Mod 1 - Surface Water Diversion

This Dubbo Hardrock Quarry Modification for a Diversion Drain - with overflow Water washing into Eulomogo Creek is a very destructive plan as it will alter groundwater dynamics - causing Public Health & Safety Risks - distributing contaminated water downstream where it will detrimentally affect groundwater elsewhere.

Biodiversity impacts have been deliberately downplayed & not adequately surveyed or even assessed by a relevant BDAR expert.

Australians are totally fed up with ruinous Quarrying & toxic Sandmining that support the Reckless Ruinable Rip-off - that’s only prioritising greedy, Predatory Vested Interests - who are despicably torturing rural communities, poisoning our essential soil/water & wrecking Australia.

I am firmly opposed to the destructive and irresponsible Dubbo Hardrock Quarry Diversion Drain Modification Plan, submitted by Holcim Pty Ltd.
This proposal for Sheraton Rd, Dubbo, is deeply troubling - with serious, irreversible harm to the environment the Dubbo/NSW community and future generations inevitable.

The area is already severely impacted by reckless renewable energy schemes, including the proliferation of toxic, slave labour reliant, PFAS-laden solar, wind, and battery energy storage systems scattered across Dubbo Shire.

The further plans outlined in the proposal—such as changes to the surface water diversion drain, reducing the safety bund height in the southern extraction zone, and increasing the importation of fly ash and concrete waste—pose serious, irreversible threats to the local ecosystem and community as these actions will lead to unassessed, cumulative impacts on vital habitats and species, contaminating the essential water system, including Eulomogo Creek, which is directly adjacent to the proposed project site.

The qualification of the author of the Biodiversity Development Assessment Report (BDAR) for this project, a Doctor of Philosophy in an unrelated field, raises questions about the competence in assessing biodiversity impacts.
This plan demands rigorous review by independent experts, free from vested interests, to accurately evaluate the public health risks, environmental damage, and threats to local biodiversity.

The biodiversity surveys conducted thus far are wholly inadequate.
Relying on ineffective biodiversity offsets as a solution is not acceptable and undermines real conservation efforts.

The proposal threatens critically endangered ecological communities, including the White Box-Yellow Box-Blakely’s Red Gum Grassy Woodland, essential habitat for species like the koala.

The applicant admits uncertainty regarding the flow of genetic material between local flora and fauna populations, underscoring the need for the precautionary principle to halt this plan.

The impacts on listed threatened and migratory species, including the koala, are far-reaching. The potential for extinction of local populations is ignored, and these impacts must be urgently assessed by the Federal Department of Climate Change, Energy, the Environment, and Water (DCCEEW).
The proposal also jeopardizes key fish habitats and riparian land in Eulomogo Creek, which could face irreversible damage from contaminated runoff and sedimentation, affecting both aquatic and terrestrial species.

The potential contamination of groundwater from construction and ongoing operations of the diversion drain poses additional risks that cannot be mitigated.
Claims that runoff won’t affect groundwater dynamics are unsubstantiated, and the possibility of widespread contamination across the region is highly concerning.

The site supports numerous endangered species and critical habitat, including the koala, grey-headed flying fox, various bats, gliders, and birds. These species depend on the wetlands, vegetation, and watercourses that will be disrupted by the proposed modifications.
The absence of a thorough and accurate ecological impact assessment raises serious concerns, and the proposed mitigation measures are entirely insufficient.

The cumulative effects of this project, alongside past and future developments, will contribute to the ongoing decline in biodiversity across New South Wales.
Local authorities, including Dubbo Council, have failed in their duty to properly assess the risks and are complicit in promoting harmful, unsustainable practices that will inflict irreversible environmental damage.

Continued->
References:
**Biodiversity Offset Crisis
https://www.crikey.com.au/2023/05/18/biodiversity-offsets-scheme-crisis/
 Biodiversity offsets are arguably one of the most damaging environmental policies in a smorgasbord of bad policies, according to the environmental community…..
Offsetting has become a trading market with no real transparency or demonstrative environmental benefits. Proponents self-refer projects, both at the NSW government and federal levels.’

Applicant - Holcim Pty Ltd has presented an objectionable plan for Sheraton Rd, Dubbo regarding the Dubbo Hardrock Quarry - Diversion Drain - which will ensure ECOCIDAL impacts & extensive suffering & hardship for the community & future generations.

Already riddled with reckless RenewaBULL ruination & the inevitable, catastrophic consequences of unethically sourced, toxic, PFAS shedding Solar/Wind/BESS JUNK strewn EVERYWHERE - as far as the eye can see throughout Dubbo Shire - further careless plans of “A design change to the surface water diversion drain location, reduction in the height of the southern extraction area safety bund and an increase in the quantity of fly ash and concrete waste imported to the site per year” only 2.5 km southeast of Dubbo, will result in seriously detrimental, irreversible cumulative impacts that have never been properly assessed for Critical Habitat and Threatened Species & contaminating impacts to the vital water system - including Eulomogo Creek which runs directly adjacent to the subject land - receiving the overflow water from the drain that is being constructed for this proposal.

One has to seriously question the suitability of a Dr of PHILOSOPHY in writing the BIODIVERSITY DEVELOPMENT ASSESSMENT REPORT
DUBBO HARDROCK QUARRY – DIVERSION DRAIN
DUBBO REGIONAL COUNCIL LOCAL GOVERNMENT AREA JULY 2024
Report prepared by OzArk Environment & Heritage for Holcim (Australia) Pty Ltd.

Reputable, Independent, Peer Reviewed Experts without Vested Interests are required to factually assess this plan & all the related cumulative impacts to Public Health & Safety, to the Ecology & Biodiversity, for Air & Noise Quality, Land & Water Contamination Risks, for Increased Traffic Congestion, Increased Rate Costs for Road Repairs, Hazardous Safety Conditions contributing to more accidents & higher Vehicle Insurance charges, etc.

Biodiversity Surveys have been completely inadequate & fobbing off the protection of nature & caring for country to useless Biodiversity Offsets is farcical & not acceptable.

EPBC Listed Critically Endangered Ecological Community (CEEC) White Box - Yellow Box - Blakely’s Red Gum Grassy Woodland and Derived Native Grassland will be impacted by the proposal with its understory far more substantial than claimed.
This is essential foraging, breeding & roosting habitat - which is important to the survival of endangered species such as the koala.

The Applicant admits it is unclear what extent gene flow persists between the site and other local communities for many flora and fauna species - which highlights the need for the Precautionary Principle to apply & the Modification plan halted.

The significance of the proposed impact to EPBC Act-listed threatened, migratory, wetland and marine species, populations and communities predicted to occur within the area has not been adequately assessed - with significant impacts to threatened entities such as the koala - likely to result in the extinction of a local population ignored.
The residual ecological impacts of the proposal cannot be adequately mitigated and offset, therefore, a referral of the proposal to the Federal Department of Climate Change, Energy, the Environment and Water (DCCEEW) for these matters is definitely required.

As adjacent Eulomogo Creek contains Key ‘Fish Habitat (KFH) - recognised by the Department of Primary Industries – Fisheries (DPI), and Protected Riparian Land (PRL), as recognised by the Department of Planning and Environment (DPE)’ - contaminating overflow water including toxins & sediment from the diversion drain is completely unacceptable.
With dredging and reclamation there will be detrimental impacts in Key Fish Habitat & to Protected Riparian Land & Waterfront Land.

According to the BDAR, there is a risk that significant accumulation of sediment or other contaminants may result from the diversion of surface run-off water into the Eulomogo Creek as well as the seven Strahler 1st order, non-perennial watercourses onsite.
Describing risks associated with runoff and sedimentation identified in the NSW Diffuse Source Water Pollution Strategy (DECC, 2009) which will alter flow regimes of the watercourses by filling depressions in the river bed and, should sediment accumulate around snags or in-stream structures, by narrowing or restricting the channel.
It is most likely that in extreme cases, sediment may obstruct fish passage or may directly impact fish health by inhibiting respiration and feeding activity. Run-off will also introduce unwanted chemicals from blasting & quarrying into watercourses, with adverse, poisonous effects on water quality (e.g. eutrophication) affecting human beings, stock, wildlife & fish health.

The Bureau of Meteorology Atlas of Groundwater Dependent Ecosystems identifies a moderate - potential terrestrial GDE within the subject land for Dubbo Quarry Diversion Drain.

Whilst the proposal does not include the direct extraction of groundwater, contamination from construction and operation of the diversion drain will impact on the quality of groundwater as adequate mitigation measures are not possible.

Despite false claims by Approving Bodies & the Applicant - they are NEVER capable of guaranteeing that the Diversion of run-off water won’t alter groundwater dynamics on a wider scale, for example by reducing local infiltration and replenishment of groundwater, or by distributing contaminated water downstream where it may adversely effect groundwater elsewhere.
Alarmingly, the significance of these potential impacts on biodiversity both within the site and in the wider landscape is even stated as UNCERTAIN by the Applicant!!

Mitigation measures to reduce the impacts of erosion and runoff, which may adversely affect groundwater, have NOT & can NOT be adequately provided at all.

Numerous, life sustaining, breeding nests - stick nests, grass nests, cup nests, and the ‘dormitory’ nests of Grey-crowned Babblers (Pomatostomus temporalis temporalis) are present onsite with active cup nests belonging to White-plumed Honeyeaters (Lichenostomus penicillatus)

Many species dependent on the wetland environment of the Eulomogo Creek are reliant on this uncontaminated habitat, as well as significant flanking vegetation, including Tall Sedge, Common Reed and bulrushes.
The creek also contains areas of cobble which provides habitat for amphibian species.
The pools of water in Eulomogo Creek contain invertebrate life, as well as fish & tadpoles which the Applicant failed to observe & assess.

EPBC Listed Critically Endangered Ecological Community (CEEC) present - White Box - Yellow Box - Blakely’s Red Gum Grassy Woodland and Derived Native Grassland

EPBC Listed Threatened Fauna & Flora Species & numerous NSW Threatened Species present, likely to occur on site &/or reliant on the site for essential foraging habitat.

Koala - Endangered - essential CEEC habitat
Grey-headed Flying-Fox - present (recorded) - Vulnerable
Corben’s Long Eared Bat - Vulnerable
Eastern Pygmy-possum
Squirrel Glider
Yellow-bellied Sheathtail-bat
Regent Honeyeater
Dusky Woodswallow
Little Pied Bat
Glossy Black Cockatoo (foraging)
Spotted Harrier
Speckled Warbler
Brown Treecreeper (Eastern subspecies)
Varied Sittella
Spotted Tail Quoll
Black Falcon
Little Lorikeet
Painted Honeyeater
White Bellied Sea Eagle (foraging)
Little Eagle (foraging)
White Throated Needletail
Swift Parrot
Hooded Robin (south-eastern form)
Square Tailed Kite
Large Bent-winged Bat (foraging)
Black Chinned Honeyeater
Barking Owl
Scarlet Robin
Flame Robin
Torquoise Parrot
Barking Owl
Grey-crowned Babbler (eastern subspecies)- recorded present
Bush Stone-curlew
Diamond Firetail
Masked Owl (foraging)
Pink-tailed Legless Lizard
Paul Headed Snake
Bluegrass
Scant Pomaderris
Silky Swainson-pea
Tylophora linearis

The direct & indirect impacts associated with the proposal are substantial & will not be able to be contained within the subject land - consequently, the cumulative impacts of this destructive proposal are enormous - contributing to the wider loss of biodiversity in the local area and across NSW.
The incremental effects of multiple impacts – past, present, and future – must be properly considered in the wider context - which to date has NOT been done at all by the gullible & irresponsible Dubbo Council - who has failed to do its Due Diligence by objecting to the DPIE/DPHI’s wretched & risky RenewaBULL Experiments - the Moral Hazard they are carelessly & deliberately inflicting on Local Regulatory Authorities - cursing their Shires with toxic contamination of their land & waterways - along with this related quarrying + stacks more toxic mining that is causing ECOCIDAL destruction of NSW/Australia AGAINST OUR WILL!

All the Principles of Ecologically Sustainable Development, the Koala Recovery Plan & all aspects of the National Electricity Law have been deliberately defied by this destructive, contaminating RenewaBULL related, Dubbo Hardrock Quarry - Diversion Drain plan.

References:
National Koala Recovery Plan is clear, unequivocal and must be applied to development proposals undergoing Federal Environmental Assessment.  
Page 80 of the National Koala Recovery Plan states that the following activities should be avoided: 
• clearing of habitat used by Koalas for feeding and resting  
• reducing connectivity between patches of habitat used by Koalas for feeding, resting, commuting and dispersing (either by clearing of vegetation or by the erection of barriers to passage)  
• clearing of habitat used by Koalas during extreme events (heat waves, drought/fire refuge)  
• activities that will expose Koalas to additional threats (e.g. dogs, cars) in places where Koalas must use the ground to move between resting and feeding trees.
👉Halt further destruction of endangered koalas -
https://tinyurl.com/5y9ddm24

I am very concerned about the contamination to the Eulomogo Creek and the impact to groundwater both in the immediate area and the broader community.

This project is an environmental disaster.

This is project is environmental vandalism. The contamination of groundwater and surface water in the immediate area will impact on biodiversity both within the site and the broader community.

This is an enviromental disaster: the Eulomogo Creek will receive the overflow water from the diversion drain.

The likely outcome will be the groundwater contamination and the distribution of contaminated water downstream further impacting groundwater elsewhere.

Stop wrecking our environment.

refer to attached letter regarding potential groundwater level impacts