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SSD Modifications

Determination

Mod 3 - Transport

Narrabri Shire

Current Status: Determination

Interact with the stages for their names

  1. SEARs
  2. Prepare Mod Report
  3. Exhibition
  4. Collate Submissions
  5. Assessment
  6. Recommendation
  7. Determination

Attachments & Resources

Application (1)

Response to Submissions (1)

Recommendation (1)

Determination (2)

Submissions

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Showing 1 - 12 of 12 submissions
Name Withheld
Object
Boggabri , New South Wales
Message
I disagree with extra mining associated traffic along main roads as this will cause an increase in motor vehicle accidents causing both injury and unnecessary death. Miners work long and tiring hours, twelve hour shifts plus traveling sometimes over an hour both ways; their families need the assurance that they will be safe whilst traveling. With all workers traveling in buses there is less stress on the roads and less chance of accidents, coaches would be better than smaller buses. I counted 57 vehicles parked in gunnedah at the pickup points one afternoon and would assume most of these would make the trip if they were allowed.This is only one mine not yet operating to full capacity ,and there is three other mines already with considerable traffic attending.
Name Withheld
Object
Boggabri , New South Wales
Message
I would appreciate Maules Creek Coal taking up the optional agreement offered by Boggabri Coal to use the intersection off the Kamilaroi Highway onto the existing haulroad to reduce the huge number of cars, trucks and B-Doubles that travel on the Therribri Road to their mine site every day and night.
I would also appreciate it if Maules Creek Coal could recommend to the RMS that the speed limit on the Therribri Road be reduced from 100 km to 80 kms .This would help to reduce the road noise that I have to tolerate.
Name Withheld
Object
Boggabri , New South Wales
Message
I request that Maules Creek Coal take up the optional agreement offered by Boggabri Coal to use the intersection off the Kamilaroi Highway onto the existing haul road to reduce the huge number of cars, trucks and B-Doubles that travel on the Therribri Road every day and night to their mine site.
I would also like Maules Creek Coal to recommend to the RMS that the speed limit on the Therribri Road be reduced to 80 kms from 100 kms. This would help to reduce the road noise that I currently have to try to live with.
Sally Hunter
Object
Boggabri , New South Wales
Message
Employee Transportation Modification 3 EIS
5th July, 2016

We object to the Modification of the Condition 63 of the Employee Transport.

My husband and I and our three sons live within the neighbourhood of the Maules Creek mine, close the junction of Maules creek and the Namoi River on the Harparary Rd. We have a small farming and livestock business and seek to produce as much of our own food requirements as possible.

The following are the key points addressed in this submission:
* Inconsistencies in the claims of locally based staff
* Questioning the location of shuttle bus pickup points
* The total lack of addressing the health and safety issues of increased traffic
* The increase in the maintenance needs of roads from increased traffic
* The restriction created by the Iron Bridge will create impacts from increased traffic
* The increased prevalence of road kill created by increased traffic
* The increases wildlife road kill that will occur by increased traffic on the Mine Access Road that dissects the Biodiversity Offset area
* The current and recurring traffic breaches by MCCM
* The weak wording proposed by the Modification

These points all demonstrate that this proposed Modification will increase traffic on surrounding roads which will create increased impacts in a variety of ways. They will also show that the new Modified Condition is completely unsuitable to meet the needs of the community and to follow the initial integrity of the PAC and DG's Requirements.

Localised Staff
According to the Maules Creek Coal Mine Employee Transport Modification Environmental Assessment (EA) the reasoning for the Modification states that the original EA was based on an assumption that "a high proportion of employees would travel to and from the area and live in temporary accommodation" thus facilitating the convenient use of the shuttle bus by 90% of staff. And now, MCC claims to have a high percentage of locally living employees who would prefer to drive in individual vehicles than catch the bus.

Right from the start of production MCC was quick to use their level of local employment to increase their social licence, and yet we now see that used as the justification for this Modification to the original Conditions. It is counter-intuitive to now state that, having achieved the local employment first desired that the initial transportation plan should be changed.
It should be noted the original EA assumed 470 full time employees in 2020 (including contractors, maintenance staff, coal handling etc), which continues to be the assumption.
Did the MCCM never intend to fulfil the assumptions that they used in their original EA? Or are they changing the story to suit the audience?


Shuttle Bus Stop Locations
Currently locally based staff meet the shuttle bus at predetermined locations. If these locations are not convenient for some staff due to where they live, the locations should be reviewed, not the Conditions of the Approval. Given all shifts start and end together, the use of shuttle buses at particular times makes sense.

Health and Safety
The original intention of the Conditions placed on the project following the Director General's Requirements (DGR's) was for safety for surrounding families and businesses. These safety concerns, originally bought up in community submissions to the Planning and Assessment Commission (PAC) still apply. We find it critical that the original intentions of the community, the DGRs and the PAC are maintained.
Recently parts of the Harparary Rd have been bitumened and the new bridge has been installed over the Namoi River. The modification of Condition 63 cannot be considered in isolation from these changes in local surrounding roads. The cumulative effect of improved road conditions on Harparary Rd and a decreased use of the employee shuttle bus will created significantly increased traffic on Harparay Rd, disproportionately to the simple 20% reduction in the use of the shuttle bus.

Our farm straddles Harparary Rd requiring us to frequently transport farm machinery and livestock from one side of the road to the other, traversing the road. Increased traffic on the road will increase the health and safety risk for us, our employees and our animals as well as our children.

In particular, as noted in the FIFO Inquiry, mine staff who have completed a 12 hour shift, offer significant risk to other road users due to driver fatigue. MCC currently have a number of staff, management and contractors based in Gunnedah, exposing Kamilaroi Highway users and Boggabri town road users to fatigued workers. There have already been at least two crashes at intersections in Boggabri, believed to have been caused by tired workers.

This Modification in no way addresses the increased safety risk of increasing the prevalence of fatigued drivers on local roads and on this basis should be rejected.

Increased Road Burden
An increase in the number of traffic movements on surrounding rural roads, many of which are gravel, will increase the road maintenance burden to Narrabri Shire Council with no compensation considered for this.

Iron Bridge Restriction
Access along Rangari Road is restricted by the Iron Bridge which is a "Give Way". An increase in traffic on this road at peak times will have an impact on the capacity of the road due to this bottle neck.


Road Kill
As a close neighbour to the Maules Creek mine I have noticed in the last six months, since the deforestation of the Leard's Forest, an increase in the road kill on Harparary Rd just outside my farm. It is reasonable to expect the destruction of a vast tract of habitat that such migration is occurring. In particular, I feel grievous about the deaths of at least half a dozen owls on the road outside my home in the last six months, and this is just a small section of road.

Dissection of Biodiversity Offset
The Mine Access road dissects the biodiversity offset area that is designed to keep safe, what wildlife still exists. By increasing the levels of road traffic (caused by reduced use of the shuttle bus) there will be an increase in the road kill of wildlife along this road. Particularly when taken into account the peak traffic times being around sunrise and sunset, when wildlife are usually on the move.

Current Breach of Condition
The GTA Consultant's report provided in the EA for the Modification on page 7 states "This Modification proposes amendment of Condition 63, Schedule 3, to reflect the traffic management practicalities and practices currently in place".
Mining Approval Conditions should not work like this - MCCM should follow the Conditions placed on them until they are approved a Modification. Modifications must not be justified by the current breaches occurring.

The Gate Survey results in Table 3.5 on page 11 clearly states that of the 1,874 operational workers travelling to the MCCM, 680 used the shuttle bus in June 2015. Therefore, 36.28% of operational staff is using the shuttle bus. This is a blatant breach of Condition 63 where 90% of employees should be using the bus. This breach has been noted as a formal complaint to the Department of Planning.

This Modification is a clear attempt to make the mine's Conditions to match the breaches already occurring.

Proposed Wording Changes
Condition 63 currently states clearly "90% of operational workers... would be transported by shuttle bus". It is proposed to drastically weaken this wording to "MCC will target that 70% (averaged over a week) of the operations, maintenance and CHPP wages employees would utilise the bussing service".
Firstly this weakened version fails to mention contractors. It is our position that contractors must be included in the Condition and subject to the same % use of the shuttle bus. Facilities are available for contractors to lock up their tools and vehicles on-site when attending MCCM for more than one day in a row, so they should utilise the bus.

Secondly, the weasel word of "target" does not place appropriate emphasis on MCCM. "averaged over a week" further weakens the condition.

Given Whitehaven's past indiscretions with regards to traffic movements, including the breach in 2015, this is clearly an aspect of the business that must be given close and careful consideration by the Department before modifying any conditions.

We implore you to consider the neighbourhood-wide social, environmental and health impacts of this Modification and reject it.

Jacqui McInerney
Comment
Boggabri , New South Wales
Message
See attached PDF file
Attachments
Narrabri Shire Council
Support
Narrabri , New South Wales
Message
See uploaded correspondence
Attachments
Maules Creek CWA
Object
Maules Creek , New South Wales
Message
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Attachments
Maules Creek Coal CCC
Object
Armidale , New South Wales
Message
Objection to WHC modification of Condition 63 Schedule 3 prepared by Maules Creek Coal Community Consultative Committee Environmental Representative (Dr Kerri Clarke) and alternate (Ms Anna Christie) - Sustainable Living Armidale
Attachments
Gunnedah Shire Council
Comment
Gunnedah , New South Wales
Message
See Attached
Attachments
Peter Watson
Object
Maules Creek , New South Wales
Message
See Attached
Attachments
Wando Conservation and Cultural Centre
Object
Maules Creek , New South Wales
Message
See Attached
Attachments
Roads and Maritime Service
Object
Sydney , New South Wales
Message
See Attached
Attachments

Pagination

Project Details

Application Number
MP10_0138-Mod-3
Main Project
MP10_0138
Assessment Type
SSD Modifications
Development Type
Coal Mining
Local Government Areas
Narrabri Shire
Decision
Approved
Determination Date
Decider
ED

Contact Planner

Name
Stephen Shoesmith