New South Wales
Re: Hanson Heidelberg Application SSD 15_7293 for a New Quarry at Sancrox NSW
I am the owner of Lot 16 DP 776681, Le Clos Sancrox. My land is located proximate to the proposed new Sancrox quarry. I am aware of the Hanson Environmental Impact Statement (EIS) on exhibition until 12th December 2019 and I am quite concerned that the Statement fails to address issues under the categories I have listed here in my letter.
I wish to object to the proposed quarry expansion – ERM Reference 0418291 (Environmental Assessment and Planning Act 1979). The current proposal seems to contain myths, omissions from the EIS, inconsistencies and unwanted impacts for local residents, business and future residents.
The proposed Sancrox quarry application has been presented as an expansion project. This appears to be incorrect as it would be more accurately described as a new quarry. The proposed expansion is to be located on a new Lot and DP and all plant is to be moved, and therefore it would be best described as a new quarry, especially given that the existing quarry was to be closed last century.
Port Macquarie is one of the fastest growth areas in NSW and all future development is to the west, it has less residential Lots than it has quarry rock. Hanson describe the resources found in their existing quarry and potential new quarry is in short supply. What they fail to disclose is the true number of quarries located in the local area with the similar material. Hanson claim they don’t own other resources in the area, but infact they own Lot 2 DP 814356 at Milligans Road, Bago were there are ample Reserves closer than the 200km claimed in their submissions. This quarry also contains high quality rhyolite daicite. Hanson claim that transport costs will be excessive because of 200km haulage distance. More accurately the supply from Bago is only 20km from Sancrox, so this would be negligible.
My land is part of an estate of some 51 Lots of approximately 2 Ha each. I, with a group of lot owners, are currently in the process of working with the local Council to have our land rezoned to Residential, from the current Primary Production (Primary production on this land has failed and it has been deemed by Council that Residential would be the best outcome for the city). PMHC indicated they would not support an application for Rural Residential land, as was originally presented to them. The Council advised that Sancrox land is earmarked for Residential development and the adopted UGMS has indicated Fernbank Creek and Sancrox to be the next areas of investigation. I along with a group of likeminded Lot owners have been working with the local Council to begin the investigations and we have engaged the services of a local Land Development company, Land Dynamics Australia, to assist in this process.
Hanson claim in their submission that Port Macquarie has a 15 year supply of Residential land. It is worth noting that the Council has acknowledged that the new Biodiversity Legislation introduced in 2016 has meant that the estimated 15 year supply of Residential land as stated in the UGMS and referred to in the Hanson letter, may be grossly overestimated. It is believed by the local Land Development experts, including LDA, that the amount of Residential land remaining in Port Macquarie is only approx. 5-7 years. This figure is to be confirmed by a study currently being conducted in conjunction with the PMHC.
The standards we have experienced appropriately being applied at the Local level for approval of our application are rigorous indeed. Our expectation is that an even more rigorous process be applied in consideration of a State Significant Development application for a quarry in an area where there is an existing and rapidly growing residential community and, as well, a sensitive ecological zone.
When considering this application from Hanson for the new quarry please consider the attached letter with my submission.
Inconvenient Truths -
1. A core koala habitat of “high use” level exists in the centre of the proposed new quarry, as shown in the Greater Sancrox study concluded in 2015.
2. A very large portion of the proposed new pit is a “medium use” koala habitat.
a. Given the devastating bushfires currently threatening this already endangered species, now more than ever we need to protect their habitat.
3. A subregional biological linkage corridor runs right through the centre of the proposed new pit location.
4. An Endangered Ecological Community (EEC) of Flax leaved paperbark, prickly-leaved tea tree is located in the area of the new pit.
5. Significant swamp oak and mixed eucalypt open forest areas will have to be destroyed.
6. Previous studies revealed 5 hollow bearing trees for koala habitat in the proposed pit area. The EIS prepared by Hanson says there is 1.
7. Twice daily blasting will impact traffic on Sancrox Rd and may impact the Pacific Highway, every blast. How this will be managed is uncertain but there is a code of conduct for blast guarding which has been developed by the Australian Explosives Industry and Safety Group which Hanson should consider adopting.
8. Hanson has not been able to comply with the screens of trees conditional requirements for the existing quarry. How therefore will they cope with the requirements of significantly higher standard mitigation measures given the dimension of the proposed larger new pit?
9. Possibly the impacted areas cannot be contained within the Hanson owned land simply via management of mitigation measures.
10. Evidence is that the culture at the Sancrox Quarry is not capable of managing mitigation measures for existing operational conditions. There is no indication that Hanson proposes significantly different behaviours to support the management of mitigation measures in the proposed new quarry.
11. The new Sancrox quarry project will fragment and alienate land and result in conflict with adjoining land uses.
The quarry is not ideally situated. In every direction over the range of 300m – 1,300m, there is both current and potential residential development and this new proposal is not consistent with the needs for this local government area.
Omissions from the EIS -
1. No mention is made of the currently being constructed 142 Lot Rural Residential sub-division to the west of the site (Le Clos Verdun), the eastern boundary of which is only 600m from the western edge of the new quarry.
2. No mention is made of the existing houses located on Le Clos Sancrox, the nearest of which is less than 1km from the edge of the proposed new quarry and the proposal currently being considered by PMHC to rezone the whole Le Clos Sancrox as residential, the closest parts of which will be approximately 300m from the southern edge of the proposed new quarry.
3. No mention is made of any bund to the south of the last stage of the new quarry which is essential to protect anything on Le Clos Sancrox. Furthermore, will any bund be effective anyway?
4. No mention is made of the high-speed rail corridor which goes right through the middle of the deepest part of the quarry. This will require the high-speed corridor to be moved onto the adjoining land owned by Jeff Freeman.
5. No mention is made of the impact upon the Billabong Wildlife Park and Koala Sanctuary less than 1 km from the pit.
6. Hanson has not made appropriate recognition of the biological community corridor nor identified how to manage its removal and create alternatives.
Inconsistencies in the EIS
1. Page 39 of the EIS shows the bitumen plant being coal fired. Page 40 of the EIS says the bitumen plant is gas fired, therefore how can this information be relied upon.
1. It will probably not be advisable for local residents to drink their tank water because of the dust impact.
2. The efficiency of solar panels for hot water heating and electricity will diminish significantly over time because of a build-up of dust.
3. Costs of home maintenance will increase with more frequent painting, cleaning of roof and down pipes and windows, all from a build-up of dust.
4. Local residents can expect their sleep will be disrupted from noise from the quarry 24/7. Sleep deprivation can adversely impact health.
5. The current freedom of movement of local residents may be impacted twice daily, from blasting.
6. Blasting from the current operations are already impacting on the local businesses of Cassegrain Winery and Expressway spares, as debris is regularly raining down on their respective rooves, (as reported by them).
7. There may be a higher concentration of dust particles within the air within the region for the next 10 – 30 years.
Considerations not given enough attention
1. The community need for good quality quarry material must be in balance with the social and economic costs of its extraction.
2. Port Macquarie is the fastest growth area in NSW and all future development is to the west, it has less residential Lots than it has quarry rock
3. Quarry operation within the PMHC area are quite competitive.
4. Hanson’s has not adhered to approval conditions for operations at the existing Sancrox quarry why expect a different outcome with a substantially more difficult to operate quarry?
5. A “new” quarry at Sancrox will deliver Hanson all the upside, and PMHC and existing and future communities all the downside. An approval for a “new” quarry also gives Hanson a significantly enhanced competitive position.
6. Round the clock quarry operation, blasting vibration, showering from rock and dust, noise and truck movements and the cost of dust removal over a long-haul period requires a very substantial and much more detailed / e