Mod 2 - Quarry Expansion

We live approximately a kilometre due East of Gunlake Quarry and I am concerned about the level of dust that we will be subjected to if the expansion is allowed to go ahead.
Currently we are experiencing a large amount of dust from the quarry as the prevailing winds are mainly from the West.
Also re the comments from the proposal:
'Gunlake do not anticipate any road infrastructure will require installation or modification
current acoustic and air quality
criteria will not require modification'.
We are ok with the noise levels; however we would would question the statement re the air quality and I would request that the quarry management install a permanent air quality monitoring device close to our house to determine the volume and make up of the dust that settles daily on our property and make the results available to us to on a monthly basis.
yours Faithfully
Lycurgus David Underdown

Reference my previous submission requesting an air quality monitor be placed next to our home and the data be made available to us( in plain English) on a regular basis; the quarry management have agreed to the above and as such we don't have any objection to the expansion.

My submission is for the rejection of expansion of quarry on following grounds.
1. I am concerned at the large increase in heavy vehicle traffic flow on Brayton Road the expansion would create. Currently Heavy vehicles travel at high speeds on the narrow road which has no centre line marking, fog line marking or turn lanes marked into quarry entrance. Drivers do not obey Give way signs and it is only through good luck that a serious accident has not occurred.
2. The noise pollution from the quarry can be heard at my residence which is approx. 8 km away as crow flies under certain wind/ atmospheric conditions. The dust pollution can be seen for several KMs.
An increase in operating hours would impact heavily on the surrounding communities of Brayton, Marulan, and the Towrang Valley with additional noise and lighting as well as traffic flow.
3. With a quarry operating even at its current capacity why hasn't movement of material by rail been planned and a rail siding from the main southern line connected to the quarry.
4. Community Consultation must be undertaken before any decision is made on this matter and the residents and land holders in the communities have to be considered.
5. Is there a land restoration plan in place.
6. Is local Landcare involved in any planning discussions.

The proposed extension to the Gunlake hard rock Quarry is unacceptable in its current form.
A number of serious issues exist and have not been adequately addressed.
These include
Noise
A comprehensive and complex noise study has been completed and presented. Very nice but it is WRONG. The current crusher can be heard regularly and the noise of a crusher is particularly penetrating, unlike white noise. If they are unable to get it right now with the current system we can only expect it to get worse. The existing equipment needs to be controlled before the expansion is approved.

Dust
Currently the Gunlake quarry can be first identified by the dust. There is concern about the amount of dust and the potential for dust diseases. Silicosis, and mesothelioma took time to become evident. We do not want to be the future dust disease story. Prudent avoidance is the only practical solution and so the dust needs to be controlled at its source.

Lighting
The visual amenity of our area is important to us. Holcim Pty Ltd have been working with us to control the light spill from their quarry to sort out the sins of their past. The section of this proposal that applies to lighting spill says "Nil" They have got to be Joking.

Roads
The current extraction uses rural roads to transport the product. The roads were not built for this purpose and they are rapidly falling apart. If Gunlake wish to use the roads then that is fine but they must upgrade the road to a safe and satisfactory state. We the community should not be subsiding their operation by way of funding the road. They currently get the rock for free.

Community
The community loses at almost every step in this process. We have significant impacts even if they get their environmental plan in place with relatively few jobs generated. A community support fund needs to be set up to pay for community improvements. A similar system to the Veolia Trust would be appropriate. If this is not included in the approval then the company will quickly find a way to shut it down. After all the get the rock for free.

These represent a number of totally unacceptable risks and penalties to our community and the application should not be approved as it stands.

CRUNCH CRUNCH CRUNCH CRUNCH CRUNCH CRUNCH CRUNCH CRUNCH CRUNCH CRUNCH CRUNCH CRUNCH CRUNCH
Irritating isn't it.
CRUNCH CRUNCH CRUNCH CRUNCH CRUNCH CRUNCH CRUNCH CRUNCH CRUNCH CRUNCH CRUNCH CRUNCH CRUNCH
It is what I hear when the wind is wrong.
CRUNCH CRUNCH CRUNCH CRUNCH CRUNCH CRUNCH CRUNCH CRUNCH CRUNCH CRUNCH CRUNCH CRUNCH CRUNCH
It does not take long for it to be as a toothache
CRUNCH CRUNCH CRUNCH CRUNCH CRUNCH CRUNCH CRUNCH CRUNCH CRUNCH CRUNCH CRUNCH CRUNCH CRUNCH
The current noise calculations are either wrong or have been treated with contempt.
CRUNCH CRUNCH CRUNCH CRUNCH CRUNCH CRUNCH CRUNCH CRUNCH CRUNCH CRUNCH CRUNCH CRUNCH CRUNCH
Do not approve the expansion until this is sorted.
CRUNCH CRUNCH CRUNCH CRUNCH CRUNCH CRUNCH CRUNCH CRUNCH CRUNCH CRUNCH CRUNCH CRUNCH CRUNCH

The applicant, Gunlake Quarries (Gunlake), proposes that they would be an independent quarry producer providing aggregates to its own operations in Sydney, as well as other potential markets. The applicant has one concrete plant established and trading as Gunlake Concrete at Smeaton Grange, with a second plant operational in the Blacktown area at Glendenning and a third proposed for the Silverwater area. Gunlake's justification for the proposed development is in order that their concrete operations will be provided with secure, long-term supplies of aggregate and manufactured sand, and that to obtain supplies from sources such as major international companies would be at a higher cost and may affect the longer term viability of their planned concrete operations.

Gunlake is seeking to expand at a rapid rate, yet is failing to adhere to the Conditions of Consent as set down by Department of Planning and Infrastructure, and has a history of non-compliance. We object to the proposed expansion by Gunlake based on several concerns and issues, as outlined below.

Resources

The applicant has identified that the proposed project site lies within the Bindook Volcanic Complex of the Devonian age, and that tests have determined the resource materials to be suitable for use in a full range of quarry products, including concrete and sealing aggregates, rail ballast, manufactured sand, and roadbase. The Environmental Assessment (EA) produced by Olsen Environmental Consulting Pty Ltd states that saleable products will be transported to Sydney and other markets to the north and south of Marulan, with approx 80% or more to the north.

The applicant states that there is a need for an independent producer to provide competitive quarry products into the Sydney and local markets. Currently there are major international companies, as listed below, who are either in production or under development consideration, which have the capacity to supply these markets with the same standard of product, now and in the future.

¨ Penrose Sand Quarries, Hume Highway, Paddy's River, Penrose, NSW, (25kms north of Marulan) - earmarked by Dept of Mineral Resources to supply Sydney/Wollongong/Canberra region with any sand type at a capacity of 150 million tonnes over a period of >100 years' duration;
¨ Holcim Quarry Johnniefelds, Marulan - generates between 250,000 and 300,000 tonnes of aggregates, rail ballast, sand and roadbase per annum;
¨ Boral Quarry at Marulan South - approved (subject to conditions) to produce up to 3.5 million tonnes of product per annum; and
¨ Holcim Quarry Lynwood, Marulan - approved (subject to conditions) to produce up to 5 million tonnes of product per annum.

Both Holcim Lynwood and Boral Marulan South intend to transport the bulk of their products to market via rail. We have been advised that Holcim Lynwood will have the capacity to remove approx 4,000 tonnes of aggregate from their site and have it loaded onto the rail system within 2 to 3 hours using two locomotives for transportation. If this amount of product was transported to Sydney via road, it would take approx 260 truck movements 3 to 4 driving hours per truck. Transportation by rail is safer, more economical and produces less greenhouse emissions

It is widely understood that the percentage of aggregate and sand required to manufacture concrete is between 60% and 70% of the total product extracted, with the remainder being saleable product to other markets. It is also widely understood that the quality of the sand extracted from a hard rock quarry cannot be used on its own in the manufacture of concrete and that further supplies of sand will need to be sourced elsewhere. As stated previously, the sand quarry at Penrose has the capacity to supply any sand type to the region for over 100 years.


We still believe the requirements of the Sydney metropolitan region for hard rock aggregate and sand can be adequately serviced by the Penrose Sand, Boral and Holcim quarries.
Gunlake Quarries' proposed expansion to 750,000 tonnes, together with Holcim Johnniefelds 500,000 tonnes would total 1.25 million tonnes of saleable product, all of which would continue to be transported by road.

According to the Environmental Assessment compiled by Olsen Environmental Consulting Pty Ltd, "table 2.7.2 in Section 2.7.2.5 contains predictions of cumulative saleable product from the modified Project. To date, 0.9mt of saleable product has been quarried by Gunlake . It is predicted that by the end of the proposed modified project this figure will have risen to approximately 19.25mt. This is an increase from approximately 13.75mt predicted in the original EA."

Based on the figures predicted in the statement above, it does not seem feasible that an increase of less than 50% (i.e. 5.5mt) over a period of 30 years (i.e. approx 250,000 tonnes per year) requires an increased footprint of 97%, (i.e. 5.8ha additional to the approved 6.0ha). Modification 2 is extremely premature as the Gunlake Quarry project has only completed 1/6th of its approved 30 year quarry life. Should approval of this application be granted, we are extremely concerned about the cumulative impact Gunlake Quarry and Holcim Johnniefelds and Holcim Lynwood quarries will have on the Marulan community, in particular those 16 or so nearby permanent and casual residences along the Brayton Road haulage route between Gunlake and the bypass road.

Mr O'Neil has advised that in the future he intends to apply for a further expansion of his pit to the west of the Gunlake site. This would move operations closer to Chapman's Creek which meets up with Joarimin Creek 1km east, both of which are classified as Category 2 streams and part of the Sydney water catchment. Mr O'Neil gave no indication as to when or for how much this expansion would be applied for however we believe it is Mr O'Neil's intention to increase extraction to 2mt per year.

We are also extremely concerned about the cumulative impact all three quarries will have on the landscape and believe Marulan will be likened to that of the Queenstown Hills in Tasmania, "one of the most notorious industrially-degraded landscapes on earth". (State of the Environment Tasmania).

Community Consultation and Inadequate Environmental Assessment

As we would expect to be considered nearby residents and/or landowners living near the proposed quarry and by-pass road, we refute that adequate consultation and discussion has been undertaken, as we have not had any direct contact from the applicant or their representatives during the EA process.

Our property fronts Brayton Road with our residence located approx 100m from the road's edge. It is interesting to note that there is no mention of our residence in any of the EA volumes, despite being located equidistant, if not closer, to the proposed quarry site as
575 Brayton Road.

The EA grossly underestimates the amount of direct impact the proposed quarry operations will have on the Marulan community from noise, dust and traffic.

We reiterate that Gunlake Quarries' community consultation is incomplete, inadequate and incorrect. The EIS for Gunlake Quarries Project Modification 2 has once again failed to fully address the impact on the community, particularly those residences located along the haulage route.

After perusing the EIS currently on exhibition with the Department of Planning and Infrastructure, we noted that several objections raised by us in previous submissions had still not been addressed and we challenge the findings of these assessments.

We requested that the proponent, Mr Edward O'Neil, arranges for monitoring to be carried out at our property in relation to traffic, noise and vibration and air quality, as well as to have our drinking water analysed for pollutants. Mr O'Neil took 16 days to respond and, to date, has not committed to providing either the monitoring or analysis requested.

In addition to this, the distribution of `newsletter-drop' advice regarding the proposed expansion was somewhat limited, inasmuch as it only covered a 5km radius of the quarry which did not include the Marulan village. Mr O'Neil advised that the Marulan Chamber of Commerce was given a copy of the newsletter, which was, in his opinion, sufficient community consultation.

Many of the townspeople have school-aged children who are transported to and from the local school and high schools in Goulburn via the haulage route for over 7kms. It is quite possible and understandable that parents would be anxious about the significant increase in truck movements as a result of the proposed expansion to Gunlake quarry however may not have been given the opportunity to voice their concerns. In fact, a recent incident involving the school bus and a quarry truck was reported to Gunlake which proves that the wider community ought to have been made fully aware of the dangers to which the children travelling this route may be exposed.


Environmental Effects

¨ Noise

We consider the proposed operating hours, as well as the location and intensity of the proposed activity, to be potentially offensive and would intrude into our sleeping time and casual solitude.

Under the Mulwaree Shire Local Environment Plan (LEP) 1995 (as amended), our property is zoned 1(a) Rural. Other than the fuel stations located on or near the Hume Highway, there is no industry, commercial or otherwise, within a 4km radius from our residence, which operates 24 hours 7 days per week.

The closest industry to our residence, at a distance of approx 800m, is the Holcim Quarry at Johnniefelds. This industry operates between 6am and 6pm Monday to Friday and 6am to 1pm on Saturdays. All drilling, blasting, extraction, crushing, loading, haulage and maintenance works are carried out during these hours. Advice is provided when blasting is to occur and is specifically timed so as not to coincide with peak traffic periods, particularly when the school buses are travelling along Brayton Road. On the rare occasion when emergency maintenance is required, permission is sought from nearby residents to extend the operating hours for the duration of the works.
We believe that we are significantly affected by the noise truck movements on haulage routes, particularly on Brayton Road and the proposed by-pass road.
We believe that the affect from noise pollution during night loading and transportation would significantly increase during temperature inversions. Temperature inversions are created by the descent and associated warming of air in anti-cyclones occurring during early mornings and evenings, and can trap pollution originating in the near surface layers.

Marulan is located at latitude 34°43'00" at the inversion base near sub-tropical anti-cyclones and at an elevation of 640m. We believe the incidence of temperature inversions would far exceed the 30% of total night time inversions stated in the EA, not only during winter months but throughout the year and needs to be strongly considered when evaluating the likelihood of sleep disturbance through noise pollution.

It appears to be a deliberate omission on the part of the EA that no receiver tests were done at residences located on Brayton Road south of the proposed quarry, and that the only residences considered nearby were 529, 531 and 575 Brayton Road. This omission seriously downgrades the noise impact assessment and renders it obsolete. Rural residents along Brayton Road are significantly adversely affected by noise and do not have the benefit of comparing before and after noise levels.

The EA does not satisfactorily address the affect of cumulative noise impact from operation of Gunlake and Holcim Johnniefelds. Contrary to public belief, Holcim does not intend closing their Johnniefelds quarry at the end of their current lease, nor do they intend closing it once the approved Holcim Lynwood quarry is operational. Therefore, we would experience cumulative noise impact for some considerable period of time, most likely decades.


As noted earlier, a request has been put to Mr O'Neil for noise pollution and vibration to be monitored at our property, however to date he has not committed to providing either the monitoring or analysis requested. Due to the location of our residence, we experience noise from trucks braking, decelerating and accelerating at a dip in the road and narrow bridge (culvert) approx 20 metres distant. This is fundamentally dissimilar to traffic conditions along the haulage route at residences monitored by Pacific Environment Operations Pty Ltd for the Noise and Vibration component of the environmental assessment, where the road is longer and wider, with clearer vision and few bends.

We have been advised that a section of the haulage route is to be upgraded and widened to 11m in parts. We have also been advised that the culvert will be widened in accordance with Goulburn Mulwaree Council's Development Control Plan (DCP) - Provisions for Heavy Vehicle Generating Development. We believe that both upgrades ought to have been carried out prior to Stage 1 of Gunlake Quarries and that the project has been operating outside of Council's DCP since its commencement in 2009.

The proposed upgrade of the haulage route may address some safety issues however during deceleration, braking and acceleration, the noise from truck exhausts and compression brakes causes a significant increase in decibels.

In June 2014, we approached Holcim to make arrangements for noise and dust monitoring to be carried out on our property in order to gauge the level of pollution we are currently being exposed to from Johnniefelds Quarry (approx 750m to our north) and to provide a benchmark for us prior to commencement of operations at Lynwood Quarry (approx 2kms to our west), The attached noise chart (Attachment A) shows the results of the monitoring conducted between 16 and 29 June 2014. Coincidentally, this was only a couple of days either side to that carried out by Pacific Environment Operations Pty Ltd for the Gunlake Quarry Modification 2. We are not yet in receipt of a detailed report of the results however we have had verbal advice from a sound technician who attended our site that the extreme spikes in decibels would be attributed to heavy vehicle traffic.

Some mitigating measures could be put in place to lessen the noise pollution, such as lowering the speed limit and ensuring the road surface is well maintained however neither measure would alleviate the necessity for heavy vehicles to decelerate, brake and accelerate with multiple gear changes at various points along the Brayton Road haulage route.

According to the attached noise chart (Attachment A), at our residence (Location 1) the nighttime readings fall well below 30 decibels and the noise levels rise to over 70 decibels (an increase of over 40 decibels) once heavy vehicle traffic commences. This noise will be amplified by the tertiary crusher and other quarry machinery and equipment being used during its proposed 24 hour operations. The results of the attached noise chart dispute the findings of the EA that there will be no exceedance of noise limits expected.

Also, according to Table 4.2 - Attended Noise Measurement Results (page 11 of Pacific Environment Operations Pty Ltd noise assessment), on 3 July 2014 at locations R2 (Brayton Road) and R4, peaks from cars and trucks passbys reached 80db during both day and nighttime measurements.

In addition to the existing Brayton Road haulage route, background noise has increased significantly since construction of the bypass road, approx 3 kms to the east and south-east of our property. Traffic noise is clearly audible from the Hume Highway as it funnels through the cutting of the ridge and as a result of removal of vegetation for the entire length of the new road. This is particularly evident during summer months when the winds are most commonly from the east.

In May 2004, a report was prepared by the enHealth Council (Environmental Health) titled "The health effects of environmental noise - other than hearing loss". The report examined the range of environmental noise sources that may affect communities, with a focus on primary sources such as road, rail and air traffic and industry noise. The report examined the key literature on noise exposure and annoyance/quality of life, sleep disturbance, performance and learning, cardiovascular disease, mental health and stress. There is sufficient evidence internationally that community noise may pose a general public health risk.
Responsibility for environmental health is diluted across a range of national, state and local governments and has effectively lowered the perception of noise as a health problem.

The exposure to excessive noise by truck movements during nighttime transportation is likely to have long term health issues related to sleep disturbance and annoyance/quality of life to those located along the haulage route.

We put forward the above as supporting evidence that the noise impact assessment is incomplete, inadequate and inaccurate.

¨ Air Quality - Dust Pollution and Wind Erosion

The dust produced because of exposed surfaces, stockpiles, loading and transportation via access tracks and internal haulage routes has the potential to generate an unacceptable level of air pollution. Stockpiles of extracted overburden, topsoil from clearing the project site and during the construction of the by-pass road, as well as the overburden emplacement bund wall, all contributed to dust pollution.

Crystalline silica is a basic component of soil, sand and granite (amongst other minerals), which may become respirable sized particles when drilled or crushed and has been classified as a human lung carcinogen. Inhaling crystalline silica dust can cause silicosis, resulting in breathing difficulties, chest pain, respiratory failure and potentially death, as there is no known cure for silicosis. Although it has been stated within the EA that there are no known adverse health effects associated with non-occupational exposure to respirable crystalline silica, the following extract from a Senate Committees Inquiry into workplace exposure to toxic dust outlines the concerns of a community in a similar situation to that of the Marulan community.

"The Somersby Action Committee reported that due to extensive quarry activities on the Somersby Plateau NSW, residents experienced exposure to silica dust. Dust also effects schools and businesses in close proximity to quarries. There have been reports of the increased incidence of asthma and concerns that the community has been put at risk of silicosis. The Action Committee pointed to problems with policing sites to ensure that dust in (sic) minimised. Although fines have been imposed, these are considered to be too low to act as a deterrent. As there are proposals to expand quarries in the area, the Action Committee called for greater protection of populations living near quarries, more regular inspection of work sites, and independent environmental impact statements".
(Parliament of Australia:Senate:Committees:Inquiry into Workplace exposure to toxic dust. May 2006)

Poor air quality during periods of low wind speeds and under an inversion can persist for days and could lead to respiratory illnesses such as asthma and silicosis. Being located SE of the proposed project site, we would be in direct line of the prevailing NW winds. Clearing to develop and operate the proposed site would further expose us to these often high velocity (gale force) winds, increasing the potential for wind damage to our property.

Additional information gathered in relation to these prevailing winds is that they bring Aeolian sand deposits, (Bruce Frazer, Matrix Planning, Statement of Evidence, Maywood Sands vs Mulwaree Shire Council, July 1996). We are concerned that we have been further subjected to airborne sand and contaminated dust deposits due to wind erosion as a result of clearing and Gunlake quarry operations.

Further, the EA does not address the affect of cumulative dust impact from operation of the Gunlake and Holcim Johnniefelds.

As noted earlier, a request has been put to Mr O'Neil for air quality to be monitored at our property, however to date he has not committed to providing either the monitoring or analysis requested.

Gunlake's extraction pit will expand to approx 1.8kms NW of our property. We have already experienced dust emissions from Gunlake's operations and bunds and are concerned that we will be further exposed to fugitive dust during any future construction and operations. Large plumes of dust can often be seen emanating from Gunlake Quarry, as in the attached photograph, (Attachment C), which indicates that appropriate measures are not being taken to contain dust emissions. These plumes of dust can be seen in the satellite image on "Google Earth Maps" which connect with those occasioning from Holcim Johnniefelds. The plumes can be seen to drift over our residence and property and as far as Red Hills Road approx 3 kms to the east where some 30 or so rural residential properties are located.

Contrary to paragraph 5.3.3.2 - Meteorological Analysis, (page 88 of the EA prepared by Olsen Environmental Consulting Pty Ltd), the prevailing winds in the Marulan area are from the west, north and north west for the majority of the year. During these times, the wind will deposit dust to properties south and east of Gunlake however, during the summer months, the easterly wind will deposit dust to the west of the pit where several feeder creeks for the Sydney Water Catchment are located. The potential for contamination and silt build up as a result of these dust deposits is highly likely.

The Meteorological Analysis mentioned above also uses information monitored by the NSW EPA at sites 70-80kms from Gunlake as well as data collected at Holcim Lynwood quarry which is not operational as yet, both of which have no bearing on the results of operations at Gunlake.

The Meteorological Analysis also compares monitoring data from the Hunter region, claiming the ratio of long term total suspended particulate matter (TSP) is likely to be similar in the Marulan area.

In a 2012 report "Health and Social Harms of Coal Mining in Local Communities: Spotlight on the Hunter Region" prepared by The University of Sydney, "evidence from international literature indicates that coal mining communities are at an increased risk of developing cardiopulmonary (heart/lung) disease, chronic obstructive pulmonary disease (COPD), other lung diseases, cancer, hypertension (high blood pressure), and kidney disease. Mortality rates for these diseases were higher in communites living in proximity to coal mines and coal fired power stations".

More research similar to that of coal mining is needed to look into the potential for health harms from the quarrying industry. Although no previous research studies have confirmed the existence of dust diseases clusters, anecdotal evidence suggests there is a higher rate of mortality for some health problems in the Hunter region compared to the rest of NSW.

At the same time as noise monitoring was carried out on our property, Holcim also made arrangements for dust tracking. The attached graph (Attachment B) shows the results of data collected at locations 550m and 750m respectively from our northern boundary with Holcim Johnniefelds. Although the results appear to be within accepted guidelines, had data been collected at our boundary, the results may not have been as favourable,

Our outbuildings and residence are located approx 63m and 89m respectively from the Brayton Road haulage route. We are concerned that unwashed vehicles, in particular wheels, and perforated tarps allow fine particles of dust to escape during transportation. As Gunlake has approval for truck movements of 100 (max 150/day) northbound and 25 (max 38/day) southbound, they are clearly the main pollutant in respect of transportation. Together with diesel fuel particulate matter from both off-road and on-road vehicles, we have grave concerns surrounding the cumulative effect of dust and diesel emissions and the health issues attributed to both.
Emissions from diesel engines are a mix of gaseous compounds and particulate matter. Gaseous compounds include carbon dioxide, water vapour, oxygen, sulphur and nitrogen compounds, carbon monoxide, and low molecular weight hydrocarbons and their derivatives. Particulate matter can contain elemental carbon, organic compounds (including Polycyclic aromatic hydrocarbons, a number of which are known or suspected carcinogens (cancer causing substances)), metals, and other trace compounds. These particles are a public health concern due to their small size (Particulate Matter of ~10 micrometers or less [PM10]) which makes them easy to inhale and able to reach the deep lung. (Cancer Council NSW).
As can be seen in Figure B Project Site Layout, the expansion of the pit would require more clearing of vegetation and removal of topsoil with the modified overburden footprint being extensive. Photographs 1 and 2 show that rehabilitation of the bunds has been minimal with little or no planting being carried out over the past 5 years of quarry operations. This shows a distinct lack of responsibility by Gunlake to revegetate the site and the exposed bunds are a substantial source of fugitive dust.
We put forward the above as supporting evidence that the air quality impact assessment is incomplete, inadequate and inaccurate.

¨ Traffic

The applicant proposes that 80% or more of the crushed product will be hauled by road from the quarry site direct to Sydney and other markets to the north of Marulan, and that rail is not a viable option due to the "just-in-time" demand for supply of materials to concrete plants.

The Holcim Regional Distribution Centre (RDC) at Rooty Hill in the Blacktown area will be a receival, blending and distribution centre for construction materials catering for the Sydney market. Construction material will be transported by rail directly to the RDC and distributed to customers via the M7 motorway. The centre will be operational 24 hrs 7 days a week to suit both train movements and customer requirements, including the "just-in-time" demand on concrete plants.

Gunlake was granted approval for truck movements of 100 (max 150/day) northbound and 25 (max 38/day) southbound, which is potentially 188 truck movements in each direction per day, i.e. 376 laden and unladen trucks.

Holcim Johnniefelds transports product via road at a rate of between 60 and 80 trucks movements per day, i.e. potentially 160 laden and unladen trucks.

The cumulative impact of potentially 536 trucks over a 12 hour period equates to 44.6 per hour or 1 truck every 1.3 mins. However, as Gunlake has approval to transport over a 24 hour period, the number of trucks from Gunlake operations equates to 1 every 3.83 mins, as well as an additional 1 truck every 4.5 mins during Holcim Johnniefelds daytime operations.

"..the state of road repair can be a predominant factor in the level of traffic noise experienced; poor road surfaces cause uneven traffic flow, with consequent noise from braking, acceleration and vibration from trucks and their loads". (Paul Wearne, EPA Officer, Statement in the matter of Maywood Sands vs Mulwaree Shire Council).

At the Goulburn Mulwaree Council meeting held 20 November 2012, it was resolved that Gunlake contribute a $0.0313 per tonne per kilometre levy to the ongoing road maintenance program. Aside from any separate upgrades of Brayton Road to which Gunlake is expected to make a one-off contribution, the levy is minimal when compared to the actual costs involved in the upkeep of the haulage route. It is widely accepted by Council that levies for ongoing road maintenance is inequable compared to the damage caused and the substantial shortfall for repairs is normally met by ratepayers.

Additional Environmental Effects

¨ Drinking Water Catchments

There are two creek systems in the main quarry area, one of which being Chapman's Creek, is classified as a Category 2 stream. Chapman's Creek flows east and meets up with Jaorimin Creek, (also classified as a Category 2 stream) approx 1km downstream. Eventually both join the Wollondilly River and ultimately flow into the Warragamba Dam, thereby forming part of the Sydney drinking water catchment.

We are not confident that silt stop fencing, or similar, placed immediately downslope of stockpiles will be sufficient to prevent silt detention in times of heavy rainfall. The EA mentions 1 in 100 year storm flow, yet fails to mention the impact of a 1 in 40 storm event. The possibility of damage to silt detention constructions is ever present and it is to be noted that any lapse in preventative measures resulting in a failure to detain silt would impact on the quality of Sydney's drinking water. The construction of haul and access roads will also impact on the upper catchments of the Wollondilly River.

The roofs of our three outbuildings and house are our sole source of water supply as there is no town water available. These roofs are located 63m, 68m. 71 and 89m distant from the haulage route and are extremely vunerable to dust and diesel pollution, particularly during long, dry spells and drought. The increase in heavy vehicle traffic since commencement of Gunlake operations has seen it necessary for us to filter our drinking water due to the obvious change in taste and odour. It is expected that traffic generation as a result of any expansion of the Gunlake quarry will have a significant effect on the quality of the drinking water of those residences along the haulage dependent on rainwater catchment.

As noted earlier, a request has been put to Mr O'Neil for our drinking water to be analysed for pollutants, however to date he has not committed to providing either the monitoring or analysis requested.

¨ Flora and Fauna

The proposal involves the clearing of vegetation which has the potential to impact on threatened species, populations and ecological communities and their habitats.

The habitat of five threatened species, i.e. the squirrel glider, speckled warbler, eastern bent-wing bat, eastern firetail bat and eastern false pipistrelle, has been identified as being within the local area.

In addition to these threatened species, the proposed quarry site is home to large communities of kangaroos and wallabies, wombats, echidna, marsupial mice, to name but a few. The site is also home to numerous species of native birds, including the endangered Regent Honeyeater.

Native wildlife is in abundance in this area largely due to the close proximity of wildlife refuges such as "Shepherd's Gully" to the south of the proposed development, (Ref Wingello topographic map 8928-IV-S) and "Johnniefelds" to the south-east (Ref Towrang topographic map 8828-I-S).

"Johnniefelds" is made up of native woodland, large sweeping garden, and wetlands including a 30 hectare lake supporting a wide diversity of bird species. In September/October 1996, 77 species of birds were identified on the property, including all three species of grebe found in Australia, i.e. Great Crested, Australasian and Hoary-headed, as well as Blue-billed ducks. (Michael Coley,Caxton House, Gunning, NSW, October 1996).

Jaorimin Creek flows into this 30 hectare lake and any run-off of nutrients, contaminants and other pollutants into this waterway could have a significant impact on this birdlife.

We believe it will be in excess of 30 years after planting native trees to replace those removed during construction and operation of the quarry before there will be any real benefit to the environment. We have allowed trees which were cleared by the previous owner to regenerate on our property, however, in the space of 27 years, none have reached their mature height as yet.

The fact cannot be dismissed that habitats of native wildlife will be destroyed during construction and operation of the quarry. It is our opinion that the proposal contravenes the Mulwaree Shire LEP 1995 (a) vii - promoting, enhancing and conserving localities of significance for nature conservation, including localities with rare plants, wetlands, permanent watercourses and significant wildlife habitat.


There has been a significant increase in wildlife mortality as a result of the high volume of heavy vehicle traffic since commencement of Gunlake operations. There have been numerous occasions where it has been necessary to euthanise native animals that have been left dying and injured by the side of the road, sometimes for several days before being found.
Historic background information
In 1995, Bill Lacey t/a Maywood Sands appealed to the Land and Environment Court of NSW against (then) Mulwaree Shire Council's refusal of his application to develop an extractive industry. This development involved extraction of sand and gravel deposits on land known as portions 214 and 215 of the Parish of Uringalla, and Lot 2 of DP 589965, situated approx 6 kms north-west of the village of Marulan. The extraction activities were principally confined to Portion 214, and Mulwaree Shire Council refused the development application on the following grounds:-

1. The adverse impact of the development on the existing and likely future amenities of the village of Marulan and the eastern section of the Marulan Brayton Road;
2. The conflicting relationship between the proposed development and the development on other lands in the locality; and
3. The public interest.

On 12 July 1996, Justice Bignold of the Land and Environment Court of New South Wales handed down his judgement on hearing 10956 of 1995, between parties Bill Lacey t/a Maywood Sands and Mulwaree Shire Council, dismissing the appeal and upholding that development consent be refused. Gunlake Quarry's site and quarrying-related activities are approximately 500m distance from the north-western boundary of the abovementioned Portion 214.

The following paragraphs have been extracted from the transcript of Justice Bignold's findings:-

"In particular, I find the proposal would involve a significantly adverse environmental impact, especially in terms of noise (both operational and transportation), on a significant section of the Marulan community, namely those eight or so residents living on rural properties fronting Brayton Road, in close proximity to the appeal site, and the greater number of residents on that same road in the village of Marulan.

In large measure, the Applicant's case has relied upon pre-existing conditions in the Marulan district, most particularly upon the existence on the opposite side of Brayton Road, in close proximity to the appeal site of the CSR Readymix (now Holcim) Hard Rock Quarry........

I, of course, accept that the existence of those two developments has a significant effect upon the amenity of the immediate locality on the outskirts of the Marulan village and upon the village itself, because Brayton Road is the only available route for the haulage of the extracted materials. However, I am not satisfied on the evidence that the likely environmental impacts of the proposed development will be effectively masked, or somehow accommodated within the prevailing environmental impacts of those activities, and more especially the CSR Readymix Hard Rock Quarry.

On the contrary, .......evidence in the case of noise impacts of the proposal (both operational and transportation wise), which evidence I unreservedly accept, demonstrates that the likely adverse noise impacts of the proposed development additional to the impacts of those existing extractive developments is likely to be significant."

The number of residents affected along the haulage route between Gunlake Quarry, Holcim Johnniefelds and the bypass road has increased slightly since Justice Bignold's decision and has the potential to increase further should nearby residential plots be developed.

It has always been our opinion that the findings of Justice Bignold should apply to the Gunlake Quarry proposal and be taken into account when assessments are being undertaken by the NSW Department of Planning and Infrastructure.

Conclusion

We believe the Major Project Application (07_0074) Gunlake Quarry - Modification 2 - Expansion of Pit - should be rejected and Modification 3 - Truck Movements be revoked by the NSW Department of Planning and Infrastructure on the basis of the following points, as detailed above:

· Noise;
· Air quality - Dust pollution;
· Traffic;
· Drinking water catchment; and
· Health






























ATTACHMENT A














ATTACHMENT B













ATTACHMENT C

See attachment.

I have uploaded our submission in PDF format

The proposed expansion of Gunlake quarry will cause unacceptable and unfunded damage to local roads, will cause unacceptable safety and risk for road users and will have a huge impact on the quality of life for the rural and residential areas that surround the quarry by way of increased noise dust and light impacts.
The proposed expansion should be rejected.