22 December 2014
Horowhenua District Council
Private Bag 4002
File ref: 1/4/HDC
Attention Arron Cox
LEVIN LANDFILL OBJECTIONABLE ODOUR BEYOND THE PROPERTY BOUNDARY
On 13 November 2014 I attended a Hokio Beach Road address in relation to Levin Landfill
odour complaints. The complainant had filled out a Horizons Regional Council (HRC) odour
diary which covered the period 22 March 2014 to 30 September 2014 at the time of the visit.
The odour diary includes the time, duration, continuity, intensity and odour character of each
odour event the complainant detected.
In relation to objectionable odour beyond the landfill boundary condition 3 of resource
consents 6011 states:
There shall be no discharge of odour or dust from the landfill that in the opinion of a
Regional Council Enforcement Officer is noxious, dangerous, offensive, or
objectionable beyond the property boundary.
Based on the complainant’s odour diary I have deemed there has been 27 occasions during
the above period where the intensity and character of odour discharged beyond the landfill
boundary would be offensive or objectionable to an extent where it would adversely affect the
complainant’s environment. Therefore condition 3 of resource consent 6011 has been
graded as Significant Non-Comply
due to the on-going nature of these odour complaints.
Horowhenua District Council advised HRC that Doug Boddy, MWH Air Quality Scientist, has
carried out a Landfill Odour Assessment. The assessment report is scheduled to be
submitted to HDC in January 2015. HRC strongly recommends HDC provide HRC with a
copy of the Landfill Odour Assessment report and implement recommendations contained in
the report as soon as practicable in order to ensure compliance with condition 3 of resource
As a result of this assessment Levin Landfill has been given an overall Significant Non-
for condition 3 of resource consent 6011. Please note that since the Levin Landfill is
at the time of this invoice not complying with the conditions of its resource consents, the
compliance monitoring charges are 100 per cent of the full charge as detailed in the attached
Please find attached a copy of Horizons Regional Council’s Compliance Assessment
Guidelines for your reference.
If you have any queries about the attached report, please contact me via email [email address]
or on 0508 800 800.
Stuart Standen CONSENTS MONITORING OFFICER
Table 1. Compliance Assessment Guideline for Individual Consents
Comply - Exceeds
Consent holder has implemented practices, procedures, systems that are over and above that required by the
resource consent or consents for the site which are having a tangible environmental benefit.
Comply - Full
Complying with all conditions of consent; and/or
A non-compliance has occurred beyond the control of the consent holder; and/or
One Minor Non-Compliance with a condition of the resource consent.
Comply – At Risk
At Risk grading identified against key condition(s) of one or more of consents for the site.
Comply – On Track
At risk grading identified AND site has entered into a Compliance Pathway Agreement (CPA) to reduce system
risks and achieve best practice.
There have been two ‘first time’ Non -Compliances with the conditions of consent; and/or
There has been one repeat Minor Non-Compliance with the same or similar condition.
There has been at least one Significant Non-Compliance Rating with a condition; and/or
There has been at least two repeat Non- Compliance Ratings associated with the same or similar condition;
There have been three or more ‘first time’ Non Compliance Ratings.
Monitoring has not been undertaken of this consent during the reporting period.
Table 2. Compliance Assessment Guideline for Individual Conditions
Adverse Effects Scale
Examples (not exhaustive)
Consent holder has implemented practices, systems, and
procedures that are over and above that required by the
resource consent and are having tangible environmental
Conditions of consent are fully complied with.
Comply - Full
Sampling out of sequence or late due to circumstances outside
of consent holders control (e.g. flow related sampling).
Nil – de-minimus.
: de-minimus - need Compliant at time of inspection but management / system
not be considered. In terms of
deficiencies indicate there is a real risk of a non-compliance
the RMA the term means an
occurring (e.g. insufficient effluent storage, poor irrigator
effect which is less than minor, performance).
of no consequence, so trifling
that it should be disregarded).
System has been identified as At Risk, but the consent holder
Comply – On
has agreed to enter into a Compliance Pathway Agreement
Nil – de-minimus.
(CPA) to ensure compliance is consistently achieved. Consent
holder is currently complying with conditions of consent.
One-off failure to comply with a condition of consent (e.g. One
off minor exceedance in key parameter in 6-months worth of
sampling (allows for two minor exceedances in a 12-month
Intent of condition met however data and / or report provided
De-minimus to less than minor.
late (no later than 6 weeks).
First up failure to install a water meter for a small take
(stockwater), provide management plan or environmental
information (e.g. water quality information) within required
More than minor and / or Four minor exceedances of key parametres for one year’s
worth of sampling / data.
Repeat failure to provide a report or monitoring data.
comparatively small in size or
Repeat Failure to undertaken sampling.
Failure to install water meter for a more than minor take (e.g.
: continuing irrigation).
Water quality results indicate there is a potential for or an
More than minor to significant, actual effect which is more than minor that is not authorised by
serious and / or ongoing.
the resource consent.
: Unauthorised discharge of wastewater / effluent into water or
noteworthy, onto land where it may enter water, excessive ponding of
effluent on the land surface.
: important, Repeated failure to provide a report/monitoring data/
demanding consideration, not management plans/install water metering equipment etc.
Repeated failure to undertake sampling.
: continuing Repeated failure to comply with authorised discharge or water
Applies to conditions that are no longer applicable. Generally
relates to historic conditions that may require provision of a
management plan, which has been provided and consent
requires no further action.
Monitoring not undertaken of consent condition.