ORC is reviewing whether the current consent conditions remain appropriate. The review focuses on the conditions attached to the consent and whether any changes may be necessary to ensure environmental effects are appropriately managed.

The review process will determine whether any changes are necessary to the conditions. To help with this, ORC has identified a range of consent conditions that could be looked at. No decision has been made yet on whether the conditions will be changed.

ORC has served a notice of review on the consent holder.

The review will be processed in a similar way to a resource consent application and follows the statutory process. This includes an assessment of whether the review should be non-notified, limited notified, or publicly notified.

If notification occurs, submissions may be received and a hearing may be held before any decision is made on whether the consent conditions should change.

The below flow chart shows the key stages for a review under the RMA:

Whether the public will be able to make a submission will depend on the notification assessment and decision.

An independent decision maker will decide whether the review should be publicly notified, limited notified, or processed on a non-notified basis. That decision will be made in accordance with the Resource Management Act.

If the review is notified, submissions can only relate to the matters being considered as part of the review. The review is focused on the consent conditions.

A hearing will be required if submissions are received and people wish to be heard; or if the consent holder wishes to be heard; or if it is determined that a hearing is necessary. No decision has been made on this at this stage.

The consent remains in effect while the review is underway. The review process does not prevent the consent holder from continuing to operate in accordance with the existing consent conditions.

Yes. ORC will continue to undertake its normal compliance, monitoring and enforcement functions while the review process is underway. The additional monitoring being undertaken by ORC will still occur.

The timeframe will depend on a number of factors, including the notification decision, whether submissions are received, and whether a hearing is required.

ORC is the regulator of this activity. Our role was to assess the resource consent application against the relevant requirements of the Resource Management Act and rules in the Regional Plan and determine whether the activity could be undertaken subject to appropriate conditions to manage environmental effects. We also ensure that consented activities then comply with the conditions of their consent and that environmental effects are appropriately managed. This is a role which ORC takes seriously. Where concerns are raised, these are considered as part of our ongoing compliance and monitoring responsibilities.

The consent is held by SJ Allen Holdings Limited (SJ Allen), a commercial waste disposal firm that services wastewater treatment plants (WWTPs), grease traps, mud tanks/sumps, winery wastewater, portaloos and septic tanks. The consent runs until 28 January 2041 and is subject to 29 conditions that ORC monitors for compliance.

Yes. Grease trap, mud tank/sump and winery wastewater have previously been discharged at another SJ Allen property under a separate consent (RM20.287.01.V1). SJ Allen is consolidating these activities at the Lauder site.

The consent permits discharge of five waste types to land at a rural property in Lauder, Central Otago.

This includes: waste activated sludge (WAS) from Wastewater Treatment Plants, grease trap waste, mud tank/sump waste, winery wastewater, and similar waste types that meet Soil Eco-Guideline limits.

It allows for up to 34.2 tonnes of N/yr (or 102.5 tonnes of N in a 3-year return period), and 3,600 m³ of grease trap, mud tank and winery waste to be disposed of over a total of 178 ha. For the first 12 months, WAS can be spread on no more than 50 hectares in total.

The waste is being spread on farmland in Lauder, approximately 1km northeast of the intersection of Muddy Creek Road and Brown Road. The discharge cannot occur within:

• 10 metres of any property boundary

• 20 metres of any formed public roads

• 20 metres of ephemeral wetlands

• 50 metres of any other natural surface watercourses

• 20 metres of any water storage ponds

• 5 metres of any irrigation races

• 200 metres of any residential dwellings

There is also a surface water take on neighbouring land to the south. A permanent 50m exclusion zone applies around a surface water take on neighbouring land, plus an additional 200m buffer for the first five years of the consent.

The application identified:

• Irrigation bore G41/0296 approximately 910 m from the discharge area

• No other bores within 2 km

• No domestic groundwater takes downgradient within 2 km

Potential effects on registered permitted takes and consented groundwater and surface water takes were assessed as part of the process as required by the Act. The consent includes conditions requiring groundwater monitoring, setbacks from waterways and ongoing reporting.

The disposal at this location has been occurring since June 2026.

There are no operations which exactly match the Lauder site, however the disposal of wastewater to land does occur elsewhere. There are more than 200 resource consents in Otago which allow for the discharge of treated sewerage to land. These range from single dwelling septic systems to Wastewater Treatment Plants.

The certified Operations and Maintenance Manual (OMM) requires:

• Regular site walkovers.

• Monitoring for surface ponding.

• Monitoring for odour during and after application events.

• Weekly inspections of Waste Activated Sludge (WAS) application areas.

• Daily inspections of grease trap and mud sump trenches.

• Complaint recording and investigation procedures.

• Ongoing contact with neighbours to identify any adverse effects.

For WAS, material must be incorporated into soil within 24 hours to a minimum depth of 50 mm. For grease trap and mud sump waste, trenches may be covered if odour becomes apparent. Covered trenches are also reinstated and planted.

The consent requires installation of a groundwater monitoring bore (BH-001), collection of two baseline groundwater samples and ongoing monitoring. Currently, monitoring occurs quarterly for the first two years and then annually. Parameters include:

• pH

• Chloride

• Electrical conductivity

• E. coli

• Nitrate/nitrite nitrogen

• Ammoniacal nitrogen

• Dissolved reactive phosphorus.

The OMM goes beyond the consent by including monitoring of:

• BH-001 (required consent bore).

• BH-002 (additional bore installed by the consent holder).

The OMM notes that BH-002 is located upstream of the neighbouring drinking water take and will be monitored quarterly.

The amount of Nitrogen (N) applied in the WAS per hectare (Ha) and the amount of N used by the crops planted is also monitored. This helps provide information on the N left in the soil and at risk to leaching.

Upstream and downstream surface water sampling will be undertaken by Council every two weeks. Additional groundwater sampling of bores in place to monitor the activity will be undertaken by Council in between samples taken by the Consent Holder. This will be undertaken by ORC as part of their compliance programme.

Monitoring of township bores or private supplies by the Consent Holder could only be introduced through consent review, future consent amendments or voluntary monitoring.

The consent requires extensive monitoring of contaminants including:

Groundwater

• E. coli

• N species

• Phosphorus (P) indicators

Waste streams

• Heavy metals including arsenic, cadmium, chromium, copper, lead, mercury, nickel and zinc

• Hydrocarbons

• Nutrient parameters

The OMM also includes the monitoring of:

• Soils

• Nutrients

• Heavy metals

Surface water

• N species

• P indicators

• Sediment indicators

The certified OMM includes:

• Quarterly monitoring for the first five years

• Upstream and downstream monitoring

• Monitoring in both Clear Creek and the Lauder Creek tributary

Any additional monitoring could be considered as part of a review process or added voluntarily by the Consent Holder.

Additional monitoring upstream and downstream of the site in Lauder Creek started the week of the 19th of October. This will be undertaken by Council every two weeks.

The consent does not require monitoring at the Lauder SOE site. The monitoring required by the consent and OMM are highly likely to detect any environmental effects. Any abnormal pattern detected at a SoE site is always investigated and would trigger more frequent monitoring. Council routinely monitors this site and results are publicly available.

The consent requires ongoing characterisation of each waste type. Sampling frequencies range from every 100 m³ to every 500 m³ depending on the type of waste.

The consent does not require testing of every individual load before arrival.

Management occurs through:

• Waste-stream monitoring

• Heavy-metal testing

• Soil monitoring

• Groundwater monitoring

• Crop monitoring

• Nutrient budgeting

• Environmental Management Plan (EMP) and OMM Reporting

• Soil Eco-Guideline thresholds

Yes, compliance visits and associated monitoring are paid for by the Consent Holder.

The results will be uploaded 2-3 days after Council has received them.  Generally, the lab takes 7-10 days to process the results after they have received the samples. All received results available prior to 5 August 2026 were published on October 12, in a bulk upload whilst council developed the webpage to display the data. Results from ORC monitoring will also be made available on the webpage.

The consent requires five-yearly soil monitoring for heavy metals. The OMM expands this to also include:

• Total N

• Total P

• Olsen P

• Potassium

• Sulphate

• Calcium

• Magnesium

• Sodium

• pH

• The soils Cation Exchange Capacity (CEC)

• Total carbon (C)

• C:N ratio

A control area where no biosolids are applied is included for comparison.

Irrigation has been reduced from previous levels. It is primarily required to help with crop yields, and only when the soil is dry. The OMM and consent require:

• No application during heavy and persistent rainfall.

• No application to saturated soils.

• No application where incorporation requirements cannot be achieved.

• Only applying when there is a soil moisture deficit in the top 50mm of soil within 200 m of any water takes.

The material authorised by the consent is treated organic waste. Information on the nature of the material and associated risks was assessed through the consent process and the consent includes conditions requiring management and monitoring to manage potential effects on human health and the environment.

Yes. The assessment considered the suitability of the land, nutrient loading, application rates and the potential effects on soil, groundwater and surface water. The consent includes limits, management requirements, monitoring and reporting conditions to ensure the activity operates within the parameters assessed through the consent process.

ORC has received a number of complaints relating to potential odour issues. ORC regularly visits the site and undertakes odour assessments. The discharge to land activity is authorised by a resource consent. There is no resource consent allowing a discharge to air meaning the consent holder and must comply with ORC’s permitted activity rules in relation to any air discharges relating to dust and odour. Those rules state that no offensive or objectionable odour can occur beyond the property boundary. To date, ORC have not detected any offensive or objectionable odour beyond the site boundary.

Under the Resource Management Act, whether an odour is "offensive or objectionable" is ultimately a matter for Council to determine having regard to professional judgement, site observations, complaints and the surrounding environment. More information can be found here https://www.orc.govt.nz/environment/air-care/odours

To date there has not been any evidence of dust discharges beyond the boundary, but ORC staff are aware of the concern and will be monitoring as we head into Spring and Summer. Dust monitors may be put in place proactively by Council to monitor the site. Any photographic or video evidence of dust discharges can be sent to the ORC Pollution Hotline.

Results of odour assessments will be published on Council's website.

The WAS uses the current NZ Biosolids guidelines to meet the stabilisation grade 1 for vector controls. The key vector attraction reduction (VAR) process is the undertaking of soil incorporation within 24 hours. Although the consent does not require a dedicated pest monitoring programme, the OMM includes a number of operational controls intended to minimise attraction of birds, rodents and insects:

• WAS is incorporated into soil within 24 hours.

• Sowing of a catch crop as soon as possible after the WAS application (generally within one month).

• Grease trap waste is placed at the bottom of trenches.

• Trenches are progressively filled and capped.

• Odorous material can be immediately covered with excavated material.

• Reinstated trenches are planted.

• Daily trench inspections occur.

• No open WAS stockpiles are authorised.

The notification decision and consent duration decision are separate assessments under the Resource Management Act. The consent duration was considered under section 123 of the RMA. While the Act allows resource consents to be granted for up to 35 years, a 35-year term is not the default or expected outcome. The report also referred to relevant policy direction supporting an adaptive approach and not the maximum duration. For those reasons, a shorter consent duration was considered more appropriate than the maximum available term.

The application was processed on a non-notified basis. ORC's analysis under the steps required by the Resource Management Act 1991 (RMA) found public notification was not required as effects were not expected to extend beyond the property boundary.

The activity is a discharge of industrial or trade waste contaminants to land and identifies it as a discretionary activity under Rule 12.B.4.1. Although agricultural production forms part of land management, the consent is regulated as a contaminant discharge activity rather than a farming

Condition 29 to the resource consent enables the allows ORC to initiate a review of the consent conditions. Under condition 29, a review can be initiated:

• each year, within a three-month window either side of the anniversary of the consent being granted (28 January);

• within two months of taking any enforcement action; or

• after receiving monitoring results.

A review initiated under condition 29 can be for the purpose of:

• determining whether the condition area adequate to deal with any adverse environmental effects that may arise from the exercise of the consent and which it is appropriate to deal with at a later stage, or that become evident after the consent commences ;

• ensuring the conditions are consistent with national environmental standards, regional plans, or the Otago Regional Policy Statement;

• reviewing how often monitoring or reporting is required;

• amending the monitoring programme; or

• requiring SJ Allen to adopt better practices to prevent or reduce environmental effects.

Condition 29 reflects section 128(1)(a) of the Resource Management Act 1991, which provides that reviews may be initiated at times and for purposes specified in the consent. Section 128 also enables reviews of consent conditions to be initiated for other specified purposes.

Council is considering if a review is appropriate and working to the date around the 3-month anniversary.

Yes. Consents can only be cancelled in specific situations, as set out in the RMA. The situations are very limited and include:

1. Where the consent has previously been exercised but has not been exercised within the preceding five years.

2. Where the council reviews the consent under s 128(c) of the RMA and the review process finds that:

• the information supplied by the applicant in the consent application contained inaccuracies which materially influenced the decision made on the application; and

• there are significant adverse effects on the environment.

3. An enforcement order is made by Environment Court that cancels or revokes the consent,

4. The consent holder has been convicted of an offence for contravening the consent; and

• the Court has ordered the consent authority to review the resource consent; and

• there are significant adverse effects on the environment.