Howlong Sand and Gravel Quarry Expansion

My main objections relate to the following 7 areas:
1. The apparent DISREGARD FOR THE AMENITY AND ROAD SAFETY OF THE RESIDENTIAL AND BUSINESS COMMUNITY OF HOWLONG by the project proponents who have been prepared to sacrifice a small rural community for the economic betterment of the region with no recompense for the loss. Employment possibilities are mentioned but are not necessarily going to be of benefit to those who lose their lifestyle and a quiet affordable rural residential location. Many people have chosen to live in Howlong for its quiet and safe characteristics.
2. The ACTUAL COSTS to the project proponent FOR THE USE OF THE PUBLIC ROAD SYSTEM, if properly calculated, would in all likelihood make the project less attractive economically. The increased number of heavy vehicles on the highway which has not been designed and constructed to accommodate it should result in major works paid for by the project to improve the surface of the road to decrease the already unpleasant and health affecting noise levels. The project should also contribute proportionally to the rebuilding and repair of any sections under threat of damage that will result from the use of roads so that the inconvenience and reduced safety of the local population is minimised. I note references to some traffic studies indicate that 10,000 light vehicles are needed to cause as much wear and tear as one heavy vehicle. This is not in the acknowledged in the documentation presented by the proponent.
3. The REDUCED ROAD SAFETY on the Riverina Highway, Hawkins Street and Sturt Street particularly due to the POOR VISIBILITY at certain times of the day eg SUN GLARE on east west direction roads, FOG on all parts of the route near low lying sections of the proposed traffic route.
In addition the LACK OF ROOM for heavy vehicles to manouver through the shopping centre of Howlong with many cars parking and accessing driveways and roadways, will further impair the safety of pedestrians and light vehicle users.
The current practice of heavy vehicles using local roads to park in, as well as parking within the confined spaces of the shopping centre provide additional safety hazards and is another increasing problem residents and visitors to Howlong have to negotiate. Heavy trucks must travel through NUMEROUS INTERSECTIONS where members of the community are used to walking, cycling and children are frequently required to cross the highway to utilise recreation areas, shops, care and education facilities and participate in general village life activities. There are NO OFFICIAL SAFE PEDESTRIAN CROSSINGS in HowlonG. The school does have some safety practices to protect the children and there have been some safety structures erected to protect pedestrians that are already often damaged by the current heavy vehicle traffic. How much less road safety are residents and visitors expected to accept WITH AN ADDITIONAL 80 HEAVY VEHICLE MOVEMENTS PER DAY?
Is a BYPASS of the village centre possible? When, where and who would pay for it? This will continue to be a future concern if the Riverina Highway into Albury is not able to be used by heavy vehicles and Howlong is the sacrificial community.
4. The INCREASE IN VIBRATION AND NOISE LEVELS for any residents living close to the Riverina Highway. Having lived in the same location on the eastern side of Howlong, in excess of 40 years, I am aware of the gradual increase in noise and vibration levels of the traffic movement along the Riverina Highway. The heavy vehicle traffic using the intersection of Howlong-Kywong Road with the Riverina Highway has contributed significantly to reduced amenity of residential land in this vicinity. Gear changes and use of engine braking during a very quiet night and through the day in a rural area are very noticable and have impacted the health of residents in the area.
5. The proposed increase in volume of extracted material per annum indicates the economic benefit the proponent believes is possible. It would therefore be reasonable to expect SIGNIFICANT SAFEGUARDS FOR THE RIVER WATER QUALITY provided by the proponent. The levee proposed to protect the project is likely to cause any natural flooding to be redirected due to the significant size of the extended boundary of the site. Who is going to be the recipient of this water and given the recent natural disasters caused by water all over the world is a 1 in 100 year event the most appropriate level to be using as a basis for prescribing the protective measures?
6. NATIVE VEGETATION CLEARING on a flood plain may also create problems for water flow at time of flooding, increasing the speed of flow and even increasing erosion and impacts on lands and recreation areas down stream. How can this be compensated for?
If OLD TREES WITH HOLLOWS are removed what nesting replacement is provided for the native fauna. Should this not be described? Whilst additional plantings of seedlings may in the future provide replacement vegetative habitat it cannot replace old hollows and large canopy trees.
7. REHABILITATION of the excavated land areas has often been a problem for communities where extractive industries have been undertaken. If for some reason this project gains approval in its current form. It is hoped that development in stages will be conditional on the satisfactory rehabilitation and maintenance of previous damaged land BEFORE the next stage of extraction can be commenced.
I hope my concerns are taken seriously. Whilst I am of the longer term resident group of Howlong I am aware that the destruction of a small rural community for economic betterment of the larger community is a possibility because of the lack of vision and planning for the future by various levels of government results in reactive decisions rather than proactive decisions.
Yours sincerely Narelle and Graham Ashford

To whom it may concern.

In this response to this I wish to advise I do not support the proposed extension, and have very little faith that such scale can be achieved without detrimental impacts on our community the and surrounding environment I believe the increase extraction and transport has not undertaken suitable community engagement and proposes detrimental environmental, social, and health and well-being impacts. It is unsettling to see how a ten fold increase per annum can be considered without comprehensive key community and stakeholder engagement. Other than receiving the letter dated 24 April 2020 from the Dept of Industry and Planning I feel I have not been engaged at all on the project, or have due time to fully absorb the impacts and implications and nature of potential contaminants.
With my limited knowledge I have attempted to comprehend the many documents related to the development which are on public exhibition. My comments acknowledge that unfortunately I do not have the required knowledge, resources or time to adequately review and comment about some of the other technical documents, which are not suitable presented in common language.

Increase number of heavy vehicles

Over 100 properties will be directly impacted by increase heavy transport through the interior of the small (yet growing) community. Our road already is affected by a high portion of heavy vehicle wishing to avoid traffic management cameras located in the Hume Hwy. The significant increased assumed through this development doesn't adequately recognise the localised impacts (including safety) on our community; including school and aged care facilities as well as the community amenity.
Across the report I fail to see suitable benefit from the development to adequately compensate the negative impacts from heavy vehicles; such as noise and dangerous vehicle emissions, nor the increased risk to bike riders and pedestrians (many of them school children), to warrant approval.
This concern is magnified when coupled with the fact that the area is known for significant periods of fog which effects visibility. As well as blinding low level sun ingress when driving at particular times of the day along the developments adjoining public access road. There additions characteristics have failed to be suitably addresses in supplementary reports. However, these types of major traffic hazards have been responsible for many serious and fatal car accidents in the past and warrant consideration. As a local resident who lives close to the townships major intersection I can also advise that the crossing barely accommodates heavier vehicles and is often the site of near misses.
Besides these obvious concerns there is addition worries regarding rapid deterioration of our major road surfaces and the impacts adjacent houses as road pavements have not been designed to host the proposed additional level of weight and use. Our dwelling vibrates in certain conditions when heavy vehicles pass and this will be exaggerated, leading to the weakening of our home’s structural integrity and increasing wear and tear on the exterior and interior building fabric.

Given the nature of our heritage character home increased heavy vehicle noise is a real concern. Historic homes were not designed to absorb high levels of noise. As such there is a real personal impact of noise pollution for our family that increased heavy vehicles traffic would have at our property. There is concern that the supplementary report doesn’t accurately capture the projects proposal noise pollution nor capture the variations of the effect of differing road pavements the vehicles would travel on, especially when compared to other historic independent studies.

Environmental

The extraction of over 5 million tons of resource have the capacity to dramatically alter the landscape and water course. I have concerns that the potential impacts on the flow of our precious and nationally significant Murray river system have not been suitable recognised, and development may impact the river bank integrity and stability.
The remediation and rehabilitation suggested are inadequate for the scale of works proposed. The designed wetlands require ongoing maintenance and irrigation to remain viable. There are numerous assumptions required to take comfort in these environmental proposals which are rarely priorities for commercial ventures. The comment that much of the revegetation activities would occur outside the disturbed areas for the quarry does not adequately address the scare on the land and overarching adverse effects of activities.

General

I also wish to make comments regarding compliance and enforcement. Given the obvious absence of any consistent regulatory and legislative enforcement presence in the township it is difficult to believe that any operational standards and conditions would be consistently and regularly monitored and compliance enforced.
The argument in the report that economic benefits outweighs any potential social and environmental threats is not only concerning but also a sad reflection on the way we as a society conduct business and disregard wide spread long term financial, human and environmental viability.
Given all the reasons listed, we find the proposal in its current form excessive and unacceptable for us as a family, Howlong as a community and the delicate and precious environment we live and thrive in.
Regards
Helen Jones

I have included my submission below and all the pictures I wish to have submitted with it will be attached by the assistance of Mr Joel Herbert .

We wish to object to the proposed Howlong quarry and have attached a list of our concens.

A submission objecting to this project was mailed to the office last Friday as there was an issue registering with the portal. A copy of the submission is attached to ensure it is lodged before the closing time.

Generally support development in our region ....but have reservations and comments - see attached

I support the project as it will make concrete cheaper in the area. The price of concrete supply is very important to industry in the town of Albury as it allows buildings whether they be industrial, commercial or housing to be built at competitive rates. Without affordable building materials in our town, it is very hard to compete with other towns who may have cheaper sources of supply. As Albury is a regional city we need to be on an equal if not cheaper comparable footing to other towns, especially in our manufacturing industries, due to our additional transport costs. To bring people to town they also need to be housed and the price of new housing has a direct correlation to the price of concrete.

I live in the Howlong and Chiltern area, and have a number of concerns about the project's impact on the Murray River, Howlong, and Australia's threatened biodiversity. I do not think it should proceed until there is more certainty around some of these risks. I have outlined these concerns in the attachment.

The applicant’s submission proposes digging up 9.5 million tonnes of sand and gravel over 30 years, to provide low-value raw material for concrete production, earthworks and roadworks. Extraction will include the use of large suction dredging, cutting, excavation, and crushing machinery.

Yet, the proposed quarry site will be excavated on an “island” bounded by the Murray River itself on one side, and the Black Swan Anabranch on the other. (The anabranch splits from the Murray north of Barnawatha and rejoins it south-west of Howlong.)

The applicant proposes expanding the existing quarry from a single 6.7ha pit, to four pits with a combined surface area of 41.2ha. The amount of sand extracted annually will be increased from 30,000 tonnes p.a. to 330,000 tonnes p.a over the 30 years. The pits will be 21m deep, and the applicant proposes 2.7m flood levees in its bid to mitigate flood risk.

I have a number of concerns including:
• Impact on community safety, amenity and quality of life: One heavy vehicle movement every five minutes of large earthmoving trucks, including B-doubles, along the Riverine Highway will destroy the peaceful amenity of the town for six and a half days (and nights) a week for 30 years. The highway runs through Howlong’s main shopping centre, passing the local primary school and community sporting facilities. The trucks will run from 6.30-6.45am to 10-10.15pm Monday to Friday, and 6.30-6.45am to 12 noon Saturday, turning from the Quarry Road out onto the 2-lane highway between Howlong and Albury with traffic at 100km/hr - braking noisily as they pass the 50km/hr speed signs near the golf club. Howlong is prized as an idyllic regional tourist destination due to its golf club and other recreational facilities. Noise and dust from continual heavy-truck movement will destroy quality of life and tourism potential of the town.
• The risk of flooding and pollution: The excavation of large, deep pits by the Murray, bring the risk of flooding and breaching of levee banks, and seepage of contaminated water from the pits to the river and its anabranch. This pollution risk endangers both the surrounding floodplain, and downstream human and riparian communities.
• Loss of significant volumes of water over the life of the project, due to mine operation, evaporation, and groundwater interception. Climate change and water scarcity have already triggered ‘water wars’ in the Murray-Darling catchment, between upstream and downstream communities and conflicting commercial and environmental values. In 5-10 years’ time (or sooner), this project is likely to become a liability in terms of environmental degradation and water use.
• Interception of shallow and deep aquifers in the course of excavation and pit operation. The operation is upstream of Howlong, which depends on groundwater for irrigation and community use, especially during drought.
• Impact on local biodiversity: Vulnerable species include the Superb Parrot, which is known to breed in this area, and Sloane’s Froglet - this is one of the last habitiats of this disappearing amphibian species.
• Questionable rehabilitation plan: Requirements for rehabilitating and managing the relatively deep remnant pits as both wetland settlement ponds and irrigation dams are contradictory.
For local people and the environment, the project brings a great deal of risk with virtually no benefit – just 2 additional onsite full-time jobs on top of the 8 already employed at the quarry site.

Mining the Murray for low-value raw construction material – at the cost of the Murray’s value as a tourist and nature destination, as well as community safety and wellbeing, local biodiversity and river health – is a highly inefficient and risky use of a nationally significant river system. While the applicant has produced volumes of consultant reports that, unsurprisingly, show that risks are all manageable, I would argue that when it comes to a national treasure like the Murray, there should be ZERO risk of harm to its ecosystems and communities from industrial development along its banks.

I trust that the NSW Government will envisage a more sustainable future for this area and protect its reputation and significant potential as an idyllic tourist and lifestyle destination and its rich natural wonders.

Kind regards,

I wish to lodge an objection based on

the excessive amount of additional traffic, (trucks and trailers, and Bdoubles) which would travel south on Sturt Street to access the bridges to Victoria. That is stated to be 95% of the 80 vehicles per day. In doing so they would pass
- The Primary School
- The Early Learning Centre
- The Aged Care Hostel
- Residential areas
And it understood this could occur up to 15 hours of the day. What would that be?? 9 am to midnight; perhaps 6 am to 9 pm? Incredible suggection.

This is ridiculous. Already there is a high number of trucks accessing Victoria from Sturt Street, through a residential area. This proposal is unthinkable.

Many pedestrians and cyclists use the bridges and Sturt Street, walking from the camping area into the town, or accessing the Lions Park for swmming, camping, picnics etc. there is not even a safe footpath along Sturt Street to the bridges so those people have to walk on the road.

In addition, as far as I am aware there has been no community consultation on this proposal. If there has been, it must have been secret and selective. This proposal would affect a great many lifestyles and safety, and it is of strong community interest.

Could you please let me know if this submission is accepted, or if you wish me to transfer it to your form. If the latter is the case could you please fix it so it is possible.

I have not made any political donations in the past two years.

Thank you for the opportunity to comment.

This proposal and associated truck movements is driven by a 1000% increase in per annum extraction for up to 30 years and therefore should not be taken lightly nor create a legacy for future residents. A lot of changes have occurred in Howlong since this project was first mooted and consultation occurred. I have lived in Howlong for 2 years, the first I heard of this project was via your 24 April 2020 letter.

Arguably the stated 'benefits' to Howlong of employment and economic growth will be overstated in pay for positive submissions provided by consultants. If benefits are achieved they are unlikely to be achieved within Howlong to offset the impact of the additional truck movements. Benefits are most likely to be achieved more consistently across the greater region and most likely those in Albury/Wodonga and other nearby large towns where service industries with the scale required for the expansion exist. If I am reading the submissions correctly there is no increase in ongoing quarry operation jobs. With no legal truck parking conveniently available outside the Howlong shops, it is highly unlikely that shop owners would see any benefit from truck movements. Mind you I have been parked in for some time recently by an illegally parked B Double operated by Hanson, a quarry contractor, opposite the town bakery. There may be short term benefits provided from time to time by contractors involved in expansion works or maintenance.

The Caltex garage on the eastern outskirts of Howlong (which provides food services) will undoubtedly benefit with more truck movements and quarry growth. There is capacity for kerbside parallel and off road parking which is a magnet to passing trucks from 6am to 8pm. As a consequence, private driveways can be blocked and truck motors left running while purchases are made. This can result in trucks being left unattended for several minutes. Residents experience lengthy periods of idling heavy exhausts, start ups, air brake release and cycling up through the gears. It is noted that no sound monitoring device was placed near the Caltex garage. There are potential safety concerns for school children in this area as well, especially those riding their bikes to and from Howlong Public school along the road side as there are no formed footpaths available.

As a resident of Howlong living near the Riverina Highway and supported by the perception of family and friends, I hold a firm belief that drivers adhere more diligently to the road rules when they know the Police are in town. Higher speeds means more noise, including from trucks operating to schedule, and using their communication devices to monitor traffic conditions and the locations of Police and RMS officers. Unfortunately it is human nature to push the limits when you know you can get away with it and time is money. While Howlong does have a police station, the township does not enjoy officer's always being in town or on duty 24/7.

One week is insufficient to capture truck movement data. The time period monitored was the first week of the Victorian spring school holidays and the first weekend and Monday of the NSW school holidays. This should not be considered as a typical period for survey purposes and is too short to include seasonal increases of truck and heavy farm equipment movements for agriculture and pastoral purposes.

The location of the vehicle count and noise measuring devices may not have captured all heavy truck movements from the Howlong Industrial Estate, which is also increasing in size. For example those exiting the Industrial Estate via Kywong-Howlong Road and turning right into the Riverina Highway and again at Sturt Street (towards Corowa) may not have been captured.

I am at a loss to understand why areas of the aerial photographs included in submission Part 5, Noise Modelling Assessment, Page 4, are blacked out. One of these blackouts includes the Howlong Industrial Estate that is also generating additional truck movements with it's expansion.

It is unclear why all quarry truck movements are required to travel through Howlong. Trips required for Albury, Wodonga and regions to the east of the quarry can also utilise approved 25/26 metre B Double routes such as the Riverina Highway (eastwards), Bungowannah Rd, Hueske Rd and Urana Rd. This route negates the identified Splitters Creek restrictions and helps share the load of the increased truck movements that ultimately travel in an easterly direction. The quarry operator has not stated why this alternative route is not utilised by eastward bound truck movements that I can see.

The proposed spread of operating hours for truck movements from 7am to 10pm is too expansive and provides maximum flexibility to the operator and nothing for the residents of Howlong. It is understood that although the quarry submissions state that it will only operate from 7am to 5pm, trucks may access the site until 10pm. Should the quarry operator wish, they could therefore assign 30 loaded truck movements, or 75% of the maximum allowable per day, between the hours of 5pm and 10pm. This could be as often as they like with assumed impunity over the next 30 years. This would be unreasonable for residents, current and future. In addition, as the traffic flow data shows, traffic volume drops off significantly after traditional business hours, despite the finding of the noise assessments as being minimal, a truck movement when it is quiet is much more invasive as it is out of the norm when there is very little ambient noise to mark it's passing.

The Riverina Highway with the towns limits is already struggling to maintain it's structural integrity under the weight of current traffic volume. The stretch from Holbeach Rd to Sturt St in particular. If additional forecast truck movements are approved, significant road works would be a priority.

How do the residents of Howlong know that the quarry is in fact only scheduling 6 trucks per hour or 40 per day? It appears a throw away appeasement to offset the size of the expansion and even within the time I have lived here, loss of quality in lifestyle in a town that is quickly losing the nicety of being a quiet township. Traffic noise has increased so markedly in the last two years that I am exploring the cost of double glazing.

The proposed intersection improvements at the quarry should be completed before expansion work commences.

Streets in Howlong, other than the Riverina Highway are not authorised B Double routes. This does not stop such vehicles however, from using local streets from time to time to perhaps avoid shopping centre traffic and school zones. Appropriate warning or load limit signs should be placed at intersections to alert heavy vehicles to this fact, in particular Victoria and Read Streets, a recognised rat run into Victoria.

I am not against the development. I am however, concerned about the delay since this expansion was put to Howlong residents, the assumptions, statements and findings made very conveniently in the submissions, particularly related to noise, and the impact of the expanding industrial estate on truck movements along with those from the quarry.

Thank you for reading my comments.

Attached.