Howlong Sand and Gravel Quarry Expansion

Comments attached.

3 KM sth east of Howlong too close. The dust it will create and 80 Heavy Vehicles a day traveling thru Howlong and District not on

This project is going to provide employment and it will also provide a much needed boost to the local economy

I like living in Howlong because of the quiet semi rural lifestyle here .
There are already too many heavy vehicles travelling through our town now, so we don't need any more.

I object to the proposal due to the impact of the additional heavy vehicle traffic which will flow through the main Howlong township and traverse school, recreation and residential zones. The proposal seeks an increase in production from 30,000 tpa to 330,000 tpa (more than tenfold increase) however, the traffic assessment does not seem to reflect the required level of increased heavy vehicles to carry that additional product. It would seem logical if the amount of production output is to increase tenfold then the amount of heavy vehicles required to distribute that product would have to increase by a similar amount yet it only appears to increase from 10 to 80 vehicles a day (Table 4.2). Is this purely due to the 'type'of heavy vehicle proposed to be used, ie. larger capacity vehicles such as B doubles, which would be even more objectionable?
I note in the Road Transport Assessment Table 3.5 indicates 321 heavy vehicles were surveyed using the Riverina Highway east of Quarry Rd however, it has also been stated that the highway past Splitters Creek is not approved for B doubles so there are clearly other heavy vehicles captured by the survey which included school buses and single unit trucks. These should be excluded in order to truly reflect heavy transport vehicles using this route and a more detailed traffic survey should be conducted to identify exactly what types of heavy vehicles are currently using the Riverina Highway both East and West of Quarry Road, what types of vehicles are currently being used by the quarry operator, and what is intended to be used in support of the proposed expansion and how those particular vehicles will be able to use the various transport routes available, not just the westerly route via Howlong. The current report appears to have all quarry traffic travelling west from Quarry Road (Table 4.2) perhaps the submission should provide for a variety of heavy vehicles (as has been advised in para 2 of Section 4.1) which would enable quarry heavy traffic other than B Doubles to use the Riverina Highway both east and west of Quarry Road.

I received notification of this project only last week and the submissions close in three weeks. I am objecting to the project on the following grounds:
1) I am concerned about the impacts on ground water in the region and would like further time to research possible impacts and gather some scientific understanding myself on the impacts this project may have on groundwater.
2) Despite the information contained in the proposal, I feel that 80 trucks travelling down our main road each day would be a significant increase in heavy vehicle traffic. The proposal states these trucks would be operating in business hours and this may represent as many as 10 trucks an hour down our main street, Hawkins Street. Presently, during business hours there are much fewer heavy vehicles than this using our main road. As a frequent pedestrian to and from the shops, school and preschool, this would have a negative impact on my personal and my children's enjoyment of our walks, as well as a possible impact of the safety of the roads. We need to cross Hawkins street to access some shops, as well as the preschool. I would like to see a clear external bypass route for said trucks and for it to be mandated to be used for all truck traffic coming from the quarry to localities to the west and south of Howlong. Prior to this project going ahead, I would like also to see improved pedestrian crossing facilities in the area of the shops on Hawkins Street, as it is currently a challenge to cross with young children from the News agency/Post Office to the butcher or cafe, without walking beyond the takeaway shop to where there is a pedestrian island.

I support the expansion of the sand quarry as it will create future business opportunities for Upton Engineering and the Howlong area.

I strongly support the expansion of this pre-existing quarry. I believe it will provide great employment opportunities for some local residents who may be unemployed or are looking at a different career. It will also be a great asset to this regional area that has limited availability to a good supply of base construction resources. Thank you for the opportunity to comment on this proposal.

Nil comment required from DPI Ag - relatively small area involved, agricultural activities on rest of property and adjacent properties unlikely to be impacted.

To Whom this May Concern,

I appreciate your Notice of Exhibition and invitation to comment on the Howlong Sand and Gravel Quarry Expansion.

I fundamentally object to this project for the following reasons:
- Sand and gravel, like coal and other resources from the earth, are finite and not sustainable for extraction. Due to ever-increasing construction demands, it cannot be replaced faster than it is extracted, and sand that is naturally sourced (eg. from deserts) is not usable for construction. (See Reference 1).

- It would be much for sustainable, and more profitable long-term, for Howlong to invest in renewable energy like solar and wind power. Such initiatives would heed the advice from experts and help Australia to meet our carbon emissions reduction targets. (See Reference 2).

- It has long been established that one of the best ways to slow the impact of climate change is to reduce our carbon footprint. Expanding this quarry ten-fold will bring ten times the number of trucks (up to 80 heavy vehicle movements per day) into this small rural town of 2,777 resisidents.

- Furthermore, Howlong is predominately populated by retirees and young families; children under 14 and people over 65 make up almost half of the town's population according to the 2016 Census (Reference 3). Due to their age, these people may potentially have already compromised immune systems that will place them at increased risk to accuiring health problems such as lasthma once they're inhaling significantly increased toxic fumes from heavy transport vehicles once this project is underway. As stated by the Department of Transport and Regional Services (Reference 4), "even though Australia may be regarded as a country of comparatively low pollution levels, and despite improvements in recent years, potential health risks remain. Health effects range from subtle or mild effects, through to asthma and premature mortality. While elderly people are most at risk, the very young are also at risk." This project effectively puts half of Howlong's residents in harms' way and should be considered a public safety risk.

- The NSW Government recognises that the Murray River has already suffered great negative impact due to climate change and irrigation mismanagement. (See Reference 5). Mining sand and gravel will likely increase the threat to already threatened ecosystems that are currently surviving, or trying to survive, in our local waterways including the mighty Murray River. The Conversation reports that, "The negative consequences of overexploiting sand are felt in poorer regions where sand is mined. Extensive sand extraction physically alters rivers and coastal ecosystems, increases suspended sediments and causes erosion... Research shows that sand mining operations are affecting numerous animal species, including fish, dolphins, crustaceans and crocodiles... It is time to treat sand like a resource, on a par with clean air, biodiversity and other natural endowments that nations seek to manage for the future." (See Reference 6). It is little wonder that the Minister for Planning and Public Spaces has not directed that a public hearing should be heard in relation to this expansion project, when you consider the failure of international policy to address the sand and gravel shortage and its related environmental impact of its extraction remains largely not evaluation and documented, as this article asserts.

All things considered, the expansion of Howlong’s sand and gravel quarry is a bad idea for the economy, for the community and for the environment.

What can be done instead of this project going ahead in the way the NSW Department of Planning, Industry & Environment intends?

As per the suggestions raised by Green Facts (See Reference 1), I strongly encourage the NSW Department of Planning and Environment to reduce the problems caused by sand & gravel extraction by considering the following options, which can be achieved in combination:

"1. Reducing the consumption of sand : this can be done for instance by optimizing existing infrastructure, by recycling concrete rubble, or the use of alternative construction materials...

2. Setting taxes on sand and gravel extraction to create incentive for economically viable alternatives.

3. Reducing the negative impact of extraction: this can be done by modulating the rate of extraction to the rate of renewal of the resource, and by determining the acceptable limit of extraction."

Thank you for your consideration of this submission.

Kind regards,
Olivia Noto
Howlong resident.

References:
1.The mining of sand, a non-renewable resource, Green Facts (last updated 30 Oct 2015): <https://www.greenfacts.org/en/sand-extraction/index.htm> accessed 7/05/20 20:21pm
2. Katherine Murphy, The Guardian, Renewables need urgent investment to ease Australia's transmission bottlenecks, experts warn (published 19 Feb 2019), <https://www.theguardian.com/australia-news/2019/feb/19/renewables-urgent-investment-australia-transmission-bottlenecks> accessed 7/05/20 21:17pm
3. 2016 Census QuickStats, Australian Bureau of Statistics, <https://quickstats.censusdata.abs.gov.au/census_services/getproduct/census/2016/quickstat/SSC11950> accessed 7/05/20 21:00pm
4. HEALTH IMPACTS OF TRANSPORT EMISSIONS IN AUSTRALIA: ECONOMIC COSTS: Working Paper 63, Department of Transport and Regional Services (2005), Commonwealth of Australia, p. xii <https://www.bitre.gov.au/sites/default/files/wp_063.pdf> accessed 7/05/20 20:52pm
5. Six main risks to Murray-Darling Basin water, NSW Government: <https://www.dpi.nsw.gov.au/content/archive/agriculture-today-stories/ag-today-archives/july-2006/six-main-risks-to-murray-darling-basin-water> accessed 7/05/20> 20:26pm
6. Misha Ketchell, The world is facing a global sand crisis, The Conversation (Sept 8, 2017): <https://theconversation.com/the-world-is-facing-a-global-sand-crisis-83557> accessed 7/05/20> 21:27pm

I am objecting to this project as the roads are not sufficient to handle such an increase in truck movements. We already have enough trucks on our roads which are to narrow as it is. Please do not approve this unless all roads are updated and widened. Also having more trucks going through Howlong is ridiculous it will become like Rutherglen, where they are trying to get the trucks off the main street as it is very dangerous

Continually improving NSW

The RR has no comment on this application. The sand and gravel extracted is for the purposes of construction and is not a schedule 2 mineral under the mining regulation.

The EPA is seeking further information in relation to the Noise Impact Assessment

I object to the proposed Howlong Sand and Gravel Expansion Project in its current format on the grounds of the impact of increased traffic on the residents and business of Howlong.

It is stated that the proposed project will result in increased movements of 19m/26m Truck and Dog or B-Double vehicles comprising up to 40 laden loads per day (80 movements) operating at a maximum of 6 laden loads per hour (12 movements), almost all of which will travel through Howlong along Hawkins Street and Sturt Street South, past schools, day care facilities, shops and restaurants, and elderly care homes.

The increase in traffic will amount to approximately 40 loaded and 40 empty trucks per weekday. As the operating times will be 7:00 am to 10:00 pm, the trucks will start moving through Howlong at approximately 6:30 am each weekday.

This will result in a number of serious issues, particularly including:

• Safety of pedestrians (particularly the elderly of which Howlong has a large population, and children) – there have already been road works completed in Sturt Street opposite Oolong to help mitigate concerns by Oolong residents and visitors on the safety of crossing the street,

• Increased road/traffic noise which will impact all businesses and residents of, and persons in the vicinity of, Hawkins Street and Sturt Street,

• Increased road/traffic noise which will impact those businesses that provide outdoor seating areas for their customers (at the moment these are The Howlong Bakery and The Half Acre Café although there may be more businesses offering outdoor seating in the future OR the road/traffic noise pollution could be a determining factor in a business NOT choosing to open in the future),

• Increased air pollution from diesel fumes, road dust and contaminant dust from the truck loads which will impact all businesses and residents of, and persons in the vicinity of, Hawkins Street and Sturt Street,

• Increased air pollution from diesel fumes, road dust and contaminant dust from the truck loads which will impact those businesses that provide outdoor seating areas for their customers (at the moment these are The Howlong Bakery and The Half Acre Café although there may be more businesses offering outdoor seating in the future OR the increased air pollution could be a determining factor in a business NOT choosing to open in the future), and

• Degradation of the road surface resulting in more frequent requirements to do repair works and thus more frequent road closures and/or disruption to Hawkins St/Sturt St traffic. This raises the concern of where the traffic may need to be diverted while road maintenance is performed.

A solution that would help mitigate these traffic-based concerns is the establishment of an alternative truck route that bypasses the main streets of Howlong. This needs to be implemented prior to any increase in the number of large vehicles operating at the site.

Refer to submission attached file