The ShUT Submission 16/10/09
Below is the ShUT Submission to Shoalhaven City Council (lodged on 16/10/09) detailing why ShUT as a community group objects to DA-09/2077. See also 'The ShUT Current Summary'
Shoalhaven Unwanted Tip Campaign Inc. (ShUT) Submission
C/o Tomerong Post Office
TOMERONG NSW 2540
Friday, 16 October 2009
The General Manager
Shoalhaven City Council
PO Box 42
NOWRA NSW 2540
Dear Sir,
SHUT is a community organisation that has formed in response to the community concern over the proposed non-putrescible waste facility at Tomerong – DA 09/2077.
SHUT has received no positive comment from the community with regard to this DA. We would like to submit the following submission in point form to cover all aspects of concern that have been brought to SHUT. SHUT are happy to provide further detail on any points at any time in the assessment and determination process.
Planning
- Business driven application that does not deal with the wider issue of waste management
- Lack of good planning principles – its is contradictory to propose a toxic waste facility in a prime coastal asset where there is expected to be a substantial increase in population
- Contrary to the intent of planning documents that apply to the area – these include the South Coast Regional Strategy, Jervis Bay Settlement Strategy and the Jervis Bay Regional Environment Plan
- The Carbon emission and financial cost implication of such movement should make it prohibitive
- Inconsistency of the description of the waste collected i.e. General Solid Waste (Non- putrescible) and the inclusion of putrescible material in the DECC list of what is included in this classification
- No boundaries on the potential catchment for this waste to come from
- No demonstrated responsible application by the applicant of the Precautionary Principle or Ecologically Sustainable Development principles to the proposal
Lack of Community benefit
- The community cannot see any community benefit in this proposal
- The huge volume of waste to be transported to this site from outside the Local Council area
- Negative impact on tourism industry
- No employment opportunity beyond a possible 4 or 5 people
- Concerns over long term management who is responsible once the site is sealed and how will the long term financial security be managed – will the community be ultimately responsible
- Concerns over controls of what will be received at the site and the potential to have prohibited material stored on site
- Major risk in the construction phase – can this be done for less than 20 million dollars and provide the community with security
- Should this be determined by the Southern Joint Regional Panel or be a 3A application where it would be scrutinized by the Department of Planning
- Concerns over negative impact on property values
- Often based on assumption and speculation
- Hydrological Study
no data to quantify groundwater seepage through the quarry faces,
contour plan shows sections of quarry where ground water is theoretically above the surface of the quarry – there should be no inflow of ground water into the landfill,
potential for ground water levels to rise
no independent design assessment to review adequacy of design or that assumptions are accurate
- Noise Study – data averaged instead of peaks used to bring the decibel increase to below 2.0 where noise attenuation would be required
- Air quality
using quarry infrastructure to control dust
- Flora and Fauna –
inadequate mapping of Federal and State listed Melaleuca biconvexa, insufficient buffer along a DNR Category 1 creek. Tomerong is a category 1 and should have at least a 50m buffer,
the site is next to an area of Ecological Sensitivity
- Leachate management –
ability to maintain leachate infrastructure that is buried below toxic waste, managing leachate of increased toxicity – it will never completely go away, the huge variation of the volume of leachate produced 39 to 480 cubic metres per day,
why is the volume so large when it is meant to be an inert facility.
- Building a mound above the existing ground level is likely to be unstable and result in a rising water table
- Likely negative Impact on water quality of SGB and Jervis Bay now and into the future
- The inadequacy of the flood studies and the ability for the proposed bridge to cope with a 1 in 100 year flood
- Traffic -
added congestion across the Shoalhaven
the suggestion that Gumden Lane can adequately cope with the predicted truck movements
other local routes are trucks likely to take as short cuts
no safe egress for pedestrians or bike riders on the route along Island Point Rd and Gumden Lane
the ability of the highway intersection to safely facilitate 30,00truck movements per year
the cost to the ratepayer to maintain Council managed roads
- Dual use of the site i.e. quarrying and waste disposal and the lack of sufficient buffer between the operations
- Insufficient addressing of the potential fire hazard
- Inadequate application of the Precautionary Principle
SHUT has held several well attended public meetings, provided information at local markets, established a web site and generally raised community awareness of this proposal. SHUT has endeavoured to do this in a responsible and reliable manner. Overwhelmingly the community has responded with concern. The above is a summary only of the issues that have been raised with SHUT in the month that the community has had to learn and understand this application. It is a shame that this is the option proposed for the site considering the other options available to it. As a solution to waste management it is flawed and relies on technological wishful thinking. It is simply unsustainable.
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If you think that this DA should not go ahead, please see our 'Lobby info' page.