PROPOSED LANDFILL AT ALLAWUNA: NOTES FROM KAY DAVIES FOR SUBMISSIONS TO DWER

From yesterday's West Australian:

(click to enlarge)

This morning I received the following email and accompanying notes from Kay Davies, who with Robyn Davies fought a long and determined battle against SITA's landfill proposal. 

Kay's notes are designed to help people write their own submissions to DWER regarding the new threat of a landfill at Allawuna. 

If you are against the current landfill proposal - as I believe are most people in York - please let DWER know.  We need as many submissions as possible to convince the government that our agricultural zone and water catchment are simply too precious to run the risks posed by a development of that kind.

Your submission doesn't have to cover every point and topic that Kay raises, though of course it may if you wish.  The important thing to remember is that the DWER is only concerned with dangers to the environment.

Please note that the closing date for submissions is 18 September 2017.

Thanks, Kay, for all your hard work. 

JP

Hi Everyone,

I am writing to you concerning a new proposal that has been submitted for a landfill again at Allawuna, York, called the “Great Southern Landfill”. This is of great concern to everyone as this new proposal does not have to follow the normal approval process because it is using the same approvals as the original SITA landfill. Therefore the proposal only needs the Department of Water and Environmental Regulations (DWER) approval to begin construction.

The new landfill proposal is being undertaken by “ALKINA HOLDINGS”, which is owned by Sam Mangione. Mr Mangione is also the owner of the company “Opal Vale” which is proposing the Toodyay landfill.

If you are against the new landfill and would like to make a submission please feel free to use the attached documents for submissions to the DWER for the Great Southern Landfill application at Allawuna, York. These documents have been provided in word format so that making a submission is made easier. The first 2 documents allow a choice of submission format to the DWER with the last document giving you reasons for objection to the landfill. Please email your completed submissions to info-der@dwer.wa.gov.au by 5pm on 18^th September 2017.

If you require further information, including applications received by the DWER and copies of Licences and Works Approvals granted please visit the DWER website at: https://www.der.wa.gov.au/our-work/licences-and-works-approvals

Can you please send this email to your contacts so that they too have the opportunity to write a submission.

Kind regards,

Kay Davies

Kay's notes:

I have written these points so that they may assist you in your submissions to the Department of Water and Environmental Regulations against the Great Southern Landfill application. Please remember that this submission is based on environmental concerns.

“Allawuna” is located 23km west of York on the Great Southern Highway with its west boundary fence running along side Mt Observation and the water catchment area for Mundaring Weir and the Wandoo National Park.

The landfill site is to be situated in a valley with a wet tributary of 13 Mile Brook running through it.  A dam is to be built on the south/east side of the landfill to capture water flowing down the hill to be used to wet the landfill. Leachate dams are to be built below the landfill just above 13 Mile Brook. 13 Mile Brook runs through farm land and directly into the Avon River through Northam.

This whole area is subject to flash flooding, severe winds and thunderstorms and is a high rainfall area receiving approx 500mm a year.

Points of greatest concerns for submissions are:

Air & Dust Emissions

·      Landfill sites are generally associated with impacts on air quality that will adversely affect environmental values and the health, welfare and amenity of people and nearby land uses. These impacts include dust, noise, odour and especially the danger of fire within the landfill.

·    Contamination will occur from rubbish blowing across into the surrounding National Forests and farms.

·      Contamination will occur from dust by equipment used in the pit and on dirt roads into the surrounding National Forests and farms.

·      Farms to the west of York have no scheme water, relying on rainwater tanks for human consumption as well as stock watering. Contaminated dust will have a huge effect upon the area.

·      Borrow pits that are to be constructed where soil is moved to use in the landfill will impact the environment and surface water flow as well as causing erosion and dust emissions.

·      Fire is a huge issue with the landfill being located next to National Forest. If a landfill fire occurs it will cause irremediable damage to the natural flora and fauna and farming businesses located near the landfill.

·      The increase in traffic along Great Southern Highway will impact upon the air quality as well as the flora and fauna. It will cause greater noise pollution especially as the area is renowned for its amphitheater effect with noise travelling over many kilometers.

Odour Emissions

·      The odour and gases emitted by the landfill is of great concern, especially with winds often blowing in a west to east direction impacting on farms and the town of York.

·      Gas emissions can impact the surrounding community including local flora and fauna, with landfills being proven to cause lung cancer.

·      Gas emissions from the landfill have the potential for huge landfill fires, which can last many months polluting the whole area and causing the closure of the Great Southern Highway.

Discharge to Water & Land

·      The quality and contamination of water in 13 Mile Brook and possible ground water contamination to Mundaring Weir and the catchment area for Helena River. Mundaring Weir is the water supply for York and the Goldfields as well as many eastern Perth suburbs. Certain liquid wastes can alter the physical characteristics of natural occurring waters and this should be prohibited near potable water supplies.

·      Contamination by heavy metals (in water & dust) from the leachate dams flowing directly down hill and into the 13 Mile Brook.

·      Stormwater management is of great concern especially in the event of a flood or huge storm. Water will flood the pit and the leachate dams causing major contamination to land and waterways.

·      There is not enough known about the hydrogeology and geology in the area where the landfill is to be located. Palaeochannels are present in the area with insufficient data available of the area to be used for landfill.

·      A Permit to interfere with Beds and Banks under the Rights in Water and Irrigation Act 1913 should not be granted as changing the direction of water flow will influence the flow of 13 Mile Brook and the Helena River.

·      E coli bacteria are present in waste and will contaminate the site and therefore water sources.

·      Contamination to surrounding fauna & flora, especially Carnaby Black Cockatoos, Wedge-tailed Eagles and native foraging animals that will contaminate the food chain. Waste can accumulate in living animals and be discharged into water and surrounding environments.

·      Contamination will occur from birds landing and drinking from leachate ponds and spreading the leachate into the surrounding National Forests and farm lands including dams and troughs where stock drink. This will affect farm bio-security. 

·      There will be an increase in vermin and pests which will impact native flora and fauna as well as farm bio-security.

·      HDPE liners to be used in the pit do break down over time and this will cause contamination into the water table.

·      York is a Seismic activity hot spot, so there is great concern over lining damage within the landfill. Earthquakes can destroy liners.

·      Alkina Holdings should be denied permission to clear any part of the property, especially in the areas under Covenant as this will have serious environmental consequence and should be denied a Native Vegetation Clearing Permit under the Environmental Protection (Native Vegetation Clearing) Regulation.

Other Concerns

·      Many York community members and businesses rely on tourism. With the increase in traffic along Great Southern Highway tourism will seriously be affected in York thus affecting the enjoyment and quality of the community’s lives.

·      Landfills are old technology with many alternatives now available to recycle more as well as pre-existing incineration locations available. No new landfill sites are required as there is enough airspace in existing landfills to accommodate WA waste will into the 2050s.

·      The Waste Authorities “Towards Zero Waste” needs to be considered.

·      Alkina Holdings appears to be a construction company for homes and sheds and not a company that has experience in landfills. We question their financial position to have a multimillion dollar contingency plan when contamination occurs to the environment or businesses in the area.

·      Alkina Holdings are leasing Allawuna from AIM Enterprises Pty Ltd for a period of approximately 20 years. Who will be responsible for environmental contamination once Alkina’s contract is finished?

·      The landfill proposal requires financial assurance under s86C of the Environmental Regulations Act so that the people of WA have some assurance that ALKINA Holdings will be responsible financially for any hazardous event at the landfill site.

·      The landfill is located in an area zoned as “General Agricultural” and the Shire of York have voted to prohibit landfills within the Shire. Even though there is a “sunset clause” on Allawuna from the previous SITA Landfill proposal object to this planning decision as it will have major ramifications on the environmental conditions of the surrounding agricultural land and national forests.

·      Environmental Protection Authority 2016, Statement of Environmental Principles, Factors and Objectives, EPA, Western Australia should be adhered  http://www.epa.wa.gov.au/sites/default/files/Policies_and_Guidance/Statement%20of%20Environmental%20Principles%2C%20factors%20and%20objectives_Dec16_1.pdf

Environmental principles: Section 4A of the Environmental Protection Act 1986 establishes the object and principles of the Act.

The object of this Act is to protect the environment of the State, having regard to the following principles:

1. The precautionary principle: Where there are threats of serious or irreversible damage, lack of full scientific certainty should not be used as a reason for postponing measures to prevent environmental degradation. In the application of the precautionary principle, decision should be guided by: a. careful evaluation to avoid, where practicable, serious or irreversible damage to the environment; and b. an assessment of the risk-weighted consequences of various options.

 2. The principle of intergenerational equity: The present generation should ensure that the health, diversity and productivity of the environment is maintained or enhanced for the benefit of future generations.

3. The principle of the conservation of biological diversity and ecological integrity: Conservation of biological diversity and ecological integrity should be a fundamental consideration.

4. Principles relating to improved valuation, pricing and incentive mechanisms:

a. Environmental factors should be included in the valuation of assets and services.

b. The polluter pays principle – those who generate pollution and waste should bear the cost of containment, avoidance or abatement.

c. The users of goods and services should pay prices based on the full life cycle costs of providing goods and services, including the use of natural resources and assets and the ultimate disposal of any wastes.

d. Environmental goals, having been established, should be pursued in the most cost effective way, by establishing incentive structures, including market mechanisms, which enable those best placed to maximise benefits and/or minimise costs to develop their own solutions and responses to environmental problems.

5. The principle of waste minimisation: All reasonable and practicable measures should be taken to minimise the generation of waste and its discharge into the environment.