Vidler Road began as a sandpit in the 1980s, started accepting waste in the 1990s and progressively became Busselton’s major landfill as restrictions were imposed at the contaminated Rendezvous Road landfill. It ultimately became the City’s only operational landfill, with waste buried in unlined cells until 2018.

“It is already there” cannot justify another generation of landfill. In this environmentally sensitive Cape Naturaliste location, close to Leeuwin-Naturaliste National Park, with nearby homes, landfill-related groundwater impacts, historical unlined waste and complex hydrogeology, would this site genuinely be chosen for a new landfill today — as a regional waste dump and permanent disposal site for asbestos, toxic liquid wastes and hazardous chemicals?

Before approving and proceeding with the expansion (Cell 3, LP3 and potentially Cell 4) that locks Cape Naturaliste into decades more landfill, the City and DWER should demonstrate that Vidler Road remains environmentally appropriate — not simply the location inherited from decisions made decades ago.

The site’s complex underlying hydrogeology raises fundamental concerns about its suitability for another generation of landfill.

The City of Busselton acknowledges the site involves “particularly complex technical issues”, including “complex underlying hydrogeology” and “limited practical access to monitor”. The City also acknowledges that the locations of its off-site groundwater monitoring bores are “not ideal”.

The landfill lies within the karst limestone landscape of Cape Naturaliste, where fractures, cavities and preferential groundwater pathways can make contamination difficult to investigate, predict and manage.

Only two off-site monitoring bores have been installed and only in 2023–24, with the closest approximately 400 metres from the site boundary — the City itself acknowledges their locations are “not ideal”.

More significantly, the City’s Annual Report states that groundwater impacts attributable to landfill leachate have been detected at the western boundary of the Cape Naturaliste tip site (most likely originating from the original unlined landfill) and in an off-site down-gradient bore, indicating that a plume of impacted groundwater is likely to extend beneath neighbouring land to the west. Groundwater flows west-southwest from the landfill, in the direction of Yallingup and Smiths Beach and the coast.

The full source, nature and extent of the contamination remain under investigation, complicated by the site’s complex hydrogeology and practical access constraints.

Yet further landfill expansion is being pursued before the extent of the existing off-site contamination has been fully determined or the publication of initial independent reports.

Previous investigations identified PFOS on-site above guideline values, prompting the need for further subterranean ecology investigation.

This is not merely a drinking-water guideline issue. PFOS can pose risks to groundwater-dependent ecosystems and subterranean fauna at concentrations below drinking-water limits. Yallingup Beach and Smiths Beach are only a few km’s away from this dump site.

Critically, neighbouring residents do not have access to scheme water and rely on private groundwater bores for their water supply. With landfill-related groundwater impacts already identified and an indicated plume extending beneath neighbouring land, protecting this groundwater is not optional — it is the community’s water source.

The technical review identifies the need for a more complete site-specific geological and hydrogeological assessment addressing deeper formations, fractures, voids and preferential groundwater pathways. That is particularly significant where contamination has already been identified and the hydrogeology is sufficiently complex that further contaminated-site investigation remains necessary.

The technical review identifies an apparent assessment gap around the fate and concentration of PFAS, metals, salts and other contaminants as leachate is evaporated, sprayed or recirculated. Evaporation removes water; the public needs to understand how the remaining contaminant load is managed over decades of operation.

Leachate is the contaminated liquid produced when water passes through decomposing landfill waste. It is collected in open leachate ponds, where water evaporates from the exposed surface — It can generate strong and offensive odours as a result of decomposing organic matter and other compounds.

Proposed Leachate Pond 3 (LP3) will approximately double the exposed leachate surface area at the site, yet no dedicated quantitative pond odour study — measuring emissions or modelling dispersion — despite residences being only approximately 210 m and 300 m away.

LP3 alone will provide 11,337 m³ of operational storage, increasing combined operational leachate storage from 14,282 m³ to 25,619 m³ — an increase of approximately 79%. For neighbours, why hasn’t that impact been specifically quantified?

The proposed polluted-water pond is to be constructed over older landfill material. That raises long-term questions about settlement, liner strain, pipework, gas/uplift, leakage and the ability to detect and repair failure. The technical review calls for verified foundation geometry, long-term settlement calculations and a practicable repair/emptying plan before relying on the pond as long-term pollution-control infrastructure.

In the wet-year simulation, leachate storage reaches 25,600.5 m³ against 25,619 m³ of operational capacity — leaving just 18.5 m³, or 0.072%. That margin is smaller than a single nominal 30 m³ water-cart load.

While the model does not predict an overflow, the operational margin is extraordinarily small. If containment were exceeded, polluted landfill leachate could escape into surrounding land and potentially migrate into groundwater or surface drainage.

With more intense heavy rainfall projected under climate change, an 18.5 m³ margin raises a serious question about whether this system is sufficiently resilient for decades more landfill.

The system appears to rely on ongoing active management rather than sufficient passive capacity under wetter conditions. Without enhanced management, the ponds cannot accommodate successive average rainfall years. Wet scenarios rely on removing approximately 2.12–2.32 × 30 m³ water-cart loads every weekday, together with enhanced evaporation.

For infrastructure intended to operate for decades, it should be demonstrated that the system can safely withstand consecutive wet years, extreme rainfall, equipment or staffing failure, periods when spraying cannot occur, or a pond being unavailable for repair.

A system containing contaminated landfill leachate should be inherently resilient — not dependent on continuous intervention to remain within its operational limits.

This expansion is part of a much longer landfill pathway, not simply a new cell to meet an immediate waste need.

The City’s supporting technical documentation states that Cell 3 will be followed by a future Cell 4, with Cell 3 specifically designed so that Cell 4 can tie into it. Proposed Leachate Pond 3 also incorporates additional capacity for the future Cell 4.

Cell 3 alone is expected to provide more than ten years of additional landfill capacity, while the supporting documentation envisages active putrescible landfill operations continuing for at least another 30 years.

The decision being made today therefore has implications far beyond Cell 3. It establishes infrastructure for a continuing sequence of landfill development at Cape Naturaliste — potentially locking this environmentally sensitive site into another generation of waste burial.

Has the environmental acceptability of expanding landfill at Cape Naturaliste for another generation ever been comprehensively assessed by the EPA? The answer is no!

The site already has landfill-related groundwater contamination, an indicated off-site plume, historical unlined waste and complex hydrogeology — with contamination investigations still ongoing.

Yet the City proposes Cell 3, major new leachate infrastructure and ultimately Cell 4, supporting decades more landfill.

The issue is bigger than another works approval. The cumulative environmental impact of decades more landfill at Cape Naturaliste should be EPA assessed as a whole — before further expansion locks it in.

The City states there are “no planning issues” relating to this expansion, yet provides no supporting planning assessment explaining how that conclusion was reached. The site is zoned Rural and the waste facility operates as a non-conforming use. Nearby residents report persistent odour and vibration, while no dedicated quantitative odour assessment has been provided for the proposed major expansion of leachate infrastructure.

Residents have also repeatedly raised road and traffic-safety concerns with the City of Busselton regarding heavy waste-truck movements on Vidler Road and Caves Road. Were traffic volumes, heavy-vehicle movements, road safety and impacts on neighbouring residents considered before concluding there were “no planning issues”?

These are significant land-use and planning considerations. Would a new regional landfill and permanent waste-disposal facility genuinely be considered an appropriate use at this location under today’s planning framework?

The public is being asked to comment on decades more landfill while key groundwater, contamination and hydrogeological information held by DWER has not been included in the consultation documents.

This information goes directly to the environmental risks being assessed. The public cannot meaningfully scrutinise those risks without access to the underlying evidence.

DWER should release all material environmental information and allow sufficient time for proper public review before making a decision.

Caves Road is a major tourism and community route — not an industrial haulage corridor. Heavy waste-truck movements between Busselton and Dunsborough have escalated, creating a repeatedly raised community safety concern. Residents, families, cyclists and tourists are being forced to share these winding roads and blind bends with heavy waste trucks every day.

Residents have reported numerous near-misses on Vidler Road. A recent double semi-trailer rollover on a bend required a major police response — a stark demonstration of the potentially catastrophic consequences for an oncoming vehicle. The Caves Road/Vidler Road intersection is increasingly difficult to negotiate, particularly with double-trailer trucks and during peak tourism periods when traffic volumes surge.

Expanding the landfill means decades more heavy waste trucks on an already hazardous road network — compounding safety risks, noise and loss of amenity for the Cape Naturaliste community and its visitors.

Nearby residents repeatedly report witnessing foxes and other feral animals accessing the landfill beneath fencing, scavenging waste and carrying rubbish back onto neighbouring properties and into Leeuwin-Naturaliste National Park. Residents also report persistent windblown litter escaping beyond the site boundary.

The landfill’s environmental footprint does not stop at its boundary fence. These repeated first-hand reports must be investigated.

The record is difficult to ignore: decades of unlined landfilling; leachate impacting groundwater; contaminants exceeding environmental guidelines; exceedances of permitted liquid-waste volumes; and inadequate containment allowing waste to escape beyond the site. And this is all at the Cape Naturaliste site.  They mismanaged and contaminated the previous landfill site at Rendezvous rd (see below).

This history demands scrutiny before Cape Naturaliste is committed to another generation of landfill. DWER should require compelling evidence that existing contamination is contained, past deficiencies are addressed and further expansion will not compound the environmental legacy.

The former Rendezvous Road landfill now closed (due to contamination) and operates as a transfer station, yet its contamination legacy continues. Approximately 31 remediation and management approaches were investigated and indicatively costed, but contaminant removal was found not to be viable.

Today, 50 privately owned properties remain subject to restricted-use classifications — 45 with restrictions on shallow groundwater use and five where groundwater abstraction is prohibited except for monitoring or testing.

Rendezvous Road provides a powerful reminder: the consequences of landfill contamination — groundwater restrictions, remediation and financial liabilities — can endure for decades after the landfill closes.

The City’s financial reporting states that potential remediation or compensation liability associated with the contaminated site cannot yet be determined. Further landfill investment is therefore being contemplated while the financial consequences of the environmental legacy already present remain uncertain.

The City states that alternative landfill locations, including waste-to-energy and pyrolysis, have “proved not to be financially viable at this stage.” Yet no financial modelling, economic assessment, business case, cost comparison or supporting data has been released publicly to substantiate that conclusion.

The community is being asked to accept decades more landfill at Cape Naturaliste without seeing the economic evidence used to support the decision and to dismiss alternatives.

Any genuine economic comparison must include the full lifetime cost of landfill — closure, rehabilitation, contaminated-site remediation, groundwater monitoring and potentially decades of post-closure management. Further expansion will only add to this potentially expensive long-term liability.

The City should publish its analysis and demonstrate that credible alternatives have been compared against the true long-term cost of continuing and expanding landfill at this site — not simply the cost of operating it today.

South West councils have investigated regional waste solutions since at least 2010, followed by market sounding in 2019. The 2021 Regional Options Paper called for detailed economic and scenario modelling, an Integrated Waste Management Plan and coordinated procurement, with further procurement undertaken in 2023.

Yet the outcomes of this work have not been made publicly available. Ratepayers funded these investigations and are entitled to know: What alternatives were assessed? What did the economic modelling show? What was recommended? And why did years of regional planning not produce alternatives to decades more landfill at Cape Naturaliste?

We call on DWER and the City of Busselton to halt further landfill expansion at Vidler Road and pursue a considered, sustainable regional waste strategy in a more environmentally appropriate location.

Retain Vidler Road as a convenient waste transfer station for the community — but stop burying waste at Cape Naturaliste.

Cape Naturaliste should not carry the burden of the region’s landfill waste for a further three decades.