Holcim Salt Ash Sand Operations

In order to add my voice as an advocate for the better protection of koalas in Port Stephens and neighbouring LGAs, I fully support the submission put forward by the Koala Koalition Econetwork Port Stephens Inc. On environmental grounds, I object to the proposal put forward by Holcim Salt Ash Sand Operations. Given the 'endangered' status of the koala, the destruction of further habitat in the Port Stephens area will only serve to take the status of our koala population closer to the 'critically endangered' status beyond which is extinction which provides absolutely no comeback.

Please see submission in the attachment section below.

I would like to bring it to your that Koalas are deemed Endangered and the Squirrel Glider is also at high risk of extinction as it uses the same kind of forest as koalas. Other vulnerable threatened species identified on the site in question include six microbats, four birds, and the New Holland mouse, so this is what we need to protect for the long term future.
The proponent admits that the Koala Habitat Information Base records the site as being within the Port Stephens ARKS (Area of Regional Koala Significance), that there is 20 – 50 % likelihood of Koala occurrence, that the range of habitat suitability on site for koalas is between 50 – 90 % and that the site is comprised of 60 – 70 % suitable feed trees.
However, the Proponent is not correct in stating that the koala is ‘vulnerable’ in their Biodiversity Impact statement, which leads me to question the viability correctness of the statement and this should be given great scrutiny. The koala was listed as Endangered by both State and Commonwealth legislation in 2022. The koala is not the only threatened creature as mention in my open statment
Undisturbed areas
Although the site is identified as supplementary rather than core koala habitat due to previous habitat clearance reducing preferred koala feed trees (PKFTs) to less than 15% of the cover, the remaining ‘high, preferred use’ PKFT E. robusta (swamp mahogany) in the undisturbed areas provides a vital corridor through the sand mining properties to the Worimi National Park. E. tereticornis (forest red gum) is also a Port Stephens PKFT and is located in the same area.
Proposed changes to the current undisturbed boundary area of 30m from south, east and north, to just 10m on north, east and west, will “force” removal of most of the remaining preferred koala food trees (PKFT) identified on the proponent’s following map.
I am objecting to this project.

I object to this proposal because it has multiple unacceptable environmental risks, including potentially serious compromise of the groundwater, effects on biodiversity, and increased heavy truck traffic.

Objection attached

KKEPS objects on environmental grounds to this proposal. We recommend it not be approved until much more detail is provided by the proponent on the biodiversity impacts.

Please find attached our objections to Holcim Salt Ash Sand Quarry Operations.

Major Projects Team - NSW Government
Attn: Mr James Mcdonough, Project Planner

To James,

I refer to Holcim Pty Ltd seeking approval for continued operations at their site through a State Significant Development (SSD) application under Part 4, Division 4.7 of the NSW Environmental Planning & Assessment Act 1979 (EP&A Act).

Holcim Pty Ltd have proposed to extract and process up to 550,000 tonnes per annum (tpa) of sand at its Salt Ash site using dry extraction and dredging techniques.

Oakvale Wildlife Park have concerns regarding the proposal made by Holcim Pty Ltd, please find below our background and key points for your consideration.

Background

Oakvale Wildlife Park was established in 1979 and has been a permanent fixture on the tourism “must dos” of Port Stephens and the Hunter since that time. The Park has continually improved since its inception in 1979, increasing in size and prominence in the region. This commitment continues with plans to continue to expand into the future which have been in train for many years in preparation of the expansion of the park, including into African Animals.

The most recent addition to the park is the Koala Breeding and Education Centre, which has successfully protected and bred koalas within a purpose-built facility and well-established food tree reserves.

The Park currently employs approximately 38 paid staff and 36 volunteers, providing a significant economic driver for the region by attracting visitors from not just the immediate local area but from across the nation and international visitors.

Visitation to the park in 2020 has been impacted by Covid 19 and the restrictions associated with managing the virus. However, with the opening of State borders, increase in domestic travel and the eventual opening of international borders, visitation is expected to continue to increase in line with trends to date.

Oakvale has a commitment to sustainability, being Ecotourism certified, members of the Zoo and Aquarium Association (ZAA) and have implemented an environmental management plan as recognition of their commitment to a sustainable future.

Key points

• Negative impacts due to the increase in traffic volume, mainly heavy vehicles. Negative impacts include:
o Potential risks imposed on visitors traveling to Oakvale Wildlife Park
o Reduction in infrastructure quality and longevity to our private road
• Noise pollution and environmental impacts from the diesel-powered dredges. There is currently several programs protecting and breeding threatened and near threatened species, such as Koalas, Tasmanian Devils, Quolls and Lumholtz Tree Kangaroos. These programs are nationally significant and have the potential to be considerably impacted by an increase in noise pollution. The implications of these impacts of noise and vibration on sensitive animals is significant. Implications include:
o Unavoidable vibration impacts for the many reptiles at the Park, which when placed under stress will often develop health conditions.
o Similarly with sensitive bird species, vibration, noise, and light could cause them to fly into the mesh of their enclosure in response to fear or disorientation from these foreign disruptions.
o Koalas and other native mammals such as Lumholtz Tree Kangaroos and Tasmanian Devils can become stressed causing a vast range of health implications from ceasing natural breeding patterns resulting in that animal not being able to breed for the remainder of its life, developing retrovirus including lymphomas and cancers, loss of appetite resulting in weight loss and subsequent death.
• Effect to water quality and reduction in water availability/volume due to an additional 402.2 ML pa planned to be unitised by Holcim Pty Ltd. Oakvale Wildlife Park currently requires the use of water to service the entire facility, including the supply of drinking water to all the animals on-site. A reduction in water quality has the potential to have negative health impacts to all the animals held within our facility, including threatened and near threatened species.
• Decline in visitation and revenue due to Health and Safety concerns from visitors (e.g. noise pollution, high traffic volume). Oakvale Wildlife Park currently employs 74 individuals in both paid and volunteers roles. A potential decline in revenue would impact the number of employees able to be retained and other significant financial impacts. This will also take away the opportunities for planned future growth of the park and therefore the opportunities to allow the park to make a bigger environmental and economic contribution to the region.

We thank you for your consideration of this submission, and we look forward to hearing from you.

Kindest regards,

Leanne Sansom
CEO/Owner
Oakvale Wildlife Park
3 Oakvale Drive, Salt Ash NSW 2318

I wish to lodge my objection to this proposal.
Without having to prepare a lengthy submission, my reasons for objecting are all contained in a submission being provided by KKEPS.

Having been involved with planting over Three Thousand Trees with the RAAF on land that has been donated to the Port Stephens Koala Hospital I strongly object to anymore mature trees being recklessly cut down just so that sand can be mined.
I have seen the result of dredge mining first hand at Mallabula with the total lack of care given into what species of replacement trees have been planted. Let alone having more large trucks impacting travel, local residents and most importantly some rare and endangered wildlife.
People come to Port Stephens to capture an exciting glimpse of out bird life and other animals.
To loose this ability is a real act of VANDALISM and should not be allowed.When is it going to stop how much sand can be removed from Port Stephens without an environmental impact on our delicately and highly endangered coast
Regards
Paul

I object to the development of ‘wet sand mining’ as it poses a high risk to the quality of drinking water to the Tomaree Peninsula. The water table is very close to the surface and ‘wet sand mining’ can damage aquifers in this fragile environment.
Heavy truck movements along the already overloaded roads along Tomaree Peninsula, are potentially harazardous. Adding extra heavy truck movements to these roads may lead to the early deterioration of the road surfaces.

I object to this proposal because;
Mining below the water table could cause damage to the surrounding areas drinking water,also I have concerns about the pfas in the area close to this site.
The extra truck movements this will bring is very worrying,as this is road is so full of trucks now with the other sand mining in the area,the local roads are not good enough for all of these trucks.

We are writing to object to the Holcim Salt Ash Sand Operation SSD-9099356. We believe the project raises unacceptable risks to water quality, water reliability, and the costs of water management for Port Stephens, Newcastle and the Lower Hunter. The potential for environmental harm to the Worimi National Park has not been sufficiently considered or mitigated. The final landform does not align with community values for environmental sustainability and has questionable feasibility. The result is a project that would not be in the public interest and on balance doesn’t meet the objectives of a sustainable development.

--Water – Hunter Water and DPE Water have repeatedly raised significant risks about extracting sand below the water table based on prior experience of contamination from mineral sand dredging in the region. These are known risks based on decades of monitoring and experience with sandbed aquifers in Port Stephens. Our water authorities advise that sand extraction be limited to best practice levels above the water table. Failure to heed their advice could have a lasting impact on the whole community – with loss of water use, increased cost or other unintended consequences affecting us all.

--Environmental harm – The potential negative impacts to protected habitat in the Worimi National Park from groundwater drawdown and increased noise have not been sufficiently evaluated or mitigated. Although the project is proposing to increase the vegetation buffer to the park by 20m to mitigate some of the impacts, such as weed incursion and bank destabilisation, we could see no information about the impacts to protected habitat from lower groundwater levels or noise going beyond the site and into the national park. If ecological resilience is weakened by permanently lowering groundwater and animals can no longer live or forage in an area because the noise is too disruptive, the park will lose important conservation value for our generation and future generations.

--Final landform – The loss of local biodiversity extends to the site itself through the proposal to replace around 10M tonnes of extracted sand with either water or backfill. The proposed methods for treating increased acid and dissolved minerals in the water are uncertain (including the financial feasibility of one of the options). There are also unresolved questions about the practical and financial feasibility of sourcing suitable backfill to fill the hole and then revegetate with native plants. If suitable backfill can’t be sourced, the default outcome will be a water-filled void. If the water can’t be treated, the pond won’t be fit for human or wildlife use. These are not sustainable outcomes for our community nor are they sustainable within the meaning of our state and local planning laws.

Taken as a whole, we don't believe this project will serve the public interest and should therefore be refused.

I object strongly to this application on the basis of
1. Danger to our water supply if this company is allowed to mine into our water table. I understand that Hunter Water is concerned about this so why shouldn't we residents be also concerned. In the recent drought years we had to call upon the water from underground for our water supplies. If a mine is allowed to interfere with natural processes of water replenishment then it definitely should not be allowed.
2. The increase on Nelson Bay Road and other roads in the area leading to the Pacific Highway from the additional sandtrucks. This is not be spelled out clearly enough for the public to understand the impact. Already we have a cumulative approval of mines with absolutely no account taken of the impact on our local roads.
3. The impact on the Lemon Tree Passage roundabout of more Sand trucks using this exit. I don't travel Nelson Bay Road on a regular basis and yet on 2 occasions I have had sand trucks pull out in front of me at great risk to my personal safety.
4. Nelson Bay Road should be like other coal haulage roads with the miners paying a large contribution to the added construction needed to maintain a road used by multiple mining sites and associated trucks.
The application definitely should be sent to a public hearing rather than being approved by some bureaucrat or State Minister. We have had enough.

Holcim Salt Ash Sand Operations project SSD 9099356

Submission – Strong Objection

I am a resident of Nelson Bay and frequently travel along Nelson Bay, Richardson and Cabbage Tree Roads which I believe will be adversely affected by this proposed development. There are other concerns on the environment that also concern me.

Impact on the Roads
The extraction limit is currently limited to 180,000 tonnes pa, although at present the operations are operating significantly below this level, an increase to 550,000 tonnes pa will result in approximately 3 times the amount volume or truck movements.

This does not include in addition to the already approved 200,000 tonnes pa from sand importation. The roads from personal experience already have enough large sand trucks operating from this site and the other five sites within the area.

Many of the other sites are not operating at capacity yet, and/or have applied to increase the volume. I do not believe the cumulative effect of increase in truck movement have been adequately discussed, it is very fortunate that to date there has not been any serious accidents, but with significant increases proposed here and at other sites it is not an acceptable risk that residents of Port Stephens should have to endure over the next 30 years. This is not a short-term project. The Nelson Bay area has a very large number of tourist visitation, a small number by buses but most by private vehicle, these vehicles will not be expecting or used to such heavy truck movements on rural roads adding to the danger.

Impact on Water Quality
The proposal to extract through dredging to 30m below the water table will expose pyritic sulfides to oxygen and the potential increase in concentrations of dissolved metals, is a major concern, particularly when Hunter Water and DPE Water have on many occasions expressed significant concerns about dredging below the water table. Currently all operations in the region are above the water table and it appears that experience from earlier local operations and in the Tweed LGA that it is not safe to go below the water table.
The proposal notes that a number of mitigation options were rejected as being cost prohibitive and there appears to be no clear solution being proposed at this stage.

As the site is connected to the Tomago Sandbeds which are a source of local water supply, it appears totally unacceptable to dredge below the water table and that operations should continue to follow ‘best-practice’.

The Groundwater drawdown of the surrounding area, particularly the in National Park of up to 0.5m is concerning, along with the potential loss in water quality.

Impact on Land Clearing/natural vegetation
The current approval does allow for the removal of most of the natural vegetation over the site, but rehabilitation is to occur in stages as the sand is extracted. As a result, natural vegetation will progressively be regenerated across the site (during the operational life of the extraction as opposed to at the end of the 30 year period proposed in this application) to the eventual benefit of wildlife and reducing the ongoing dust problems during operations.

As proposed a total disturbed footprint of up to 35ha may result at the completion of operations, with the likelihood of large open pond remaining. This will have a significant impact on reducing habitat areas for wildlife, loss of carbon filtering and other environmental benefits from the reduction in trees across the site.

The proposal to find backfill would appear very unlikely at a feasible cost, along with the doubling of the amount of trucks to bring back in the fill, the evaporation levels and there appearing to be no requirement real for an artificial lake in an area surrounded by natural waterways and beaches is enough to reject the proposal. The three proposed landforms are unacceptable, and no dredging should be allowed.

The calculation of biodiversity offsets is only based on the 1.75ha area. I submit that the remaining 30 to 35ha of the existing operations should also be considered somewhere as it will be a loss of rehabilitated vegetation and habitat connectivity at the end of operations as per existing conditions of consent to either a lake or grass field. Environmentally the loss of rehabilitation is totally unacceptable. Any offsets should be used within the immediate area, the loss of 75 tree hollows, just on their own need to be replaced onsite.

Impact on 24hour Operations
The proposal to operate the dredging, processing and dispatch over 24 hours Monday to Friday is not acceptable in regard to the increase in noise, light spill and dust to wildlife in the adjacent national park, the nearby residents and particularly the residents along the transport route, the increase from 10pm to 6am should not be allowed.

Conclusion
The proposal to dredge below the water table and to operate over a 24 hours period is totally unacceptable for environmental and safety reasons, together with the risk to water quality the proposal should be refused.

I am writing to you to make a submission against the Holcim Salt Ash Sand Operations, Major Project SSD 9099356.
I have concerns about how this wet mine will impact, particularly the ground water.
The adverse impact it will have on local residents as it will be running 24hrs a day for 5 days a week and up to 12hrs day on weekends.
Port Stephens roads are already very bad with many potholes. More trucks will only further damage our already inadequate roads.
Kind regards
Roslyn Scoles
38A Hanson Ave
Anna Bay 2316

I object to the Holcim Salt Ash Sand Operations project because of the adverse impact on the local environment and damage to the sand dune systems.
There will be a loss of vegetation.
I believe there is a risk that sand mining will contribute to long term damage to the dynamic dune systems.
The construction sector has a requirement for sand. However, this can be met by sand from other sources including the production of sand from crushing other materials.
Several of the proposals for rehabilitation are deficient, particularly the proposal to leave a lake which would make the loss of vegetation permanent.

I object to the extra truck movements and the wet mining.
The Holcim mine is one of at least 5 sand mines operating along Nelson Bay Road. The truck traffic is already huge. Nelson Bay Road has very heavy traffic due to tourists, sand mine trucks and residents travelling to Newcastle for work. This increase in truck movements will be almost 3 times greater. Impact on local residents, safety of drivers and damage to our already substandard roads.
I am absolutely against wet sand mining. This has potential to affect the quality and reliability of our water supply.
This project should be refused thankyou.

I object to the proposal on two grounds:
1) The potential for damage to the water supply of the Port Stephens and Lower Hunter areas. The water table is precious and once damaged, how do we repair it?
We are already dealing with the PFAS contamination and any further risk to the local community cannot be allowed to happen. Water is too precious, and the risk to groundwater is not in the public interest.
2) Proposed increased truck movements in the area. I am a frequent user of Nelson Bay, Richardson & Cabbage Tree Roads.
The vast majority of sand truck movements are on undivided two-lane roads that are already close to capacity. These roads already carry many truck movements from the existing dry sand mines in the area and more truck movements would increase the danger to other traffic. As a resident and frequent user of these roads, this increased risk is not acceptable.