As stated on page 6 of the Environment Effects Report (EER), the proponent current stockpiles tyres at the development site, subject to the permit P13-199 issued by the Northern Midlands Council, but has now made the planning application P16-077 which seeks permission to store and shred tyres at the same site.
The proposal aims to continue to collect tyres at the site and shred these plus
those currently stockpiled at the site.
While the Project Description, contained in the EER, states that it is the
proponent’s intention to take shredded tyres off the site there is no
management comment to this effect in Part D.
The TCT finds it difficult to know exactly what the scope of the project is, what
the extent of the Council and EPA’s authority is and how the existing permit P13-
199 will relate to any approval that might be granted by the EPA and Council.
For example, it is unclear whether the EPA and/or Council are regulating the
removal of tyres from the site and whether it intends applying controls, in
particular in regard to fire management, over the currently stockpile of tyres as
well as those proposed to be sent to the site? This is critical given our concerns
regarding how the current stockpile is managed (see below).
The TCT wants to see the current stockpile and any additional tyres taken to the
site removed as soon as possible, that the amount of tyres stockpiled at the site
is kept to a minimum and that all tyres are stored in a manner that minimises the
risk from fire.
Assuming the EPA and Council have the required authority, it is critical that
conditions are applied that:
- guarantee that all tyres currently stored at the development site and
those proposed to be sent there are managed subject to the current
best practice fire guidelines; and
- guarantee the tyre stockpile is removed entirely from the site by the end
of 2020 (preferably with annual targets of at least 25%), either by the
proponent or, if this is not possible, by another approved operator; and
- that tyres proposed to be sent to the development site are also removed
from the site, with an appropriate level of ‘new’ tyres able to be
stockpiled e.g. 100 tonnes.
The TCT recommends that the proponent be required to pay a $ 2million bond
to the EPA to be used to remove the tyre stockpile if the proponent fails to do
so. We understand this amount is sufficient to have the tyres shredded and
transported to a mainland recycling facility.
Furthermore, the proponent should be required to meet annual or six month
targets, e.g. 25% per year of the total stockpile, and that failure to do so will
trigger the closure of the business and the use of the bond to remove the tyres.
SPECIFIC COMMENTS ON THE ENVIRONMENT EFFECTS REPORT (EFR)
Potential Environmental Effects
1.0 Flora and fauna - Weed management
The proposal in the EER to “grub out” gorse as a measure to minimise fuel build
up is not sufficient. It is important to control weeds such as gorse for reasons
other than fire management e.g. to control its impacts on environmental and
agricultural values. Grubbing gorse out is a sure way to assist with spreading
seeds and stimulating germination. Smaller mature plants can very easily be cut
and pasted and bigger plants and clumps sprayed and dead wood later cut
out and removed. Grubbing out is also only possible once plants are
established and younger plants are best controlled through spot spraying.
A condition should be applied requiring the development of a weed
12.0 Hazardous substances and chemicals - biosecurity and human health risk
The EER fails to make any assessment of the potential for tyres that are
transported to and from the site to contain weed seeds or other biological
material that poses a biosecurity risk. Clearly shredding would only slightly
reduce the risk by removing some but not all soil and other biological matter.
A condition should be applied requiring the development of a biosecurity
The EER fails to make any assessment of the potential for tyres to store water
and be an environmental health risk. This is of particular concern given the way
the tyres are stacked, which allows easy entry of water (see below for further
A condition should be applied requiring an assessment of the risk of disease
from tyres accumulating water and appropriate management measures be
13.0 Fire risk
The existing stockpile seems to not comply with the stacking requirements for
outdoor storage of tyres as per the ‘General Guidelines for Rubber Tyre Storage’
(2014), which is attached to the EER.
The attached aerial photo of the site (dates from December 2015) and more
recent image from the Examiner newspaper (also attached) show numerous
non-compliances with stacking requirements, including:
- Tyres not laid flat or laced;
- Tyres are in rows greater than 20 metres in length and greater, in some
cases, than 6 metres in width (see aerial photo)
- Aisles are less than the required 20 metres (see aerial photo).
We note that in Figure 1, Appendix H, the correct pile layout is show, overlayed
on the aerial image of the existing tyre piles. This clearly shows the noncompliance
with the stacking requirements.
The EER states that stacking of tyres will be according to the ‘General
Guidelines for Rubber Tyre Storage’ but there has been no assessment as to
whether the tyres currently stored at the site comply with these requirements.
We assert that they do not comply and that a condition must be applied to
require an assessment of the current stacking and that remedial action be
taken to correct non-compliances prior to the operation commencing.
Additionally, the row of mature pines trees shown in the aerial picture poses a
fire risk and should be removed.
The EER states that water is available from an irrigation pipeline and dams on
the property but makes no assessment of the potential for these water sources
to be limited during the hotter period of the year when fire might be expected
to be a higher risk. There is no management commitment made in this regard.
A condition should be applied that requires an appropriate quantity water to
be kept in storage at all times.