Bonny Glen Submissions Hearings

~ To view or download the Horizons reports indicating compliance and non-compliance by RDC scroll to the end of the submission ~

This page features submissions to the consent hearings conducted at Feilding in February 2015. (See ‘Bonny Glen Landfill’ page for a background to the process so far).  The page also includes other information and updates that relate to the topic. You can access some of the other submissions yourself in their original form at the Horizons website. 

To read all articles and updates on Bonny Glen go to ‘categories’ on the left side of the page, or scroll to the bottom of the ‘Bonny Glen Landfill’ page.

 Submission on RDC’s Leachate Disposal into the Waste Water Treatment Plant in Marton

On February 24th Hamish Allan, a Marton resident, presented a submission to the panel on a topic that is not considered to be part of the hearing. Neither, as was pointed out prior to the hearings, were property values or trucks.  Ironically, since these are the very concerns which automatically arise when a neighbouring landfill announces plans to quadruple in size.  Nevertheless, Mr Allan’s submission concerns the leachate that is disposed of through Marton’s Waste Water Treatment Plant (WWTP) and has been for nine or so years (deemed the RDC’s concern, not Midwest Disposals’) . This has been, rather than a formal arrangement on paper … a ‘gentleman’s agreement’. The levels have been poorly reported, not tested consistently and there are many non compliances, as Mr Allan’s submission demonstrates. He has supported his submission with documented evidence. Just prior to Christmas 2014 the Wanganui Chronicle reported that the exceeded leachate levels had likely been harming the local Tutaenui Stream. There have been by all appearances, no penal consequences issued by Horizons for these failures in compliance by the RDC. Following is Mr Allan’s submission which outlines the history of how the Marton Community Committe (MCC) of which he was a member at the time, tried, albeit unsuccessfully, to address this in 2011. There needs to be accountability here … as Mr Allan points out in his submission …

‘there can be no economy on a dead planet’. 

The consistent placing of economic interests over the environment is NOT sustainable. The very principles our regional authorities are purporting to pursue … Maintaining and enhancing our Region’s land, water, air, coast and habitat protection” (from Horizons’ website) …  are being held in flagrant disregard. These elected representatives need to be held accountable. You can assist with that process by attending the Marton Community Committee Meetings and lodging your objections there (meetings are held on the second Wednesday of each month … details on the RDC website): 

Marton Community Committee
Location: Youth Club, Centennial Park Pavilion, Humphrey Street, Marton
Every second Wednesday of the month at 7.00 pm

Note: I attended on the 11th … to see outcome go HERE

At the end of the submission below here are links to the original compliance and non-compliance reports.  Any inserts of photocopied evidence within the submission can be clicked on to enlarge. 

~ Please feel free to offer any feedback  in the ‘comments’ section below the submission ~

The Submission

By Hamish Allan

Hello, thanks for this opportunity to speak etc., now…

Irrespective of the leachate issue being taken off the table with regard to Midwest Disposal Limited’s application, I’m going to persist with the issue as…

Whether it falls outside the ‘jurisdiction’ of what the commissioners can consider or not, it remains for me the single most important aspect of these hearings because by allowing Midwest – via a labyrinth of regulatory technicalities – to export the most toxic by-product of their operation off-site ‘legally’, the two councils (as well as central government) are doing very little to protect the interests of ratepayers & the environment (that makes all our lives possible).

Interestingly enough, my beef here is not with the bureau but with the bureaucracy – with people’s behaviour and not necessarily the people themselves, for it is partly because we all need money and something to do with our lives that what has happened has been allowed to happen.

That doesn’t however excuse Horizons Regional Council or the Rangitikei District Council failing to take responsibility for what they’ve done or in this case not done but…

Either way! … The story begins and ends in my home town of Marton, where I was a member of the Marton Community Committee for slightly more than three years.

In theory the purpose of the committee sounds great:







(*taken from the Rangitikei District Council ‘Delegations Register’)

Nice & democratic right? but… In practice it works somewhat differently.

Our meetings were governed by documents called ‘order papers’ whereby unelected bureaucrats (for the most part) set our agenda for our bi-monthly meetings. The only time we or a member of the public were able to initiate anything was during either the ‘general business’ segment or the ‘matters arising’ (from the previous meeting’s minutes) segment:




















Almost everything we talked about arose not from the community – the people – but instead because the local government act 2002 instructed a well-paid mandarin to literally order us through the order paper to talk about this, that or the other thing.

On occasion though however, it did indeed function according to its stated purpose:



So as you heard – a member of the public came to us because they were concerned about ‘Enviro Waste’ trucks disposing of industrial waste from Bonny Glen down a manhole in ‘the junction’.  Ground-up democracy in action right?

(For a limited time it was)

We took it a stage further by formalising the issue in the form of four recommendations to the RDC in our meeting on the 6th of December 2011 – the formulation of recommendations being standard meeting practice for anyone who’s gone along to one of these things:


Our next meeting was held in February the following year, five days after Council met to discuss our ‘recommendations’, amongst other things.  These other things that I’m referring to are the



that we were asked to provide comment upon by Council, as well as the bi-annual toilet survey now… this was the third occasion that we were asked to rate the four locations around Marton that qualify as public toilets.  Only one of us completed the six-monthly toilet survey because nothing had happened as a result of the first two surveys which…

I’d be happy to go into some other time and…

It should also be noted that our comments (with regard to the waste ‘minimisation’ & financial ‘strategies’) could certainly be construed as flippant and non-constructive at times but… Council asked for our opinions, and we gave them.  Otherwise…

This is (part of) what happened at Council’s meeting in February 2012:


And I say ‘ironically enough’ because by bringing up the issue of the leachate in our recommendations we were genuinely endeavouring to be an effective liason with the community so…

What could be a relatively simple & democratic process – providing straight-forward answers to straight-forward questions – became an opportunity for Council to tell us off about small-scale procedural matters, with only one councillor voting against the motion, to her eternal credit.

What’s more, the minutes of the Community Committee meeting in February 2012 detail Council’s deliberate attempt at avoiding any direct response to the issue of the leachate:



How more ‘specific’ and ‘clear’ could we have been with our recommendations? Do the Council have something to hide?


Seemingly not – if you’re to take Andy and Mike’s word for it but…

Despite Mike following through and organising a tour to the rubbish dump for the (Committee), he failed to ‘circulate information’ on the WWTP and ‘follow up on the non-compliance issue’, which Council admitted (in its report on the WWTP from December 2014):

QUOTE: “….has a variable record of compliance with the current resource consent”

And… as you may have noticed, ‘legitimately’ or let’s say ‘legitimate’ was the word then-councillor Andy Watson used to describe the Council’s ‘gentleman’s agreement’ with Midwest to dispose of the leachate at the treatment plant. Which begs the question: what did he mean by ‘legitimate’?

Let’s take a closer look (this taken from the same December 2014 report):




Right so…

According to Council’s own report, the leachate and the ongoing non-compliance of the treatment plant are intimately connected.  Is this what Andy meant by ‘legitimate’?

I requested all the reports from the last nine years from Horizons, expecting 36 in total as intimated by the May 2005 report which clearly states at the end of it:

Please continue to monitor and report on results in the months of July, October, January, and April each year.

To me that implies that 4 reports are required each year (I might be wrong on this one – can anyone please clarify this for me?).  I only received sixteen.  What happened to the other twenty?  Why would Horizons withhold information if indeed the leachate is being dumped ‘legitimately’?

Supposedly, according to Robert Rose (the ‘environmental protection officer’ from Horizons who sent me some of the reports) there was:

 Only one report from 2005

 Three reports from 2006

 No reports from 2007

 One report from 2008  et cetera, et cetera.


Interestingly enough, the one report from 2008 refers to the missing information from 2007 when it mentions how:

 The breaches of the ammonia limits in September 2007, November 2007, December 2007 and March 2008 are significant non compliances. 

Please investigate the reasons for the breaches of the consent conditions and implement procedures to prevent recurrences.

That final sentence is especially infuriating & ridiculous considering that of the 16 reports that contain enough in the way of specific details, all of them contain at least one instance of raised levels of ammoniacal nitrogen that breach the consent conditions. And as the report also states:

 These concentrations have been shown to be directly toxic to aquatic life.

And what do we know about the ‘aquatic life’ in the Tutaenui Stream? (the following is from the same report)

  1. The Consent Holder shall conduct an in stream biota survey…once every 3 years from the date of issue of this consent, for the duration of the consent.

The last report that we have on our files is from 2002, please forward copies of the more recent reports to us.   

And what of these more recent reports?

It wasn’t until May 2013 that a non compliance was issued by Horizons, because the compliance report sent in February 2012 highlighted the need for the 2012 survey.

I couldn’t find one instance of an ‘in stream biota survey’ or ‘macroinvertebrate report’ (as it’s also called) in the 16 reports that were sent to me yet…

Strangely enough, on the 22nd of November horizons reported that A macroinvertebrate report [was] due in 2012. Discussions with RDC have indicated that a… report has been commissioned. Please forward a copy of the… report as soon as it has been completed.

And a compliance rating was subsequently issued. Which gives me the impression that…

Either a report still hasn’t happened since 2002 and they’re not being honest or…

A report has indeed occurred and it confirms that the presence of industrial pollution has killed most if not all of the life in the stream because…

Strangely enough, in order to comply with the consent, all that needs to happen is the report itself.  The state of the stream is seemingly irrelevant when it comes to the governmental authority with the responsibility of protecting the environment.

Either way, Horizons has had an absolute shocker by allowing RDC to continue to pollute with no penalties for non-compliance beyond the words ‘significant non-compliance’ appearing on a report that virtually no-one ever sees.

I received a number of letters last year from RDC because my lawns were overgrown & the second letter quoted a passage from the local govt. act to remind me that If I didn’t do what I was told, when I was told, they would send around a contractor and I’d have to cover the cost:




Who picks up the tab as a result of both Horizons & RDC’s incompetence and irresponsibility?  We do.  Who pays the price when RDC ‘legitimately’ take leachate from the Bonny Glen dump and Horizons fails to hold them to account for polluting the Tutaenui stream?  Not just us, but future generations.

As confirmed by:

The four options put forward by RDC in their report from December last year:




RDC and Horizons mess up and…

We had to pay for them to not do their jobs properly in the first place and…

Also pay for the consequences of the treatment plant (overall, for the most part) failing its consents for the last nine years.

How is that fair? How is that just? How is that democratic & how are they able to get away with it? Where do they get off consciously deceiving and then reprimanding the very community organisation that was only wanting answers on behalf of the community when we first raised the issue back in 2011?

Because the rules are set up to allow them to, that’s why.

And who makes up these rules that we’re all compelled to abide by? Have we as tax and ratepayers ever been asked to vote for or against these rules?

I certainly haven’t and…

This is partly why I accuse Horizons and the Rangitikei District Council of a ‘conflict of interest’.  The two ‘interests’ in question being (generally speaking) 1. Doing their jobs according to the undemocratically conceived rules of the government & the economy and 2. Protecting the environment.

Anyone who works for the ‘public service’ in this country gets paid 36% better money than the average worker and 15% of ‘public servants’ are on six figure salaries.  Not just that, but their income is tied to annual inflation so that no matter what happens in the economy, anyone who works for central or local government is immune from the negative side-effects of our economic system.

So…Irrespective of what they do and why they do it, they still get paid above average money for their troubles.

The trouble though, is that we live on a planet with finite resources & the rules around ‘natural growth’ are not the same as ‘economic growth’.

As human beings we grow until reaching physical maturity and then we stop growing and we all understand that that’s natural and normal right? Can you imagine the problems we’d have if our bodies grew according to the rules of the economy? How big would our clothes have to be? Our houses? Our cars?

It would be impossible to plan ahead for anything let alone survive so…

I’m thankful for these natural limits.

What I’m not thankful for are the government & the economy’s impositions on my everyday life and the threat they both pose to our collective future. Continuous growth on a finite planet is insane, and when this growth is not just officially sanctioned but demanded by our governing institutions we have a serious problem if we want to ensure that our children our able to raise their children in a healthy & safe environment.

At some stage, something’s got to give.

At this current stage in time, it’s Ratepayers who are giving time and time again.  It’s ratepayers who have no choice but to pay Horizons and RDC to poison our rivers & endanger our future.

But we do have a choice whether to speak up or remain silent – unlike the environment that makes our lives possible. We need to choose as there is no middle ground between the way our government & economy currently operate and the natural limits of the environment that are more difficult to influence and control.

Some people would argue the opposite, that ‘sustainable development’ is the answer to our problems but…

I for one do not agree which…

Isn’t to say that ‘sustainable development’ isn’t eventually possible – more to say that it’s currently impossible due to the design flaws that I’ve detailed today and in other previous submissions because…

 “there is no economy on a dead planet”.


Compliance & Non-Compliance Reports

Note: due to some earlier technical difficulties I had to copy & paste these into the web page. Apologies as some page formatting has not translated too well. They are now uploaded below as PDFs. Click on the links below to read.

1. Compliance Reports  (Mar 2005-Mar 2008)

 2. Compliance Reports  (Mar 2009-Feb 2012)

 3. Compliance Reports (Feb 2012-Mar 2013)

4. Compliance Reports (March 2012-July 2012)

5. Compliance Reports (Nov 2013-Jun2014)

Compliance & Non-Compliance Reports as PDFs

NOTE: These are uploaded singly and not as groups as above. They are now all uploaded. You may need to download Adobe Reader from the Adobe website  to read them (it is free).  It remains to request the report due for late 2014. Check back periodically for updates.

1. 20-05-2005 Non-Comp.

2. 28-10-2005 Non-Comp.

3. 06-04-2006 Comp

4. 16-10-2006 Non-Comp.

5. 10-07-2008 Non-Compliance

6. 16-03-15 Complied 7. 09 12-2009 

7. 09 12-2009 Complied

8. 01-07-2010 Non-Compliance

9. 03-05-2011 Significant Non Compliance

10. 13-02-2012 Complied

11. 22-11-2012 Complied

12. Horizons Audit Report 22-11-12 to 26-03-13

13. 01 07-2013 Non Compliance

14. Horizons Audit Report 26-03-13 to 29-11-2013

15. Horizons Audit Report 24-06-2014

 NOTE: Please feel free to comment, or contact me to comment via the contact page. To follow up on these issues it remains for the public to approach the RDC which is possible through the Marton Community Committee  which meets monthly on a Wednesday (details and dates on the RDC website).  With enough persistence by enough people change must surely come about.

As to the consents … personally I think it’s unlikely they’ll be denied, given the preparation & expense made by Midwest. I feel very much for those who live near the landfill. Mr Mullinger has said that fresh refuse has a ‘sweet odour’ … I’m sure that the folks living next door don’t describe it as sweet. I’ve noted in the compliance reports reference to there being no complaints of odour … perhaps it is the squeaky wheel principle that needs to be applied.


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