Dunmore Lakes Quarry (Mod 2)

On my behalf and many local residents I have spoken to I'd like to offer
support to the Kiama Council in its concern about Dunmore Proposed new
Sand Mining and ask the Department of Planning terminate the current
assessment process.

I would like the Dept of Planning to Amend the Submission as requested
by the council.

21 May 2019
The Director
NSW Planning and Industry Sydney
Dear Sir or Madam
Re: Dunmore Lakes Sand Extraction Project- Modification 2 of
DA195-8-2004
I wish to object to this modification.
Given the scale and relative locations of the expansion to the
Minnamurra wetlands and river. This sensitive area warrants
examination as a new development in its own right.

The existing mined sand area acts as a natural filtering system for
impurities such as dairy farms runoff in the Jamberoo river area, land
fill leaching from two Council Refuge Centres and the A1 motor way
runoff seeping into the sensitive wetland area of the Minnamurra
River.
The river is also used as an ecological excursion site for many
schools students.Many people use the area for family visits and many
locals and tourists enjoy and use the area.
The area is highly sensitive and any further development should be
very carefully considered.
This is a natural treasure for all to enjoy and should be protected

23rd May 2019
The Director
NSW Planning and Industry
Sydney

Dear Sir or Madam

Re: Dunmore Lakes Sand Extraction Project-
Modification 2 of DA195-8-2004

I wish to object to this modification. Firstly, given the scale and
relative locations of the expansion to the Minnamurra wetlands and
river. This is a popular recreational area, many visitors enjoy the
Minnamurra river and its clear waters. Solids leach into the river and
surrounding wetlands on a regular basis. The water quality has
definitely declined in recent years.

The overall area is approximately 2 square kilometres of which a large
proportion will be sand mine. In this same
area we have the Shellharbour Waste Depot and the Kiama Council
Recycling Centre.
The existing sand mining area acts as a natural filtering system for
impurities such as dairy farms runoff in the Jamberoo river area, land
fill leaching from two Council Refuge Centres and the A1 motor way
runoff seeping into the sensitive wetland area of the Minnamurra
River.
The river is also used as an ecological excursion site for many
schools students. There is a limit to how much disturbance the area
can tolerate from the sand mining before the ecosystem will collapse.
The area is highly sensitive, it is an important breeding ground for
marine species. The expansion of area permitted for sand mining of
this site should be refused to protect the Minnamurra river and
surrounding wetlands.
Yours Sincerely,

I feel this proposal will have a detrimental impact on the river and
surrounding areas. Disturbance of this magnitude cannot be undone if
it proves to be the wrong one. The impact on both flora and fauna
cannot be accurately predicted long term and the short term benefits
in no way compensate for irreversible environmental damage.

I object to the Dunmore lakes sand extraction-Modification 2 application
by Boral

(1) Given the small life of this proposed extension (5-7 years), the
loss of established biodiversity, including Endangered Ecological
Communities with centuries of history, is not warranted.

(2) The use of offset plans to replace centuries old established
forest remnants with new plantings is inappropriate as there is no
relativity between the two which means this not a true offset.

(3) A development of this type so close to the Minnamurra River and
Wetland has the potential to significantly effect the local
underground water systems and lead to pollution of those waterways.

(4) The proximity of the development to the Minnamurra Waste Depot is
of concern given the possible interaction with groundwater pollution
from that site.

(5) The proposal is contrary to the objectives of the 2018 Coastal
Management Act, the Shellharbour LEP and the Illawarra Shoalhaven
Regional Plan.

(6) The "extension" proposal needs to be withdrawn as this is not a
true extension to the existing development. Stage 5 was never
suggested as a possible future extension. Many of the impacts related
to the new proposal were not relevant to the original.


Janet Mayer

I am writing to you to lodge my opposition to the Dunmore Lakes
Extraction Project -Modification 2. I believe that the department of
Planning and Environment should reject this application by Boral

I object to the Boral application

I object to this application

Exhibition of Modification Request for "Dunmore Lakes Sand Extraction
Project" (DA 195-8-2004 Mod 2)


As a concerned frequent visitor of the Minnamurra River and its
immediate surroundings who voluntarily removes rubbish from the river,
I object to the aforementioned proposal. The site is within an area
governed by multiple pieces of State Government legislation and
contains Endangered Ecological Communities (EECs). It is clearly
environmentally sensitive and should be left alone to allow the
ecosystem to thrive and for future generations to appreciate. My main
concerns regarding such proposal are as follows.

Firstly, it should be noted that any community members with concerns
are disallowed from visiting the sites proposed for the mining. This
prevents the public from performing independent observations and
research on the area. Additionally, the sites were surveyed within an
hour on 10 May 2019. It would be reasonable to assume that such
assessment was inadequate given the size and ecological diversity of
the sites.

Indeed, any vegetation in the area to be mined will be destroyed. Such
vegetation present at site 5B includes littoral rainforests (of which
themselves are classified as endangered - partly due to mining),
including seven endangered species. One such species, commonly known
as "Bangalay" (Eucalyptus botryoides) is a slow growing tree of which
the individuals in this site could be as old as 300 years (though in
general they can reach 600 years). This species prefers substrates
predominantly consisting of sand-based soils which, along with other
environmental preferences, results in its limited range near the coast
of south-eastern Australia. It should be noted that once the mining is
complete, it is planned to leave pit 5B as a water body. Even if the
pit is to be replaced with fill it is highly unlikely to contain soils
which the Bangalay thrives in. Consequently, nearby Bangalays could
experience nutritional issues when sending new roots to the newly
filled pit. Such ecosystem cannot be replaced.

Furthermore, the trees contain hollows which are used by native
animals such as birds and possums/gliders for nesting and other
purposes. Lopping the trees will clearly result in loss of these nests
and likely any young present. Additionally, there is a White Bellied
Sea Eagle nest in the immediate vicinity of site 5B. This is a very
timid type of bird and its behaviour will be affected by disturbing
the area, quite possibly resulting in it leaving the area completely.

Site 5A is nearby the site of the former Minnamurra Tip, which a
concentration of toxic compounds exists within the groundwater below.
Vacating the sand at this site is likely to result in this toxic
solution migrating into and filling the pit, only to be forced out
again once it is filled, presenting risk of contamination into the
river.

I also have concerns regarding the increased truck traffic along the
local road in order to gain access to site 5A in order to fill it once
mining is complete.



I have never made any reportable political donations.

I am a concerned resident in a Kiama who frequently uses the Minnamuura
river on a regular basis to fish and also access the beach at mystics.
Have any studies been done to see how this will affect sand flow to
the river mouth and further flow to one of the most popular surfing
spots on the south coast?
This natural sand flow could be disrupted and change the quality of
waves that bring so many people to the area to surf.

Not to also mention the detrimental environmental effects this will
have on the ecosystem in the estuary.
Once again big companies are wanting to exploit our natural resources
for the almighty dollar.
Please leave Minnamurra alone so our future generations can enjoy
what's left of our coastline.

Dear Sir,

I am writing in concern for the Dunmore Lakes Sand extraction Project.

It is within a very short distance to Minnamurra River where a number
of endangered ecological communities exist. I am worried about the
effects it will have on local wildlife, marine life and habitats. The
sand mining pits will be in close proximity to Littoral Rainforest,
Casuarina Swamp forest and Salt Marsh.

I am concerned in regards to the clearing of vegetation in order for
this project to be completed.

Please consider this location to be unsuitable for Sand Mining and
extraction.

Howard Jones
407 Free Selectors Road,
Foxground NSW. 2534

23rd May 2019

I oppose the proposal for an "Extension" to the Dunmore Quarry on the
following grounds:

(1) The application is being treated as an "extension" to the existing
Dunmore Quarry operation. The new application is quite obviously
physically distinct from the existing proposal, with a unique set of
environmental implications and should be treated as an entirely new
application. The current assessment process should be terminated and a
new application should be made as a new project.

It is noted that previous proposals for extensions to the original
application have required new applications and as this proposed
extension is even more at odds with the original and not identified as
a possible future extraction area in the original a totally new
application should be required.

(2) The proposal is likely to have significant impact on flora and
fauna and the evaluation of the impact has been insufficient. In
particular there is little recognition of the cumulative loss of small
areas of important vegetation from ongoing projects that is reducing
connectivity between the escarpment forest and the coast.

(3) Little respect has been given to the impact on Endangered
Ecological Communities and Endangered species such as the Greater
Glider, nearby local populations of which (Seven Mile Beach NP) have
been declared endangered. The small level of survey time does not
provide an opportunity to measure the seasonal variation in fauna
activity and increases the likelihood of some species not being
identified.

(4) The areas proposed in this extension were not identified in the
Illawarra Shoalhaven Regional Plan as having extractive industry
potential. As such they are partly mapped and zoned with Environmental
protection intent. The proposed extensions are therefore in conflict
with the long-term strategic vision that was to provide some certainty
for land use planning in the region.

(5) The use of offset plans to compensate for the loss of significant
species and habitat is inappropriate given that the whole project has
an expected life time of only 5 to 7 years. The loss of very old trees
and established habitat and vegetation communities for what is such a
short term gain cannot be justified with any local offset areas not
likely to provide the same "benefits" for decades if not a century.

I note the references in the Office of Environment and Heritage
submission to the possibility of using the Biodiversity Conservation
Fund (BCF). The lack of "like for like" possibilities and escape to
the BCF will see a permanent loss (no local compensation) of these
important vegetation remnants. This is an appalling outcome for what
is just a few years of extraction of the recourse.
Furthermore I have serious concerns about the limited number of
species chosen for calculation of the required credits. That limited
species list results from a very conservative approach to calculation
of the biodiversity impacts of the proposal.

(6) The proximity to the Minnamurra river and wetlands of the
extraction sites, including a depth of 27 metres in the case of State
5B, suggests a high likelihood of impact on local hydrology. There is
inadequate assessment of the hydrological interaction between the
proposed dredging and the Minnamurra Waste and Recycling Depot.

(7) There are considerable concerns about the impact of large volumes
of potentially incompatible backfill material on the hydrology of the
area after extraction.

(8) There are serious conflicts with the objectives of the new Coastal
Management Act 2018 relating to coastal wetlands, littoral rainforests
and the objectives of the Shellharbour LEP E3 zone.

(9) There has been insufficient conservation recognition given to the
identified aboriginal sites which are of high cultural and moderate to
high archaeological significance.

NOTE: I have made no reportable political donations.

Howard Jones

I strongly object to this proposal to bring sand mining to the edge of
the Minnamurrra River. It has the potential to impact on ecologically
important ecosystems such as Coastal Wetlands and Bangalay Sand
Forest, in addition to impacts on tourism and the scenic amenity that
is of very high value to the Kiama Community. It will also impact on
the residents of The Village (dust and noise pollution), increase
traffic affecting the suburbs of Minnamurra, Kiama Downs and
Gainsborough. I am also concerned that Kiama Waste and Recycling Depot
is very close and sand extraction in that location will potentially
impact upon groundwater hydrology, mobilising contaminated groundwater
with resultant impacts on the adjacent Minnamurra River. This
potential risk has not been sufficiently evaluated.
I ask that the Department of Planning terminate the current assessment
process and consider this a new proposal, as Areas 5A and 5B are
distant from the current approved extraction areas and will have a
range of different impacts.

I object to the proposed sand mining Dunmore Lakes. I believe that this
mining would have a significant negative impact on the littoral
forest, Bangalay sand forest and flora including Bangalay (Eucalyptus
botryoides) and Coast Banksia (Banksia integrifolia subsp.
integrifolia), while Blackbutt (Eucalyptus pilularis) and Lilly Pilly
(Acmena smithii), fauna living within the forest, fish within the
river and the general amenity of the area. This area is used by many
locals for river activities including fishing, kayaking,
paddleboarding, swimming, walking.

I oppose because of the need for us to protect our coastal wetlands and
rainforests in their natural state, including their biological
diversity and ecosystem integrity. These areas are both located in
very close proximity to the Minnamurra River, and will impact on
ecologically important ecosystems, tourism and this beautiful area
that is of such inestimable value to the Kiama and surrounding
communities. There will be significant impact on flora and fauna and
adjoining coastal wetland ecosystems and the unacceptable loss of
ecologically endangered forest.

To Whom it may Concern,

I request that the NSW Dept of Planning apply the Precautionary
Principle in regards to this proposal. This is a very beautiful,
environmentally significant area and at the very least deserves a
thorough investigation and time to consider the consequences of this
proposal.
I believe the small short term gains are far outweighed by the
detrimental impacts on the environment, flora and fauna
.
Consequences to consider

* destruction of endangered Bangalay sand forest
* impact on coastal wetlands
*impacts on tourism
*impacts on the scenic amenity of a really beautiful area
*contaminated groundwater entering the pristine Minnamurra River

The areas proposed in Modification 2 are physically separated from
those in the original approval and have greater likelihood of causing
environmental impact.

Please look at this with the great care and consideration it deserves.

Kind Regards

Jennifer Gardner

I'm opposed to Borals plan to mine sand in areas 5A and 5B until further
research is done into the impact this will have on the local ecology.
As it stands, it doesn't appear to be a sustainable long term option.
The people of this area are passionate about the Minnamurra, the
health of this river system should not be sacrificed to serve big
business. We need more information about the long term impact of this
project.

I've been a resident of Kiama Downs for over 29 years. When I heard about
the proposal to extend the Boral Sand Mining Operation to the site of
Dunmore house I was disgusted that a decision of this size and
potential impact had not been thoroughly and adequately investigated
or actively put to the community this will affect. While a venture
such as this will impact Boral in the short term it is the residents
and community of Kiama, Kiama Downs, Minnamurra, Gainborough, Dunmore
and Shellharbour who will have to live with the long term and
permanent impact of such an operation.
A closer look is needed to ensure a proposal of this magnitude is as
beneficial to the community AND environment it will impact as the
company.

Having watched the sand mining operation being carried out over the
last few years on the once lush farming land along the Highway at
Dunmore and being yet to see any form of environmental rehabilitation
of their existing site, I am extremely concerned about the future
should this enterprise be allowed to expand operations. I strongly
oppose the modification 2 and urge the reconsideration of this
proposal based on the following:

The areas proposed in Modification 2 are physically separated from
those considered in the original approval and have a far greater
likelihood of causing environmental impact.
Areas 5A and 5B are both located in very close proximity to the
Minnamurra River, and unlike the existing extraction areas, has the
potential to impact on ecologically important ecosystems such as
Coastal Wetlands and Bangalay Sand Forest, in addition to impacts on
tourism and the scenic amenity that is of very high value to the Kiama
Community.
Area 5A is located opposite Kiama Municipal Council's Waste and
Recycling Depot and sand extraction in that location will potentially
impact upon groundwater hydrology, mobilising contaminated groundwater
with resultant impacts on the adjacent Minnamurra River. This
potential risk has not been sufficiently evaluated.
The proposal appears to be inconsistent with the Objectives in Part 2
Section 6 of the Coastal Management Act 2016 (and the former SEPP 71)
which are as follows:
(a) to protect coastal wetlands and littoral rainforests in their
natural state, including their biological diversity and ecosystem
integrity,

(b) to promote the rehabilitation and restoration of degraded coastal
wetlands and littoral rainforests,

(c) to improve the resilience of coastal wetlands and littoral
rainforests to the impacts of climate change, including opportunities
for migration,

(d) to support the social and cultural values of coastal wetlands and
littoral rainforests,

(e) to promote the objectives of State policies and programs for
wetlands or littoral rainforest management.

The potential impact on Flora and Fauna is likely to be significant
and has not been evaluated sufficiently. Area 5B is surrounded on
three sides by the Minnamurra River and coastal wetland containing
mangrove forests and salt marsh.
Area 5B is very low-lying and council is concerned that the extraction
will impact on natural groundwater and surface water (flood) flows
with resultant impacts on the adjoining coastal wetland ecosystems.
According to the supporting documentation, 56% of Area 5B is made up
of Bangalay Sand Forest vegetation that is classified to be in either
moderate or good condition and it is proposed to remove completely
4.53 hectares of this ecologically endangered forest.
Council is concerned about noise and dust pollution to the residents
of The Village (part of Minnamurra, off Riverside Drive), located
within 500 metres of Area 5A.
Council is concerned that increased heavy vehicle traffic on Riverside
Drive to service area 5A (including proposed backfill at that site)
will add a significant traffic risk on the primary northern access
road to the suburbs of Minnamurra, Kiama Downs and Gainsborough and
has not been adequately addressed.
Neither council nor the community has been provided access to Area 5B
to allow evaluation of the impacts of the proposed Modification.
2) Request the Department of Planning terminate the current assessment
process and consider this a new proposal, as Areas 5A and 5B are
distant from the current approved extraction areas and will have a
range of different impacts.

3) I would like to request request the Department of Planning, either
as part of this (or any new) proposal, offer a guided site tour in
conjunction with the proponents to Kiama and Shellharbour councillors
and staff and interested community group representatives

4) Amend the Submission to the NSW Department of Planning and Industry
to add the points raised above and include a copy of the council
resolution.

All members of the community which is Kiama (including Kiama, Kiama
Downs, Minnamurrra, Gainsborough, Dunmore and Shellharbour) have a
responsibility to protect it for future generations. This
responsibility also falls upon those who may allow or deny the
proposal in Modification number 2.

The Precautionary Principle ought to be applied in relation to this
application. The risks are far too great and the environment ought not
be compromised and degraded. The request ought to be refused. I
strongly urge the Councillors of Kiama and the Department of Planning
to give all impacts of this request the consideration it needs from
all angles especially the long term consequences of such an operation.

Exhibition of Modification Request
Dunmore Lakes Sand Extraction Project
DA 195-8-2004 Mod 2

Department of Planning and Environment

I strongly object to this proposal. I have not made, nor have ever
made, any political donations and lodge this objection as a concerned
citizen.

I was made aware of this proposal while viewing potential properties,
searching for a new home in the Minnamurra area. I have family in the
region with young children and I was distressed to learn of the impact
this proposal would have on the environment, wildlife and amenities
for the current and future generations. These features are attractions
that have influenced my decision to live in the area.

I have read the proposal in some detail. It is my understanding that
the two sand pits in question are in low lying areas close to the
Minnamurra River; in particular, Pit 5B is on the flood plain on a
large bend of the river.

This Pit 5B has a proposed depth of 27m over a huge area of almost 8
hectares. If this is left as proposed as an open water body, it will
require the removal of trees and vegetation which are habitat to many
endangered species. The main vegetation is mature Bangalay Sand
Forest, which the NSW Office of Environment & Heritage lists as an
"endangered ecological community."
https://www.environment.nsw.gov.au/threatenedspeciesapp/profile.aspx?id=20035
The loss of this forest will do irreparable damage to the local
ecosystem.

Proposed Pit 5A is adjacent to the former Minnamurra waste disposal
facility, where there is recorded evidence of a large toxic plume in
the water table.
http://www.kiama.nsw.gov.au/ArticleDocuments/722/Minnamurra-pollution-incident-plan-April-2015.pdf.aspx
Removing sand from this pit risks fluctuations in the water table,
which could cause this toxicity to leach into the Minnamurra River.

Also of concern is the intention to truck 235,000 tonnes of landfill
from Sydney to fill the mined pits. The prospect of thousands of laden
truck journeys contributing to the already congested M1 Motorway and
then turning off onto local roads is a recipe for traffic and road
safety chaos. This heavy traffic is also likely to impact tourism to
the Kiama and Shellharbour districts, and to local residents who have
to travel north to work.

It defies logic that this proposal for two new mine sites is described
as a "modification" to an original mining approval granted for the
Rocklow Creek catchment in 1999. It is clear from all available
information and maps that this is a new and separate attempt by Boral
to mine for sand in the highly environmentally sensitive Minnamurra
River Catchment. It should be subject to fresh and rigorous
assessment.