New Berrima Brickworks Facility

Heritage Council of NSW comments attached.

EPA response attached.

Our Shire Council has recently declared a "Climate Emergency", following strong community demands that it do so. The DA for the brickworks makes no provision for the use of renewable energy, and is to use natural gas in the firing process. At the very least, the company should be required to plant wide plantings of native trees and shrubs around the perimeter of the large lot on which the brickworks is to be sited to partially offset the carbon emissions (23,000 tonnes of CO2 per year). This perimeter planting should be at least 20 metres wide around d the entirety of Lot 1 DP785111. The plantings would also filter dust and noise from the industrial activity. It must be noted that the dust from the brickworks and quarry is cumulative to that generated but the massive Boral cement works over the road and the dust that will be generated in the future by the now approved Austral Masonry Plant to be adjacent to the brickworks. The dust and the risk of silicosis is a particular risk to the nearby residents of New Berrima and Berrima. In addition there needs to be native plantings along Stony Creek. This should be 30 metres on each side of the creek, as per the Shire's LEP 2010 (Clause 7.5(5) ... Riparian Zone Category 2).
As to the failure of the DA to provide for renewables, the gas fittings and pipelines should be adaptable to hydrogen, which in future can be produced from water by the use of renewable energy. There should also be a requirement that solar arrays be installed to generate electricity for the general operation of the plant and its vehicles.

Water NSW's Response to the EIS attached

Hi Shaun
Please see attached comments on the abovementioned major project. Happy to discuss.
regards
Calvin

Following are my recommendations:
a. The use of natural gas for the kilns will give rise to 23,000 tonnes of CO2 per year. Hydrogen should be stipulated for the long term. The plant needs to be adaptable to the use of hydrogen produced from renewable energy in the future.

b. The Austral parcel of land at New Berrima is sufficiently large to allow a major solar array to be used for electricity to run the non-kiln operations of the plant (e.g. lighting, conveyor belts and forklifts)

c. The land contains a sensitive 60-metre wide riparian zone along Stony Creek, which should be revegetated with native trees, shrubs and grasses (LEP 2010 Clause 7.5(5)(b)). Similarly, the tributary riparian zone of Stony Creek should have a 20-metre wide native planting (LEP 2010 Clause 7.5(5)(c)).

d. The site is close to New Berrima and Berrima, which need to be protected with native plantings to screen the dust and noise from the plant.

e. Austral must be required to have extensive native plantings to offset the greenhouse gases emitted as a result of the operation of the brickworks (CO2 and Methane)

e. The dust and noise impacts will be cumulative to those emanating from the Boral Cement Works, and the massive adjoining Austral Masonry Plant approved December last year (24/7 operation).

f. Silicosis is a real health threat to the residents of New Berrima and Berrima, with particular vulnerability of children in the villages and also attending Berrima Public School.
A perimeter native planting 20 metres wide should be required around the entire lot to maintain the visual amenity of the surrounding rural environment, as well as screen from dust and noise. The plantings will partially offset the greenhouse emissions resulting from the use of fossil fuel in the kilns, which are expected to give rise to 23,000 tonnes of CO2 per year.

g. The conveyor belts conveying crushed material from the nearby Austral quarry (due to be operative in 2 years’ time) and the crushing plants both at the quarry and in the brickworks plant, must be covered to minimise the dust and noise impacts on the amenity of the villages of New Berrima and Berrima.

h. The Austral industrial complex at New Berrima will include the brickworks, the masonry plant (approved in December 2019) and the shale quarry (expected to be completed in 2022). This massive industrial complex is in a particularly environmentally sensitive location adjacent to the Wingecarribee River. There should, at the very least, be a condition of consent that the completely denuded banks of the Wingecarribee River be revegetated with native plants to a width of 50 metres (see LEP 2010 Clause 7.5(5)(a)).

i. The Shire is a biodiversity hotspot, and the Austral complex is on land that abuts the Wingecarribee River, where the platypus habitat finishes on the Austral boundary. The platypus habitat there because the riverbank is completely denuded for the entire length of the Austral land along the river. The company has a moral obligation to protect this threatened species by revegetating the riverbank and fencing off the riverbank to prevent the cattle entering the river. Again, the revegetation will partly offset the enormous greenhouse gas emissions generated by the operation of the complex.

My comments are contained in the attached submission.

Attached is the submission from the Berrima Residents Association. Our primary concerns relate to the need for perimeter and riparian zone native vegetation planting to offset the the 23,000 tonnes of greenhouse gas annual emissions, and to provide screening for dust and noise. This is particularly so because of the cumulative impact of the proposed brickworks combined with the approved Austral masonry plant and quarry and the adjacent Boral Cement Works. There also needs to be a requirement to revegetate the banks of the Wingecarribee River for the length of the Austral frontage to the river. The operations of the quarry near the river cannot be separated from the other related industrial activities on the Austral parcel of land, and the combined cumulative impact justifies remedial riverbank work. The use of natural gas should only be temporary and a requirement for conversion to hydrogen derived from the use of water and renewable energy should be required within 5 years of the plant commencing operation.

Please find attached letter (More information request)

a. The use of natural gas for the kilns will give rise to 23,000 tonnes of CO2 per year. Hydrogen should be stipulated for the long term. The plant needs to be adaptable to the use of hydrogen produced from renewable energy in the future.

b. The Austral parcel of land at New Berrima is sufficiently large to allow a major solar array to be used for electricity to run the non-kiln operations of the plant (e.g. lighting, conveyor belts and forklifts)

c. The land contains a sensitive 60-metre wide riparian zone along Stony Creek, which should be revegetated with native trees, shrubs and grasses (LEP 2010 Clause 7.5(5)(b)). Similarly, the tributary riparian zone of Stony Creek should have a 20-metre wide native planting (LEP 2010 Clause 7.5(5)(c)).

d. The site is close to New Berrima and Berrima, which need to be protected with native plantings to screen the dust and noise from the plant.

e. Austral must be required to have extensive native plantings to offset the greenhouse gases emitted as a result of the operation of the brickworks (CO2 and Methane)

e. The dust and noise impacts will be cumulative to those emanating from the Boral Cement Works, and the massive adjoining Austral Masonry Plant approved December last year (24/7 operation).

f. Silicosis is a real health threat to the residents of New Berrima and Berrima, with particular vulnerability of children in the villages and also attending Berrima Public School.
A perimeter native planting 20 metres wide should be required around the entire lot to maintain the visual amenity of the surrounding rural environment, as well as screen from dust and noise. The plantings will partially offset the greenhouse emissions resulting from the use of fossil fuel in the kilns, which are expected to give rise to 23,000 tonnes of CO2 per year.

g. The conveyor belts conveying crushed material from the nearby Austral quarry (due to be operative in 2 years’ time) and the crushing plants both at the quarry and in the brickworks plant, must be covered to minimise the dust and noise impacts on the amenity of the villages of New Berrima and Berrima.

h. The Austral industrial complex at New Berrima will include the brickworks, the masonry plant (approved in December 2019) and the shale quarry (expected to be completed in 2022). This massive industrial complex is in a particularly environmentally sensitive location adjacent to the Wingecarribee River. There should, at the very least, be a condition of consent that the completely denuded banks of the Wingecarribee River be revegetated with native plants to a width of 50 metres (see LEP 2010 Clause 7.5(5)(a)).

i. The Shire is a biodiversity hotspot, and the Austral complex is on land that abuts the Wingecarribee River, where the platypus habitat finishes on the Austral boundary. The platypus habitat finishes there because the riverbank is completely denuded for the entire length of the Austral land along the river. The company has a moral obligation to protect this threatened species by revegetating the riverbank and fencing off the riverbank to prevent the cattle entering the river. Again, the revegetation will partly offset the enormous greenhouse gas emissions generated by the operation of the complex.

As someone who has lived in Berrima for over 50 years, I am very concerned at some of the impacts this project will have on the areas surrounding this vast industrial complex.

I know, from experience with Blue Circle Cement in the 70's, that the dust problem will be immense. The dust, then, was so great that car windscreens had to be scraped off before driving. To their credit, Blue Circle made many changes to their operation, so eventually, the dust fall out over New Berrima and Berrima was, and is, miminal. And Boral continues in the same manner.

Points for consideration:

1. At the moment, there seems to be little, or no, effort to alleviate the effects that this huge complex will have on people living less that half a kilometer away. With
Austral, an operation that is going to operate 24 hrs a day, seven days a week , 365 days a year, in a relatively built up area, the problem with dust and noise for New
Berrima residents in particular, is beyond comprehension.

2. As the Austral complex borders the Wingecarribee River - a river it is important to state is part of the Sydney water catchment system - it is imperative that strict controls be placed on Austral to ensure that the Wingecarribee is not polluted , in any way, by fall-out from the proposed brickworks and masonary plant.

3. Austral must be compelled to install a solar system large enough to run the non-kiln operations (lights; conveyor belts etc): thus helping to partially off-set the enormous
23,000tonnes of CO2 emissions per year thet will come for Austral's of use natural gas.

Thank you for the opportunity to make some comments on this project.

August 25th 2020 SUBMISSION ON SSD-10422 NEW BERRIMA BRICKWORKS FACILITY

I reside in the New South Wales shire of Wingecarribee and I oppose the brickwork project as it is currently proposed. My opposition is primarily due to its massive carbon footprint, both during the construction phase but particularly over the long operational life of the facility.

The department would be aware that Australia is a signatory to the Paris Climate Agreement, which aims to keep average global temperature increase to below 2 degrees C. The Paris Agreement explicitly "recognises the roll of local governments, business and industry, investors, civil society, unions, faith and academic institutions as critical to achieving its goal".

Given that stopping a climate crisis is critical for the wellbeing of all life on the planet, every individual, business organisation and all levels of government must work aggressively to massively reduce Greenhouse Gas Emissions.

Also attempting to play its part in the drive to reduce GHG emissions, the local Wingecarribee shire Council declared a Climate Emergency on the 12th February this year, with a plan to net zero emissions by 2050 at the latest.

Alarmingly I see little in the planned new brickworks that indicates the proponent's interest in reducing GHG emissions. This development offers Austral the perfect opportunity to construct a state of the art, low emissions brick making facility that would demonstrate to the community and industry what a modern environmentally responsible brickworks should be. For example, the massive roof area of the production building as well as the nearby land owned by Austral could accommodate thousands of solar panels which in combination with battery storage would be a mini power plant. The installation of electricity producing windmills should also be a priority consideration. It's entirely feasible the facility could produce all of its electricity requirements from renewables. The long-tern financial benefits to Austral would be considerable whilst also massively reducing emissions.

Austral's EIS displays no plan for the use of or future adoption of new brick firing technologies, such as microwave heating or the use of hydrogen produced by renewables to eliminate the use of natural gas, once again a massive reduction in green house gases would be the result. Also, wherever possible all vehicles and plant equipment should be electric.

Austral must also guarantee to surround the facility with a closely planted corridor of native vegetation at least 20 metres wide to provide screening, habitat and movement for wildlife. This would also serve to offset for the removal of native vegetation during the construction phase. Special attention must also be given to the revegetation of Stoney Creek and the Wingecarribee River, which runs along side the quarry site. The restoration and the protection of the riparian zones 50 metres wide along the riverbanks and 30 metres wide along Stoney Creek are essential. This revegetation is required to protect water, provide habitat and corridors for wild life and also act as a carbon sink.

This project and the already approved shale quarry and masonry plant next door will particularly impact the communities of New Berrima and the historic village of Berrima. When combined with the impacts of the neighbouring Boral cement works, the threat to health from respiratory diseases such as silicosis is very real. This further reinforces the importance of the 20 metre wide native vegetation screening around the perimeter of the facility.

In conclusion, I believe all of the issues I've outlined in this submission must be addressed by Austral before any consideration of approval be given by the D.P.I.E.

Yours sincerely
GEOFFREY WRIGHT

The more detailed submission by WinZero Inc is attached. In brief, we are very concerned that Austral will be using fossil fuel to fire the bricks and that there is no provision in the DA for the production and use of renewable energy. Hydrogen produced from renewable electricity should be required for the firing, if not now then at some time in the near future. The brickworks is part of an Austral industrial complex, and the parcel of land is sufficiently large to allow for the construction of a large solar array. The electricity produced by the solar array should be sufficient with the installation of batteries to run the lighting, the conveyor belts and the vehicles (e.g. forklifts) used on site.
The Austral industrial complex is in a particularly sensitive location, being adjacent to the Wingecarribee River. The platypus habitat finishes right at the start of the Austral land, with the riverbank completely denuded for the entire length of the Austral land along the river. There is a need for revegetation of the riverbank to extend the platypus habitat and for native plantings along the riparian zone of Stony Creek and its tributary. Austral should also be required to plant a corridor of native vegetation around the perimeter of the lot on which the brickworks and masonry plant are to be built. This is to offset some of the carbon emissions of the brickworks, and to screen dust and noise from impacting the nearby villages of New Berrima and Berrima. Dust leading to silicosis is a particular problem, as the dust from the brickworks is cumulative to that created by the adjacent Boral Cement Works, as well as the Austral masonry plant and the Austral quarry.

In tendering this submission I am writing on my own behalf as a long-term, concerned resident of the Southern Highlands, but also as a member of a number of environmental groups whose sole purpose is to enhance and preserve the environmental integrity of the Southern Highlands. This extends to the minimisation of polluting emissions into our atmosphere; the protection of native vegetation already decimated by severe bushfires this year (2020) with consequent impacts on our wildlife including local glossy black cockatoos and koalas to name just two; the restoration, preservation and ongoing protection of the Wingecarribee River which abuts Austral's parcel of land which has been and should once again become platypus habitat, and broadly maintain at all cost the physical and mental well being of everyone in the Southern Highlands including therefore, Austral personnel.

There is no reason why the 'Enterprise Corridor' of industry such as that proposed between Moss Vale and New Berrima cannot operate and still take into account all the above mentioned environmental considerations of clean air, protected native vegetation, re-establishment and protection of the Wingecarribee/Stony Creek riparian zones and the well-being of Southern Highlanders. In this respect the following should be considered:

i) in lieu of natural gas that generates huge quantities of atmospheric pollution Austral should consider renewable energy such as hydrogen for its kilns and solar power for its other operations. When worldwide focus is on renewable energy Austral could aim to be regarded as a leader in the field of renewables rather than attempting to exempt itself from innovative practices.

ii) Austral should undertake native plantings in the riparian zone along Stony Creek and the vicinity of the Wingecarribee River as recommended (LEP 2010 Clause 7.5(5)(a)(b)and (c). The revegetated riverbanks should then be fenced off to provide protection to platypus and other wildlife.

iii) The plant is within close proximity of New Berrima and Berrima and while the impacts of environmental pollution that would be generated by the plant would extend beyond these townships, serious consideration needs to be given to the vulnerability of children in the immediate vicinity and attending the local schools. Native plantings would provide a screen from dust, noise and also maintain the visual amenity of the surrounding rural environment and contribute generally to the well being of the wider community.

Expertise in the form of professional advice through to hands-on-participation for achieving all the above mentioned environmental outcomes exists through a wide range of environmental organisations in the Southern Highlands. In the new order of environmental responsibility where the focus is on corporate responsibility (refer recommendations of the Climate Council of Australia, ABC's 'Fight for Planet A: Our Climate Challenge' as two immediate sources) Austral could become a showplace for innovative environmental practices rather than an industry that seeks to exempt itself from environmental responsibility.

In general, I believe that the project as a whole has some merits as a foundation for the development of a local small industrial complex in the Wingecarribee Shire. However, there are several serious faults and omissions in the overall plan as proposed which render the project as a dangerous and harmful exercise which should be rejected in its present form by the NSW Government.
The dangerous and harmful aspects of the existing proposal are related to the impacts of three components of the development: (1) its fossil fuel requirements for all of its energy and heating requirements which will result in significant increased greenhouse gas emissions leading to furthe global warming;
(2) the harmful pollution effects resulting from various phases of the entire processing sequence. In the atmosphere there will be large quantities of dust emanating from the several stages of crushing and transportation via conveyor belts and other phases of the manufacturing, all accompanied by high levels of noise - a serious danger risk to the children and adults of the relatively close inhabited areas of Berrima and New Berrima towns.
(3) along the nearby creeks and rivers there is high risk of environmental degradation which can affect the biodiversity in and around the waters and riparian zones.

I am absolutely astounded by the total absence of recognition of modern day technology, science, environmental experience and social consideration of the proposed development. In its present form it would be a wonderful new and exciting undertaking in the era of the turn of the century, the early 1900s. But today it ignores all of the advances humans have made in technology, ecology and health management. It completely ignores all of the negative impacts of the processes, energy and resource utilisation, and degradation of natural environment.

Surprisingly, it is and will become even more simple to rectify these harmful deficiencies, because the technology is here now. A major solution to the energy problem is by replacing the fossil fuel requirements with renewables and some battery storage arrangements. All engineering and economic studies show that this will not significantly increase costs and over the longer term will greatly reduce costs.
As for the pollution problems, rectification involving enclosing operations that enclose dust and noise are not expensive. And proper well designed revegetation schemes are readily available at minimal costs.
There are no valid reasons for ignoring the possible solutions to the damaging proposed design and development program proposed by the company. It is mandatory that the Government authorities respect the demands of the community, whose welfare is at risk, and therefore impose much more restrictive requiremnts for such a project.
Yours, respectfully, Louis G Flower

SUBMISSION RE EIS FOR AUSTRAL BRICKWORKS AT NEW BERRIMA
I am a member of a coalition of a wide range of environmental and sustainability groups in the Southern Highlands of NSW (WinZero Inc) whose stated objective is to achieve net zero carbon emissions in the Wingecarribee Shire by 2050 at the latest. Given the fact that Austral is proposing to build a state-of-art brickworks in a Shire that has recently declared a Climate Emergency following the devastating droughts and 2019/20 bushfire season, I am amazed and appalled at the cursory attention given to greenhouse gas emission reduction in their Draft Environmental Impact Statement.
I should say at the outset that we are not opposed to new developments in principle, as we understand the importance to the community of sustainable economic activity in the area. We are also not opposed to the brickworks in particular as there is an ongoing need for suitable building materials in a relatively cold area of the country and, being located in the Southern Highlands, we would like to minimize the transport component of their supply. Also, we understand that an EIS is not a design document so does not include the fine details of construction and operation of the plant. However, it is the place to make statements about the environmental and sustainability principles and objectives of the Proponent.
Again, I must repeat that we are in the middle of a Climate Crisis and new builds should be a shining beacon of what can be achieved to minimize our carbon emissions. Therefore, I contend that the following design, construction and operating objectives should be demonstrably front and centre in Austral’s thinking:
Design
•  Focus on the use of solar passive design principles wherever possible
•  Installation of suitable insulation to minimise the need for heating and cooling
•  Reuse of waste heat wherever possible
•  Use of native vegetation where possible to minimise temperature build up
•  Investigation and implementation where possible of alternatives to gas-fired heating – in particular taking into account the future promise of renewables- produced hydrogen
•  Installation of the maximum amount of renewable energy production

Construction
Use of low embodied carbon materials wherever possible – particularly with regard to the large expanses of concrete proposed 

Operation
•  Electrification of the vehicle fleet
•  Establishment of operating procedures that minimise the use of coal-fired grid electricity and maximise the use of renewable energy
•  Establishment of “green” energy Power Purchase Agreements in partnership with renewables producers to supplement energy needs that cannot be met by on-site renewables production
•  Installation of large-scale battery banks to enable the most effective use of renewable power over the 24-hour operational cycle.
In conclusion, I think it would be highly beneficial for Austral’s public image and for its engagement with key stakeholder groups in the local community if they were address these issues in a substantive way in their Response to Submissions.
Yours sincerely

Gaye White
W winzero.com.au
E. [email protected]
F: zerowingecarribee
T: @winzerow

Mittagong NSW 2575
25 August 2020

Objection is subject to the matters identified in the letter being appropriately addressed so as to not comprise the Berrima Cement works operations.

Application Name: New Berrima Brickworks Facility
Application Number: SSD -10422

Objection to the proposed brickworks

New Berrima is a residential village in the Southern Highlands. Latest statistics show a population of 584 people with children 14 years and under comprising 21.8%. The health and wellbeing of these children needs to be protected. They comprise nearly a quarter of the village population.
https://quickstats.censusdata.abs.gov.au/census_services/getproduct/census/2016/quickstat/SSC12938

For years the village coped with the unnecessarily high industrial noise and dust fall out from the Boral cement factory. In recent times, under environmental laws, the factory has done much to ameliorate the noise and dust levels. This has been a great relief and has made a marked improvement to the quality of life in the village.

For the last few years we have been under the cloud of the potential Hume Coal development just 3 kms from the village. Now we have been presented with another industrial development which will have a myriad of factory noises from the different processes, the generation of air particulates (including Brickworks pollution and diesel particle pollution) and noise and congestion with the increased movement of heavy vehicles.

The expert reports on these issues are weighty and difficult for lay people to understand. The summaries indicate that noise and pollution “should not” be a problem. “Should not” is hardly any guarantee that the village will not be grossly impacted in the future. The proposed Brickworks would only be 500 metres from the village.

The other concern is the potential for noise from the Brickworks to oscillate with the noises from the Cement factory. With so many different processes happening 24 hours a day, 7 days a week, with the changes in wind direction and atmospheric conditions, we question if there is a possibility that the noises will combine to form an unbearable auditory environment. We have already experienced the unbearable impact that can occur when a group of different industrial processes from the Cement factory were not properly insulated.

Furthermore, at a meeting with Wingecarribee Shire Council about the proposed Enterprise Corridor, when the issues of noise, traffic and pollution were raised we were informed that the Council was only interested in new clean, low impact businesses coming into the corridor. This proposed Brickworks does not fit that profile. It is alarmingly close to the residential village of New Berrima.

We have made no reportable political donations in the past two years.

Please see attached.

Dear Mr Williams,

Please make it a condition of consent that Austral undertake native plantings around the lot perimeter and along the riparian zones.

Yours sincerely,

Mary Moore

8, Wingecarribee St, Berrima, NSW, 2300