The Evidence For/Against Three Kings Quarry "Cleanfill"

Today's Thursday 17th March. If all goes according to plan legal counsel for Fletchers Infrastructure/Winstone Aggregates will complete the two week Environment Court hearing of its application to use Three Kings Quarry as a cleanfill/managed fill, by delivering the right of reply. I will report later on further developments.

But for now, I thought I would provide you with copies of evidence that has been provided to the Environment Court by various experts and parties to the hearing. Links to selected evidence files are later on below in this blog.

In a hearing of this size, complexity and challenge - there is vast amounts of paper, and it is beyond my resources to make all of it available here. Or even a small proportion of it. Every affidavit is rebutted by those who disagree with it for example. All of this material is available to the Court. The Judge and Commissioners indicate they have either read it all, or they have heard it. And of course witnesses have been cross-examined in Court.

My main interest in this matter has been its potential effect on Auckland's Underground water resources and aquifers. There are other issues of significance including traffic effects, dust effects and so on. However I have concentrated on groundwater effects. So, here's some written evidence that is primarily around that issue. There are many documents other than these....

For Fletchers Infrastructure/Winstone Aggregates

Bernie Chote (General Manager)
Mr Burden (Geo Chemist, expert in environmental effects of landfills)
Mr Harding (Hydrogeologist and computer modeller of groundwater effects)

For Envirowaste Services

Mr Parker (Engineer, expert on Australian landfill policy and management)
Mr Mitchell (Engineer and Planner, expert in environmental effects and RMA)
Mr Northcott (Chemist, NIWA experience, expert in organochlorines in environment)

For Auckland Council

Mr Stapleton (GeoEnvironmental Engineer, expert in soil and landfill processes)

Local Submissions for South Epsom Planning Group

Pip Mules (Local resident)
Garry Law (Engineer and Manager Water systems, expert in water resource management)
Mr Triggs (Professor of Statistics at Auckland University)

Watercare Services Ltd

Mr Widdowson (GeoScientist at BECAs, expert in groundwater monitoring & risk assessment)

These are my selection. They are indicative. Happy reading.

Garbage In = Garbage Out

There was a delightful moment in the Environment Court on Tuesday 8th March.

Dr Bellamy, who is representing the submissions of the South Epsom Planning Group, got the opportunity to cross examine one of Winstone's key expert witnesses. This was Mr Chote, who has been a senior General Manager for Winstones for several years. His evidence had been "taken as read" by Judge Smith and the two commissioners sitting with him, and all parties respresented then had the opportunity of asking Mr Chote questions about his evidence and the application.

This was day 2 of the hearing of Fletcher Construction's contested application. They want to use the Three Kings Quarry at Mt Eden as a "cleanfill" for around three million cubic metres of "fill" which they hope is permitted to contain contaminants of various kinds (DDT, Petroleum Hydrocarbons, heavy metals etc - see below) up to certain prescribed levels. The South Epsom Planning Group has raised questions about the effect of the proposed fill/cleanfill on the groundwater, and on the Auckland aquifers beneath.

Judge Smith encouraged Dr Bellamy to "go for the jugular", he encouraged Bellamy to "not beat about the bush".



So, first up, Bellamy was keen to demonstrate that his team of experts (many seem to hold positions at Auckland University), had investigated Winstone's computer model of the proposed cleanfill/landfill project. It appears they have big questions over the "permeability" the model ascribes to the fill material. Bellamy talked of it being "five orders of magnitude" in error. (In layman's terms that would mean the Winstone's model assumes fill is 100,000 times more (or less - I wasn't sure from the question) permeable, than it really is. This would make a big difference to the rate at which water would percolate through. And make a big difference to its predictions.

Mr Chote wasn't very clear in his answer, but it seems he's not the Winstone's modelling expert. That person comes later. Dr Bellamy was charitable in his explanation of his question. He beat about the bush a bit here - talked about if the model is that far wrong how can you trust its predictions.



But what I was screaming out for him to say, what the whole court must have been busting for him to say, was:

"GARBAGE IN - GARBAGE OUT".....



But he didn't. Dr Bellamy is too well behaved for that.

Pity really. It was like a metaphor for the whole thing. A sort of truth. Almost the elephant in the room. Stands to reason. If you put contaminants in a hole, you'll get contaminants out of the hole. You get back, what you put in. Unless you collect it, trap it, and treat it.

The pictures on this blog are a selection of what you find if you Google "garbage in equals garbage out".