BLAXLAND WASTE MANAGEMENT FACILITY EXTENSION

- Brian Marshall, 20/02/05

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The Development Application and Environmental Impact Statement pertaining to the Blaxland landfill extension was available for public comment from early December 2004 to February 18 2005. The Society has made a submission that covers a range of items, including concerns about a deficiency of the existing landfill operation at Blaxland, the current composition of the Blue Mountains' waste stream, aspects specific to the extension proposal, and possible misuse of the window of opportunity that the extension proposal provides.

A known problem with the Blaxland landfill (as identified in 2003) relates to leachate entering the current Cripple Creek diversion pipe. A remediation proposal exists, but the Society is concerned that the remedial work is indirectly contingent upon approval of the Development Application covering the proposed extension, and will be deferred accordingly. Ongoing deferral of the remedial work without explanation to those downstream from the landfill is unacceptable. Has the tender for the remedial work (independent of the extension DA) yet been called?

About 60% of the Blue Mountains' waste stream is organic and compostable. This is partly being addressed by voluntary (not mandatory!) bin-size reduction, but there is no specific provision for enforcing minimisation of organic waste. Similarly unacceptable is the proportion of non-recyclable plastic waste (including plastic bags!). The City of the Blue Mountains must either become plastic-bag free or plastic bags must incur a charge (as successfully applied elsewhere). Council does much to manage waste and encourage waste reduction at source, but whereas some respond to non-punitive educational methods, limited levels of 'hip pocket' enforcement help others to comply. Council should not shy away from such adjuncts.

The Blaxland landfill has an operating life of ~12 months and the Katoomba landfill has less than 4 years, so the need for additional capacity is paramount. The Society acknowledges this and accepts that Council's 'barely-in-time' proposal (involving extension of the Blaxland landfill and transference of the 'Katoomba' waste) is the only option that is currently available, economically acceptable, and has a sufficiently short implementation timeframe. Nevertheless, some aspects of the EIS require clarification and/or are cause for concern.

Disposal of leachate is queried on two counts. Firstly, disposal of untreated leachate by injection irrigation (pumping it back into the landfill) should not influence surface water quality but, under dry conditions, could have a cumulative impact on leachate chemistry; the potential impact of this should be considered and perhaps monitored. Secondly, if excess leachate exceeds the capacity of the plant to treat and discharge it to the local sewerage system, will there be overflow of raw leachate to sewer or Cripple Creek? Are the capacities of the leachate dam and treatment plant adequate for conditions of extreme precipitation?

The EIS provides for landfill gas is to be extracted and flared off (wasted!), despite recognising that potential exists for electricity generation via an energy recovery plant. The Society is disappointed that exploitation of this potentially valuable bi-product is not a provisional part of the development application. To maximise the potential return, Council should expedite investigation of the resource and, if justified, formulation of a supplementary development application.

Queries regarding the ecological assessment include whether there was consultation with knowledgeable and independent 'locals', and whether a more protracted investigation of fauna and flora would have reduced the expressed levels of uncertainty. The limitations of the assessment do not seem to conform with the emphasis in the EIS on the importance of the Precautionary Principle and the need to conserve biological diversity and ecological integrity.

Although alternative waste technology (AWT) may be a longer-term necessity, the EIS emphasises that imminent landfill closures leave insufficient time to fully investigate, select and implement such technology. The Society accepts this, but because 'investigating, selecting and implementing' could take at least 5 years, the window of opportunity provided by the Blaxland extension is short. The Society therefore believes that Council should urgently commission an organisation to analyse the City's waste processing needs and recommend an appropriate AWT.

The EIS also raises the possibility of a sub-regional treatment facility servicing BMCC, Bathurst, Evans, Lithgow, Mudgee and Rylstone. The Society is particularly concerned that such a possibility, when placed in the context of the differing councils' agendas, will delay serious consideration and implementation of AWT. Overall, the Society sees the proposed development as a relatively short-term solution to the limited waste management capacities remaining at the Blaxland and Katoomba facilities. The EIS covers the majority of the issues and has measures that ameliorate identified problems, but deficiencies exist and should be addressed. The solution provides Council with a window of opportunity for determining and implementing a long-term waste management solution that should not be squandered. The Society has asked Council to respond to the submission and to be kept informed about actions taken as a consequence.