Making a Submission
In making a submission you need to ask yourself one question – “Do I want to risk the water supply that will be consumed by me, my children and my grandchildren being contaminated by toxic pollutants in the future when I have a chance to put a stop to it now?”
If you oppose the renewal of this licence and your answer is NO, then send a Submission to the EPA saying so. Email it to:
OR mail a paper copy to:
MML Submissions – Waste Branch, Environment Protection Authority, PO Box A290, Sydney South NSW 1232.
The closing date for submissions is 20 December 2018.
(Verde Terra Pty Ltd’s actual application and supporting documents can be found on the EPA’s website at https://www.epa.nsw.gov.au/working-together/community-engagement/community-news/mangrove-mountain-landfill. It is not necessary to read all of the documents. They are only those submitted by Verde Terra Pty Ltd to support its application with the EPA).
We need your input. Please do not assume others will take on the responsibility. This may be your one and only chance to have a voice.
There are several options available:
- Write your own submissions, using any of the points below that you think are relevant, plus any of your own thoughts on the issue
- Download the Pro Forma Word Document, make any changes or additions Word Doc here
- Print the Pro Forma PDF, tick the issues you think are relevant and add any of your comments you’d like to make PDF here
Below are some suggested reasons for opposing Verde Terra Pty Ltd’s application that you could use (cut and paste) in your submission to the EPA.
Some reasons to include :
I am a resident of the Central Coast and potentially affected by this landfill. [change as necessary]
I oppose the reissuing of EPL 11395 to Verde Terra Pty Ltd for the following reasons [choose any or all from the following list to include in your Submission].
Key issue – please include:
I believe that Verde Terra must be required to submit a new DA and Environmental Assessment, not only for assessment by Central Coast Council, but also to be subject to public exhibition and comment.
Then any or all of those below:
- The purity of the water supply for the Central Coast is at risk from run-off and seepage of leachate into the creek system supplying Mardi and Mangrove dams.
- The NSW Environment Protection Authority (EPA) and Central Coast Council, both regulatory authorities, are united in opposing the renewal of the licence, for the stated reason of environmental safety.
- EPA Guidelines for Solid Waste Landfills would today prohibit the siting of this landfill at the head of a water catchment.
- For over a decade, the Community is on record as frequently opposing the size, nature and operation of the landfill.
- Stormwater and leachate management at the landfill has been and still is poorly managed, with potential for contamination of ground and surface water, and potable water off-site.
- The landfill presently holds 800,000 tonnes of waste, 10x that permitted by the 1998 development consent (DC). Without considering the DC or environmental safety, in 2014 the Land and Environment Court (LEC) approved a further 1.3 million tonnes of waste to be imported into four new cells (W, X, Y and Z) in Area B. Central Coast Council requires a new Environmental Impact Statement and Development Application for this major change. Verde Terra Pty Ltd has not submitted either.
- The present waste mound is over 85% unlined, allowing toxic leachate to enter the underlying Zone 4 Kulnura Mangrove Mountain aquifer and ground water.
- The EPA has not transferred important pollution control guidelines from its ‘EPA Guidelines for Solid Waste Management’ to this landfill’s licence, creating a loophole for the Operator to pollute without penalty.
- The current three stormwater ponds and leachate holding pond have been operating in an unlicensed area for 10 years, outside EPA’s jurisdiction, emphasising slack management of the site by all parties.
- Increase in truck traffic carrying waste in a rural community to an average of 55 truck movements/day over a 10 year period.
- A 6-7 million litre odoriferous leachate holding pond is planned for siting on the golf course near a gully leading to Stringybark Creek. It has the potential to contaminate both golf course and creek and drive away golfers.
- Dust, noise and smell will affect neighbouring Central Mangrove School, adjoining private properties and the Mangrove Mountain Memorial Club with its restaurant.
- Current EPA water testing is inadequate for detection of pollution of ground and surface water by the landfill, assurances of safety in a 2017 EPA Media Release notwithstanding.
- EPA oversight of the landfill has drawn extensive criticism for several years from the local Mountain Districts Community and from a broad base of Central Coast residents.
- The Community is in favour of a golf course, but it was purchased by the landfill owner in 2014 and is no longer owned by the Community, so its future is in doubt.
- The aquifer has been breached at the base of Cell W, without a licence to take water. This will also interfere with lining and longevity of this Cell.
- The Community and regulatory bodies such as the EPA and Central Coast Council have minimal or limited oversight of Verde Terra Pty Ltd’s activities on the landfill. The granting of a licence renewal will quite literally be a licence to pollute.
- An independent consultant appointed by the EPA with input from Mountain Districts Association, Alan Dyer, produced a report entitled ‘Technical, Environmental and Operational Review of Mangrove Mountain Landfill’ in May 2017, with 61 suggestions for improvement. This report has been omitted by Verde Terra Pty Ltd in its supporting documents.
- Sub-surface methane gas levels between 2012 and 2016 have been as high as 896,000 ppm, far higher than the 500 ppm permitted, with no acknowledgement or warning by the EPA or Verde Terra Pty Ltd. These levels indicate that putrescible waste has been landfilled, which is not permitted.
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