The Landfill Directive (99/31/EC) seeks to prevent or reduce the negative effects of landfill waste on the environment, including groundwater. Like the IPPC Directive the directive establishes provisions for issuing permits based on a range of conditions including impact assessment studies. For each site the groundwater, geological, and hydrogeological conditions in the area must be identified. The sites must be designed so as to prevent groundwater from entering landfill waste, collect and treat contaminated water and leachate, and prevent the pollution of soils, groundwater or surface water by using the appropriate technical precautions such as geological barriers and bottom liners. The directive establishes criteria for waste testing and acceptance taking into consideration the protection of the surrounding environment, including groundwater.
Looking further into this directive, I find no provision for “cleanfill” but there is provision for “inert waste”, see this scan.
Also the Directive has very strong guidance for those planning to establish a landfill of any kind. “…the location of a landfill must take into consideration requirements relating to…the existence of groundwater… the geological and hydrogeological conditions in the area…." And goes on to stipulate: “…the landfill can only be authorised if the characteristics of the site with respect to the above mentioned (location) requirements, or the corrective measures to be taken, indicate that the landfill does not pose a serious environmental risk…”
The Directive goes on to stipulate requirements for liners to prevent leachate from percolating into groundwaters and so on and these only do not apply if: “…the landfill poses no potential hazard to the environment…”
Not de minimus, not less than adverse, not minor – no potential hazard.
Here in NZ we were blessed with the Resource Management Act. In 1991 environmentalists thought it was great. So did its New Right supporters. But over time it has been shown to be ineffective when it comes to cumulative pollution. That is pollution from non-point sources.
We see this problem manifest in New Zealand at its most intense in the dairy industry. But somehow all concerned sit like the proverbial frog in heating water. All the evidence points to this problem growing. The sources of this pollution of rivers is in the ground now, from dairy effluent, and it will flow steadily into the rivers and lakes for decades – even if diary farming stopped. We know this. But still it goes on. And it appears to be impossible for Councils to stop themselves granting farmers even more permits.
New Zealand is a very young country. We have a large and extended commons. National Parkland, beaches, oceans, rivers, mountains, rivers, and aquifers. A degree of exploitation has been permitted and the consequences are becoming more or less visible to us all. But there are no national standards (like the EC Directive on landfills), there are no standards for water allocation and use (though there is now some work happening on this front – but it’s little and it’s late), there are no bottom lines (so organisations like Fletcher Construction can think of running a “managed fill” which permits them to pollute), and there is no long term view. Even the much vaunted EPA Environmental Protection Agency looks like a joke.
The preoccupation with red-tape cutting and short cutting to get consent – all in the interests of short term economic activity – will have dramatic long term consequences. We cannot continue to shit in our own nest and leave it to the next generation. That is not a legacy to be proud of.
New Zealand is no longer 100% pure, and hasn’t been for a long time. The way we are going now with our environment – and with our aquifers and groundwaters – is the same as the path we took with our rivers. When will we learn?
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