.2 Stormwater Quality Management

First flush flows up to the 2EY (6 month ARI) storm event from the western portion of the Elara Precinct 6 development will be conveyed via a low flow pipe to CP21 Gross Pollutant Trap (GPT) ML 5.3 and CP21 raingarden ML 5.1 for stormwater quality management.

Similarly, 2 EY flows from the eastern portion of the site will discharge to regional CP21 GPT ML 1.14. Secondary water quality treatment will be provided in regional CP21 bio-retention raingarden ML 1.1 for water quality treatment.

3. FLOOD LEVEL ASSESSMENT

The proposed Elara Precinct 6 development is relatively consistent with the development extents considered at rezoning stage. Hence the flood model that supported the “Marsden Park Residential Precinct - Post Exhibition Water Cycle & Flood Management Strategy Report’ (JWP 2013) is still considered ‘fit for purpose’ to confirm flood levels. Further detailed modelling will be provided as part of the detailed design process.

Figure 6.15 from the 2013 Water Cycle and Flood Management report provides the developed conditions flood level for the combined 1% AEP + 1% AEP regional tailwater condition (see Appendix A for a copy of this figure). It is noted that all flood modelling in the 2013 assessment considered a 15% increase in rainfall intensity. An interrogation of the flood levels within Little Creek adjacent to Precinct 6 indicate that the proposed development levels are well clear and provide the minimum 0.5 m freeboard to the proposed lots, even with the elevated flood levels due to climate change conditions. Table 3-1 refers to locations in Plate 3-1 within Precinct 6 where flood levels have been compared with engineering design levels.



Table 3-1 Flood Level Assessment – 1% AEP + 1% AEP Regional

Plate 3-1 Flood Level Reporting Locations

4. COMPLIANCE WITH CLAUSE 19 OF SEPP (SYDNEY REGION GROWTH CENTRES) 2006

Clause 19 of the State Environmental Planning Policy (Sydney Region Growth Centres) 2006 requires the following heads of consideration (in italics) to be addressed. The subdivision development application has been prepared giving due consideration to the approved Marsden Park Residential Precinct Post Exhibition Water Cycle & Flood Management Strategy Report (J. Wyndham Prince 2013). We provide the following additional comments as to how these specific sub-clauses of clause 19 of the SEPP have been addressed:

(a) whether or not the development will adversely affect flood behaviour resulting in detrimental increases in the potential flood affectation of other development or properties,



Response: The precinct wide strategy1 mapped the changes that are likely to occur both within and external to the precinct in July 2013. This assessment confirmed that no detrimental impacts will occur to other developments or properties external to the site. Our understanding of the adjoining Newpark Precinct 5 development is that at least 1.8 m freeboard is provided from the flood levels shown in Plate 3-1. Thus no property impact will occur.

(b) whether or not the development will alter flow distributions and velocities to the detriment of other properties or the environment of the flood plain,

Response: Appropriate scour protection and erosion mitigation works are proposed to ensure that flood velocities are reduced to acceptable levels where the proposed works interface with the receiving waters. Therefore we do not anticipate that the proposed development will alter flow distributions and velocities to the detriment of other properties or the environment of the flood plain.

(c) Whether the development will enable safe occupation of the flood prone and major creeks land,

Response: All housing development will be constructed to be above the 1% AEP flood level + 0.5 m freeboard. A continuous raising grade will also be provided for all dwellings to the proposed Regional Flood evacuation route on Richmond Road. This arrangement therefore ensures that the Flood Prone Land can be safely occupied and appropriate flood evacuation of the Flood Prone Land is catered for.

(d) whether or not the development will detrimentally affect the flood plain environment or cause avoidable erosion, siltation, salinity, destruction of riparian vegetation or a reduction in the stability of the riverbank/watercourse,

Response: The Soil Salinity and Aggressivity Assessment undertaken by DLA Environmental (May 2015) indicates that there is a low potential for salinity impacts in the vicinity of drainage channels, creeks and water dams at depths of 2 – 3 m below ground level, and that a soil salinity management plan will need to be implemented as part of the proposed works. However there are no long term salinity or siltation issues expected. Appropriate scour and erosion protection works will need to be provided at the site discharge location/s to ensure avoidable erosion is mitigated.

(e) whether or not the development will be likely to result in unsustainable social and economic costs to the flood affected community or general community, as a consequence of flooding,

Response: All housing development will be constructed to be above the 1% AEP flood level + 0.5 m freeboard. The proposed works will enhance the existing environment which is a benefit to the greater community. Therefore we do not anticipate that the proposed development will be likely to result in unsustainable social and economic costs to the flood affected community or general community, as a consequence of flooding.

(f) whether or not the development is compatible with the flow conveyance function of the floodway,

Response: No residential development is proposed within a floodway. Therefore the development is compatible with the flow conveyance function of a floodway.

(g) whether or not the development is compatible with the flood hazard,



Response: the proposed development is consistent with the approved Marsden Park Residential Precinct Post Exhibition Water Cycle & Flood Management Strategy Report1 which shows all development is clear of the high hazard mapping in the 1% AEP event.

(h) in the case of development consisting of the excavation or filling of land, whether or not the development:

i). will detrimentally affect the existing drainage patterns and soil stability in the locality, and

Response: flows from the proposed development are safely managed via overland flow paths and a street drainage network and we do not anticipate that there will be any detrimental affect on the existing drainage patterns and soil stability in the locality.

ii). will significantly impact on the likely future use or redevelopment of the land, and

Response: the proposed development supports the proposed future use, and re-development of the land.

iii). will adversely impact on the existing and likely amenity of adjoining properties, and

Response: The proposed development is consistent with the planning proposal and will not have any adverse impact on the existing and likely amenity of adjoining properties.

iv). will minimise the disturbance of relics, and

Response: AHIP No. C0001857 has been issued. The salvage works were strictly carried out in accordance with the AHIP.

v). will adversely impact on any watercourse, drinking water catchment or environmentally sensitive area.

Response: The site is not located in a drinking water catchment. Regional gross pollutant traps and a water quality devices will ensure that the expected stormwater pollutants can be treated and managed to the appropriate standards prior to discharge to any environmentally sensitive areas.

5. CONCLUSION

This report details the investigation completed in order to support the proposed subdivision of Precinct 6 Elara at Marsden Park. Further details of the proposed development is provided in J. Wyndham Prince’s engineering design drawings 11035003/DA01 to DA130.

The eastern portion of the site was considered in the recent the Elara, Marsden Park Section 94 Concept Design Report (JWP November 2017) submitted to Blacktown City Council for approval.

For the western portion of the site, a low flow diversion pipe is proposed to convey 2EY (6 month ARI) flows to regional CP21 GPT ML 5.3 and regional CP21 raingarden ML 5.1 for water quality treatment. An XP-RAFTS hydrologic assessment has been completed to confirm that stormwater runoff in excess of this treatable flow will discharge directly to an unnamed tributary of Little Creek to the west without having any increase in peak flows within the local watercourse or downstream in Little and South Creek.



This proposed stormwater management strategy is consistent with the Marsden Park Residential Precinct Post Exhibition Water Cycle & Flood Management Strategy Report (J. Wyndham Prince 2013), and considers the objectives of Council’s policies and provides best practice stormwater management for Elara Precinct 6.

Detailed flood modelling will be provided to Blacktown City Council’s engineers as part of the detailed concept design process for the future Contributions Plan works.

Should there be any queries regarding this matter please do not hesitate to contact David Crompton on 4720 3340 or [email protected]

Yours faithfully

J. WYNDHAM PRINCE

DAVID CROMPTON

Manager – Stormwater and Environment Group

mailto:[email protected]

APPENDIX A – COUNCIL CORRESPONDENCE

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Francis LaneFrom: Georg Eberl <[email protected]>Sent: Wednesday, 22 February 2017 5:34 PMTo: David CromptonCc: Tana Sainsbury; Chris Mudie; Francis Lane; Mike Milligan; Graham Mallison; Robert Peterson; Peter ShahatitSubject: RE: [110350-3] Marsden Park residential - detention management of catchments south of the Collector Road

Hi David, In principle will consider this on the basis that there is no increase in peak flows along this tributary of Little Creek up to the 100 year as it will remain in private ownership. This may mean that the diversion pipe size has to be increased above the minimum treatable flow rate. Regards GEORG EBERL I Senior Engineer – Forward Planning BLACKTOWN CITY COUNCIL PO Box 63 I Blacktown NSW 2148 T 02 9839 6382 F 02 9831 1961 E [email protected] I www.blacktown.nsw.gov.au From: David Crompton [mailto:[email protected]] Sent: Tuesday, 31 January 2017 12:26 PM To: Georg Eberl Cc: Tana Sainsbury; Chris Mudie; Francis Lane; Mike Milligan; Graham Mallison; Robert Peterson Subject: RE: [110350-3] Marsden Park residential - detention management of catchments south of the Collector Road Hi Georg, As requested, please see updated tables below. An additional reporting location (CSim90/CSim151a) on the Little Creek tributary immediately upstream of Crossing 2 (Flood Evacuation Route) has been included to allow Council to have confidence that the solution is achievable and will not have significant impacts on flows within Little Creek in order to provide ‘in principle’ support to this proposal.

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Plate 1 – Reporting Locations

Table 1 – Discharge (m3/s) Summary. Catchment D_13 discharge to regional Basin 2 (current climate rainfall intensity).

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Table 2 – Discharge (m3/s) Summary. Catchment D_13 discharge to Little Creek (current climate rainfall intensity).

Regards David David Crompton – Acting Executive Manager Engineering Design -------------------------------------------------------------------------------------------------------------------------------------------------------------------------------

J. WYNDHAM PRINCE CONSULTING CIVIL INFRASTRUCTURE ENGINEERS & PROJECT MANAGERS P 02 4720 3340 F 02 4721 7638 M 0458 181 823 W www.jwprince.com.au 580 High Street, Penrith NSW PO Box 4366 PENRITH WESTFIELD 2750 From: Georg Eberl [mailto:[email protected]] Sent: Thursday, 19 January 2017 8:53 AM To: David Crompton <[email protected]> Cc: David Johnson <[email protected]>; Tana Sainsbury <[email protected]>; Francis Lane <[email protected]>; Chris Mudie <[email protected]>; Mike Milligan <[email protected]>; Robert Peterson <[email protected]> Subject: RE: [110350-3] Marsden Park residential - detention management of catchments south of the Collector Road Hi David,

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Your preliminary assessment doesn’t show what the impacts on the tributary of Little Creek are that catchment D13 drains into. Until we have an understanding of what all the impacts are can’t give in principle support. Can discuss at our meeting on Tuesday. Regards GEORG EBERL I Senior Engineer – Forward Planning BLACKTOWN CITY COUNCIL PO Box 63 I Blacktown NSW 2148 T 02 9839 6382 F 02 9831 1961 E [email protected] I www.blacktown.nsw.gov.au From: David Crompton [mailto:[email protected]] Sent: Tuesday, 17 January 2017 12:48 PM To: Georg Eberl Cc: David Johnson; Tana Sainsbury; Francis Lane; Chris Mudie; Mike Milligan Subject: RE: [110350-3] Marsden Park residential - detention management of catchments south of the Collector Road Hi Georg Just wondering if you have had a chance to review the below email. Do you have any comments regarding the assessment? Regards David David Crompton – Manager - Stormwater and Environment -------------------------------------------------------------------------------------------------------------------------------------------------------------------------------

J. WYNDHAM PRINCE CONSULTING CIVIL INFRASTRUCTURE ENGINEERS & PROJECT MANAGERS P 02 4720 3340 F 02 4721 7638 M 0458 181 823 W www.jwprince.com.au 580 High Street, Penrith NSW PO Box 4366 PENRITH WESTFIELD 2750 From: David Crompton Sent: Friday, 23 December 2016 2:48 PM To: Georg Eberl <[email protected]> Cc: David Johnson <[email protected]>; Tana Sainsbury <[email protected]>; Francis Lane <[email protected]>; Chris Mudie <[email protected]>; Mike Milligan <[email protected]> Subject: [110350-3] Marsden Park residential - detention management of catchments south of the Collector Road Dear Georg

As you would be aware, J. Wyndham Prince are working with both Winten Property Group and Stockland to support the development of a significant portion of the Marsden Park Residential Precinct.

The XP-RAFTS hydrologic model for the Broader Marsden Park Residential Precinct has been recently updated to support the Winten Hills (Woorong Park) Precincts 4 and 6 development, and also reflects Stockland’s Elara development within the Precinct. The catchments within this model reflect the bulk earthworks grading and the recent development application which includes construction of regional detention Basin 3 and its associated trunk drainage channels.

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The refined design of the collector road and the rising grade considerations for the development as a whole has resulted in the area south of the collector road now being lower than anticipated as part of the Water Cycle Management Strategy assessment. This has presented some challenges in directing catchments on the southern side of the collector road to the regional detention Basin 2 in the north.

The purpose of this email is to gain ‘in principle’ support from Council to discharge some additional catchment without detention to Little Creek while providing compensatory flow management in regional detention Basin 2.

Plate 1 provides location details of the reporting locations documented in the following tables.

Plate 1 – Reporting Locations

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Management of catchment D13

Regional detention Basin 2 already compensates for un-detained catchment, as shown in red in Figure 2 attached. Table 1 provides details of flows at key locations, with the assumption that catchment D_13 would still discharge to Basin 2 (i.e. probably piped).

Table 1 – Discharge (m3/s) Summary. Catchment D_13 discharge to regional Basin 2 (current climate rainfall intensity).

We have then amended the XP-RAFTS model to reflect catchment D_13 discharging directly into Little Creek without detention, but have maintained the previous detention storage and outlet configuration in Basins 2 and 3. Table 2 below provides a summary of discharges at key.

Table 2 – Discharge (m3/s) Summary. Catchment D_13 discharge to Little Creek (current climate rainfall intensity).

The un-attenuated flows discharging from catchment D_13 do not result in adverse impacts within either Little Creek or the confluence with South Creek during the 1% AEP event. The minor 0.02 m3/s increase in flow in the 0.5 EY event in Little Creek downstream of Winten’s boundary (LC_08) could be mitigated with a minor amendment to either the Basin 2 or Basin 3 outlet structures as part of the detailed design process.

We, therefore, seek Council’s ‘in principle’ support to discharge catchment D_13 directly into Little Creek without detention management. Please note that if this position were supported, a more detailed assessment would be undertaken to document the outcomes of the assessment and included details of the appropriate scour protection and water quality treatment for the catchment prior to discharge to Little Creek.

SUBMITTED FOR YOUR REVIEW AND APPROVAL

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Regards

David

David Crompton –Manager - Stormwater and Environment -------------------------------------------------------------------------------------------------------------------------------------------------------------------------------

J. WYNDHAMPRINCE CONSULTING CIVIL INFRASTRUCTURE ENGINEERS & PROJECT MANAGERS P02 4720 3340 F02 4721 7638 M0458 181 823 W www.jwprince.com.au 580 High Street, Penrith NSW PO Box 4366 PENRITH WESTFIELD 2750

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APPENDIX B – FIGURES

Documents

J. WYNDHAM PRINCE CONSULTING CIVIL ......J. Wyndham Prince Consulting Civil Infrastructure Engineers & Project Managers Document: 110350_3_Elara P6 SW Compliance Letter.docx 4 of 9