NELSON CITY COUNCIL
LOCAL GOVERNMENT ACT
SUBMISSION ON THE DRAFT LONG TERM PLAN 2015-2025
To:
LTP Submissions
Nelson City Council
PO Box 645
Nelson 7040
Submitter:
Rasamibe Co Ltd (Mr R Curtis)
Dated:
this 28th day of April 2015
………………………………………………
(Signed by the Applicant’s authorised agent)
Address for Service:
Staig & Smith Ltd
PO Box 913
NELSON 7040
Attn: Jane Bayley
Email: jane@staigsmith.co.nz
Phone: (03) 545 6883
Submission LTP 2015-2025 (NCC)
Staig & Smith Ltd – April 2015
Page 1 of 4
Job No 6891
1.0
Introduction
The Submitter, Mr Ray Curtis of Rasamibe Co Ltd, obtained subdivision
consent in May 2003 to create 64 residential sections over a number of
stages, being Kendall View and Lassen Place, Stoke. Whilst all sections have
been created, around 50 have been built upon.
Recently, a purchaser of one of the vacant allotments sought building consent
from NCC and was advised that a detailed site investigation of the land was
required under the provisions of the National Environmental Standard for
Assessing and Managing Contaminants in Soil to Protect Human Health as
the Council had recently registered the subdivision area as being a potential
HAIL site due to past use of chemicals (hazardous substances) in horticultural
activities.
The purchaser undertook a detailed site investigation which confirmed that the
previous orcharding operations had left residual heavy metals in the soil, to
such a level that the site was considered contaminated for residential
activities and that mitigation, through removal of soil was required.
Due to the timing of the NES, both the subdivision and any existing houses do
not trigger the requirements of the NES, however new houses on the vacant
allotments will require an assessment under the NES, and mitigation being
undertaken to bring the soils to ‘residential’ standards.
The Submitter therefore proceeded to investigate the remaining sections
which he still has for sale, and confirmed that removal of soil was also
required for these sites to meet with residential health standards.
Upon approach to the various landfill sites, the Submitter was advised the
cost of dumping soils which do not meet the ‘residential health guidelines’, as
being $114 per tonne of soil at York Valley Landfill.
Given the requirements of the NES, it is expected that more subdividers and
property owners who wish to build a new dwelling or addition will be required
to mitigate their soils to ensure it complies with the residential health
standards, which will place more demand on the Councils’ landfills.
The Submitter also notes that with the recent NCC/TDC Joint Solid Waste
Initiative, the number of landfills available for accepting such materials is
further limited by the closure of Eves Valley Landfill.
Submission LTP 2015-2025 (NCC)
Staig & Smith Ltd – April 2015
Page 2 of 4
Job No 6891
2.0
Submission
Schedule of Charges for Rubbish collection and disposal
The LTP advertises that it has a schedule of charges for Council’s operations.
The Submitter could not find within the supporting documents advertised with
the LTP, the schedule of charges for Rubbish collection and disposal.
The Submitter seeks confirmation as to the Discharge Rates for York Valley,
to be referenced into the Schedule of Charges.
Internal efficiency of resources within the landfill
The Submitter accepts that the Council operate the landfill as a user pays
operation, however seeks that Council review the cost of dumping soils that
do not meet with the residential health standards. These soils are usually still
suitable for other purposes, such as commercial or industrial soils.
The Submitter considers that the Council is able to manage the landfill in such
a manner as to be able to utilise these soils as capping layers within the
landfill. Thus reducing the overall operational budget of the landfill, and
therefore reducing the cost which should be forwarded to the user.
The Submitter therefore seeks that NCC seek to reduce the amount it costs to
dump residentially contaminated soils within the Landfill(s).
Specific landfill site for ‘residentially’ defined contaminated soils
The National Environmental Standard for Assessing and Managing
Contaminants in Soil to Protect Human Health requires an assessment of
soils at the time of land use change (for instance building on an empty section
or potentially extending an existing dwelling), or subdivision.
When soils are found to not meet with residential health standards, mitigation
must occur. Whilst it is possible to potentially mix soils to reduce levels of
contamination, this is not a preferred method when it comes to building sites,
as it makes foundations more difficult.
As such, developers are tending towards stripping the contaminated soils, and
taking them to an approved landfill site.
The Submitter therefore would expect a greater demand being placed on
Council’s landfill resource as a result of the need to mitigate contaminated
soils.
With the recent NCC/TDC Joint Solid Waste Initiative, the number of landfills
available for accepting such materials is further limited by the closure of Eves
Valley Landfill and the acceptance of such material from the Tasman District.
The Submitter seeks that NCC and TDC consider a specific landfill site for
‘residentially’ defined contaminated soils, with a reduced cost to discharge.
Submission LTP 2015-2025 (NCC)
Staig & Smith Ltd – April 2015
Page 3 of 4
Job No 6891
3.0
Relief Sought
The Submitter seeks confirmation as to the Discharge Rates for York Valley,
to be referenced into the Schedule of Charges.
In particular, the Submitter seeks that NCC seek to reduce the amount it costs
to dump residentially contaminated soils within the Landfill(s).
The Submitter also seeks that NCC and TDC review their operations to use
‘residentially’ contaminated soils to act as a capping material, for improved
efficiency of the landfill, and to reduce the overall operating budget of the
landfill.
The Submitter seeks that NCC and TDC consider a specific landfill site for
‘residentially’ defined contaminated soils, with a reduced cost to discharge.
4.0
Hearing
The Submitter wishes to be heard in respect of this Submission.
DATED this 28th day of April 2015
Signed by the Submitters (or their authorised agent)
Submission LTP 2015-2025 (NCC)
Staig & Smith Ltd – April 2015
Page 4 of 4
Job No 6891