Mod 2 - Local Product Delivery

My submission is attached as a pdf document.

Bungonia & District Historical Society Inc,
Hon sec
A Wiggan
King st
Bungonia. 2580.


Major Development Assessment,
Dept. of Planning,
PO Box 39,
SYDNEY 2000

Submission in Response to the Project (07 0155 Mod2) "Ardmore Park" Quarry via Bungonia, NSW.


The Bungonia & District History Soc. Inc. object to the proposed Modification "Ardmore Park" Quarry Development .

Basically this modification is an attempt to establish a different access to the Hume Highway:
it is a proposed operational haul route for a major supply chain and should be treated as a major change to the existing Conditions of Consent for the Ardmore Park Quarry . The Proponent has indicated that ,beyond the numbers presented to the public in the EA document ,there could be an increase in truck movements (see the newspaper report on page A2-5 in the Environmental Assessment Report).where Mr. Micosic indicates that
* The proponent states an interest in supplying the wind farm on Kialla Rd Gunning ;
Mr. Micosic stated ---Multiquip was supplying to sub-contractors of the Gullen Wind farm" " "Goulburn Post 31 May: extract supplied in Appendix 2 of this proposal
Gullen Range Wind Farm
The proposed Gullen Range Wind Farm (GRWF) is located approximately 20km West of Goulburn, NSW. Seventy-three (73) wind turbines were given planning approval in August 2010 and will be constructed.
Also in this article "Goulburn Post 31 May: extract supplied in Appendix 2 of this proposal.
This statement is a clear indication that
a/ the truck movements identified as the basis for this application requested will be subject of further upward pressure over time,
and
b/ that contrary to the Conditions of Consent Mr. Micosic says he is currently supplying ---i.e. operating the Quarry and possibly even moving material out of the Quarry site.
Furthermore there seems to be a specific Haul route.
c/ Mr. Micosic's suggestion that the location of the sub-contractor was " a neighbour in Windellema" would indicate that there is a definite proposed route to that specific destination ;

* By using rural roads that in earlier reports and assessments for the initial DA by CEAL were excluded because they were rightly dismissed as unsuitable to the Quarry Proponent and not able to support the Quarry long term viability .
* By again maintaining that unimproved roads are suitable as a haul route despite being shown to be wrong in the past.
* Disregarding the rights of existing road users.
* These roads were not considered in any detail the supporting documentation to the original DA and are not covered in any detailed way in the current Environmental Assessment.
* Use of the existing entrance to Ardmore Park and turning left will damage the root system of the Larbert Tree. This tree is of historical significance and the Proponent has said in the past and in previous documentation that he will preserve it.
* the use of unimproved local roads in the greater Goublurn Mulwarree area for truck haulage is against the strategic planning principles for vibrant societies with appropriate infrastructure to support major Part 3 A developments. for the
* The proponent has not stated clearly or defined what grade of vehicle will be used as basic to this application.; EA Report 625/7 1.4 the proponent says he has a fleet of B-Doubles and semi-trailers; no mention of truck and dog - or single units that are the other vehicles mentioned for this route. Contractors are not liable to uphold the Conditions of Consent of the quarry.


One of the reasons for refusing consent to the D.A submitted in 2005 was " The existing conditions of Jerrara Road, Oallen Ford Road and King Street are in a poor state
and considered not to be of suitable standard to accommodate the proposed increases in traffic movements."
Justice Jagot in her judgement said ( para. 33) " Accordingly, the existing road infrastructure is inadequate to accommodate the consequences of the operation of the proposed quarry."
TRANSPORT and SOCIAL IMPACTS
This EA pays scant attention to the rights of the present road users or to the inadequacy of the proposed route. We would like to make the following points:
* Existing Road Network: The proposed transport route along Oallen Ford Rd. and Windellama Rd. have verges less than ½ metre, broken edges, varying widths (which is considered as dangerous as narrow roads) and in many instances poor road surface. Lumley Rd. is not sealed and is narrow. The Environmental Assessment considers the section of Lumley Rd. from Oallen Ford Rd. to Windellama Rd. unsuitable and the road doesn't improve after Windellama Rd. This section of Lumley Rd. is incorrectly labelled Tarago Rd in Figure 4 Page.8 On the same map Jerrara Rd is called Oallen Ford Rd.

We consider that the increased traffic movements of 10 truck movements a day plus additional traffic movements for support vehicles (conveniently overlooked in the EA) on such roads would affect:

* the safety of all road users,
* the state of the roads and
* damage the Larbert Tree root system. See the attached Arborist's Report.

The entrance should be moved back to where it was before Modification No.1. This would take out all the Lumley Road traffic turning north onto Oallen Ford Road and the reverse. It would also preserve the Larbert Tree

SOCIAL IMPACTS INADEQUATELY EXAMINED .
The stated economic and social benefits are assertions and not supported by facts.
Traffic counts from Goulburn Mulwarree Council indicate the huge numbers of increased vehicle traffic of all sorts on these roads. Much they put down to tourism and to the regular recreational movement of vehicles from Canberra, and the Coast Bungendore ( large new residential and Military Facility ) especially via the newly opened route 92. The traffic counts provided by Ardmore Park proponent do not capture any of these traffic flows , therefore they cannot have taken the extent of impact on public access and use of these roads into account.
There are contradictory statements about the use of Restricted Roads and statements claiming wide community consultation that are untrue.
INADEQUATE CONSULTATION
There has been no effort on the Proponent's part to notify residents affected by the changed haul route. Johnno's shop is a small takeaway & limited grocery supplies shop on Oallen Ford Rd. closer to Bungonia than Windellama -the and the locations more likely to be affected by the proposed changes.
Appendix2 Community Consultation
1 Multiquip local deliveries community consultation letter
2 Goulburn Post Extract 31 May 2013

No 1 stated "we are conducting meetings with community members through out May 2013 to identify any issues that may arise during this application ;
the meetings of community were confined to 1 at Windellema school and 1 at Bungonia where the proponent left having stated he was "not prepared" to present the proposal or to answer questions.
IN the previously referenced Goulburn Post article
Mr. S MIcosic stated that he "didn't see the need for any community meetings beyond his discussions with Windellema school regarding school bus times"
The Bungonia Times itself, at its own cost , forwarded the notification put out by the Proponent to the Windellama News.

NOT IN THE PUBLIC INTEREST
SECTION 94 contributions are inadequate to support traffic on unimproved rural roads. AS Mr. Corkery pointed out in the EA report- the assessments are 'desk-based and unlikely to indicate the true condition on the ground of the roads labelled as passable.
In the EA there are numerous statements about using this or that road if it rains or does not rain -,that fact plus all the weight limits in the district should ensure heavy vehicle operators understand that the roads are NOT for any regular heavy vehicle applications at all.
All Major developments put the associated traffic as immediately as possible onto the adequate infrastructure as part of the major Projects Planning strategy. Public roads for use as a quarry haul route have to be upgraded to manage the extra impacts before being used for private gain .
It is not in the public interest to ask the public to pay for damage to sub-standard roads.
NO JUSTIFICATION FOR APPLICATION
Two vast Quarries at Marulan Linwood and Boral as well as Southern ,also recently consented ;all make the same or equivalent use products; they are situated on substantial and high grade road and rail infrastructure corridors and have no need to interfere with residential areas or rural road users.
One year of their output dwarfs the entire lifetime output as projected for this development.
They are ideally placed to provide material to all the wind farm developments along major arteries to any wind farm sites.

Locally there are numerous other suppliers e.g. Divall's , Goulburn Sand and soil, Rocky Hill Sand and supplies; Southern Highlands Landscape supplies, Packsons Quarries, Highland sand and gravel; Burgess sand and gravel., easily able to supply a local market;
They are not Part 3 A approved and are small local operations .Local needs are easily supplied by these competing operators.
All have access through the Sydney Canberra Corridor as does the current Ardmore Park Quarry Consent.

We refer also to Boral Promotional material from its website
The quarry is not only strategic for Boral, but
extremely important for the local area and the
Sydney building and construction industry.

, our strategy is to
ensure we have a continuous, cost-effective
supply of aggregates

"In 2004/05 we upgraded our Dunmore
Quarry to 2.5 million tonnes per annum and
also obtained approval to expand the Peats
Ridge Quarry to 800,000 tonnes annually.
"We also acquired two strategically valuable
sand operations at Dunmore and Penrose.
Dunmore Sand provides Boral with a
particularly good set of synergies, being next
to our hard rock resource at Dunmore and on
rail. It has sufficient consented reserves for
15 to 18 years depending on the output, plus
a further 20 years worth of reserves for which
consent has not yet been sought,"

The new Marulan site has the advantage of
being located alongside the existing Blue
Circle Cement rail spur, which means that
100% of the product will be railed to Sydney.
At 3.5Mtpa, this will remove 250,000 truck
movements annually off the road and thereby
reducing GHG emissions by well over 5,000
tonnes of CO2
.
The quarry will be industry best practice
in terms of sustainability,

We request that the proposed Modification is not allowed and that the quarry is held to its existing Conditions of Consent .
Sincerely
For the Bungonia and District Historical Soc Inc.
Hon.Sec. A Wiggan

I am lodging this submission on behalf of my wife and myself. All our comments are incluided in our attachments.

Kenneth L. Knights

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