our guide to Making your Submission

Start with whether you support or oppose the application.

The application includes two main activities; an increase in lime extraction and the creation of a landfill to accept hazardous building waste.

Try to be clear and concise - what impacts could this landfill have on you, your community, and the surrounding area? Any colourful language will result in your submission being struck out.

Commissioners will be assessing the risks of the application and determining whether those risks have been adequately eliminated or minimised. Broadly speaking, if you oppose the landfill, your submission should aim to do 3 things:

1: Show that ProTranz has overstated the benefits to the community and understated the risks to the community and local ecosystem.

2: Push back against ProTranz’s assurances that the risks will be well managed.

3: Show why this application will harm community identity, and why it is not aligned with our community’s vision for the future.

This is YOUR story

Make it personal. Why do YOU reject/accept ProTranz’s landfill application? Include your local knowledge about anything that might be relevant to the application, including

local flooding events
high wind events
local ecology & geology
prior dealings with the applicant

Below are some concerns that you may want to pick from to include in your submission:

Water

One of the major issues with the application is that the landfill would be very close to the Karetu River, which feeds into the Okuku and Rakahuri/Ashley Rivers. If there is damage to the landfill liner (e.g. tearing, fire, earthquake, incorrect installment), contaminants from the landfill would not be contained and could enter local water courses. Also: consider that the liner has a limited life expectancy (20-100 years).

Several local families obtain drinking water downstream of the quarry. Many families use the water downstream for irrigation and recreation.
The application also proposes to take clean water from the river to damp down their asbestos for the twenty years they plan to keep dumping. What will happen in times of drought, when the Karetu runs dry?

In the case of fire, toxic chemical foams would be required because water alone would not extinguish the likes of old tyres in the landfill - where will those chemicals drain? There are also concerns about storm water runoff over contaminated material. Flooding is not considered to be a major risk by the applicant, but those of us who were here for recent major floods may disagree!

Air & Wind

White Rock is in an extreme wind zone. The famous North Canterbury nor’wester funnels down the valley, humbling all in its path. Asbestos is an airborne carcinogen. Even if ProTranz employed all best efforts (including using pure Karetu water to keep waste dampened), the nor’west can’t be underestimated.

Traffic

While ProTranz say that this landfill would only add an additional 20-something traffic movements per day, this is deceptive. Their application seeks to factor in days lost to weather conditions, and stack traffic movements onto the days when they can operate. This means we could see more like 200+ movements on those days. BIg trucks, narrow roads, toxic loads. How do you use these roads? Walkers, runners, school kids, horseriders, cyclists, etc.

Flora & Fauna

The landfill project would cause direct disruption to flora and fauna in the current footprint of the proposed landfill, particularly for native lizards (ProTranz are applying for a wildlife permit to relocate lizards living on the landfill site). The cliffs behind the quarry are a nesting site for Kararea /NZ falcons. The proposed quarry expansion would put a Significant Natural Area under threat. The Karetu river is home to tuna (eels), cockabullies, and kōwhitiwhiti (watercress).

Harm to community identity & values

White Rock is a quiet and peaceful place, with a rich history and incredible natural surroundings. ProTranz’s plans would industrialise the area, altering the feel and identity of the community and putting the local ecosystem at risk. While the community and local ecosystem carry the risks of the landfill, ProTranz will be the only ones that profit. ProTranz argue that the landfill with have a positive impact on the community and landscape values - we disagree!

Long Term Risks

The risks of the landfill contaminants will outlive the consent period. Once those contaminants are buried, the waterways will be at risk long term if anything goes wrong with the liner or the drainage systems. Who will take responsibility for managing the risks once the landfill is closed down?

Unreliable Applicant

The trustworthiness of the applicants is vital. Can we trust ProTranz to uphold best practice? We know they have violated the terms of their resource consent at their Leggetts Rd facility, and they have been operating the Whiterock Quarry without consents. What would happen to this site after consents lapse or if they go out of business? Who would clean up after them? Who’d pay for it?

If you’d like to submit your opposition to the landfill online you can do so here. A copy will be emailed to you once you hit submit.

Here is a link to a Wordpress Doc version of the form. You can either print this form, fill in in by hand and mail it to the address at the top of the form, OR download the form, fill it in and save it, and email it to hearings@ecan.govt.nz

Here is an example form to help you in your process, and here is a downloadable copy of this submission guide.

Notes to the submitter

  1. If you make an online submission a copy will be sent to the applicant.

  2. All submissions received will be provided to the applicant.

  3. Privacy: The information requested on this form, including your contact details, is required by the Resource Management Act 1991 (RMA). The information will be held by the Council, and you may ask to check and correct any personal information that we hold about you. The RMA requires your submission, including your name and contact details, to be made available to the Council (including the Council decision-maker) and the applicant.
    Your submission, including your name may also be made available to other submitters and to the public on the Council’s website, or on request. If requested, the Council may legally be required to make all submissions available to the public (which can include the media), including the name of the submitter, subject to the provisions of the Local Government Official Information and Meetings Act 1987 (LGOIMA) and with careful consideration of the Privacy Act 2020.
    If you believe there are compelling reasons why your name should be kept confidential from other submitters or the public under LGOIMA, please contact hearings@ecan.govt.nz prior to making your submission.

  4. Delegation to Hearing Commissioners: If you make a request under section 100A of the Resource Management Act 1991, you must do so in writing no later than 5 working days after the close of submissions and you may be liable to meet or contribute to the costs of the Hearing Commissioner or Commissioners. A request cannot be made in relation to an application for a coastal permit to carry out an activity that a regional coastal plan describes as a restricted coastal activity. Please note that Environment Canterbury delegates the functions, powers, and duties to hear and decide the application(s) to one or more hearing commissioners where there are submitters to be heard, and a hearing is required under s100 of the Resource Management Aa 1991 (the RMA). Where there are no submitters to be heard and a hearing is not required the decision-making Is undertaken by the Council committee and/or delegated staff.

  5. lf you are a trade competitor. your right to make a submission may be limited by the trade competition provisions in Part 11A of the Resource Management Act 1991.

  6. Please note that your submission (or part of your submission) may be struck out if the authority is satisfied that at least 1 of the following applies to the submission (or part of the submission):

    • it is frivolous or vexatious;

    • it discloses no reasonable or relevant case;

    • it would be an abuse of the hearing process to allow the submission (or the part) to be taken further;

    • it contains offensive language;

    • it is supported only by material that purports to be independent expert evidence but has been prepared by a person who is not independent or who does not have sufficient specialised knowledge or skill to give expert advice on the matter.