Mod 5 - Design Changes

As the shooting population increases suitable venues are needed and, current ones require updating for the sport to continue in a safe environment.

I support the Southern Highlands Regional Shooting Complex at Hill Top.
This facility will be greatly appreciated by the sports shooting community of the Illawarra, Southern Highlands and Western Sydney areas.
In fact, I believe this state of the art facility will be utilised by a large number of interstate competitors also.
Features such as disabled access, engineered sound mitigation measures and extended trading hours, will make this facility welcoming for all.

I am concerned about the increased impact of traffic brought in by the firing range as useage increases to full operating levels. Currently we have a single entry road (Wilson drive) that is already impacted by traffic and weather, with potholes and raised areas. There is no safe space for cyclists and walkers to negotiate this road, particularly with increased traffic. In addition, the bridge entry to Hill Top is the only way to cross into the village by pedestrians, without having to walk down further and cross the railway line (where I regularly see snakes). No one is taking responsibility for the needed repairs to the bridge wall, or the need for widening the bridge to allow for foot traffic. The safety of children and the elderly will be compromised as use of the road increases. There will be further impact on the roads into the shooting complex, and currently it seems that the council, not the owners and users of the shooting complex, will be responsible for road maintenance. Hill Top is a tiny, rural village, I live here because it's a peaceful safe space. Allowing an increase in use of the shooting range will not bring money into the area, but it will decrease safety, decrease the peace and quiet. I will no longer be interested in taking walks in the parks near the range on the weekends. I urge you to reconsider allowing the expansion of the shooting complex and the increase of noise limits in this quiet, rural village.

I opposed any change to the noise limit from ab absolute limit of 75dbl for the use of any range of the complex on any day.
My family and property value are severely and adversely impacted by the use of the ranges and we refuse to be further disadvantaged by a lessening of the only noise control that has been afforded us.
Obviously the result of allowing averaging permits louder noise !! THIS IS NOT ACCEPTABLE TO US.
It PERMITS FOR EXAMPLE shooing NOISE at 100dbL for half an hour and then 50db for half an hour and just call it 75~!~!! ABSOLUTELY outrageous!! Unacceptable and unfair.
According to the EPA guideline, if we have to put up with noise at our home of 100dbl the complex isn't even permitted to operate!!.
Any increase in permissible noise levels at residences can be averaged down to 75 and will result in an even higher level of noise at the national parks than that measured to date which makes the surrounds entirely dangerous for all other stakeholders. The shooters have to wear ear protection what about protection for other stakeholders?
If a new method of assessment relating to averaging of noise for this new development is to be adopted, despite applications for such a change failing many times previously when considered by all stakeholders and government appointed officers and independent experts, then they also need to provide noise attenuation measures at our home to allow a respectful amenity for residents having regard to ambient conditions and our ability to enjoy the outdoors of our own property .
NO community consultation with us was offered or undertaken when the EPA guideline was written despite the EPAs absolute knowledge of the request by local resident group HTRAGI to be consulted due to the key role residents play in this saga and the adverse impact hoist upon them. Clearly there was obviously a vested interest based on political imperatives which implies bias and corruption of due process and natural justice.

In the interests of transparency and equity and in light of the obvious pecuniary interest of the Department of Sports Noise Consultant related to literally dozens of consultancies for other shooting clubs in relation to noise reporting:

The Department of Sport should be required to engage a noise consultant TO BE APPOINTED in consultant with the Department of Planning and the Hill Top Resident Action Group so as to afford all parties equity and to provide a transparent process which is accountable to the community stakeholders as well as the proponent. There is no reason for the Department of Planning as compliance authority to not instruct such action
Such action would reassure the community that the Department of Planning are not complicit with the Department of Sport in servicing only the needs of the Shooters and are affording all stakeholders equity in the process. THE EPA should be the Noise Consultant on all occasion into the future.
This Range licence has been renewed with amendments regularly up to 2010 and undoubtedly will have been since - the Department of Planning should investigate with the Police Department - NSW Firearms Registry what further changes since 2010 have been approved and ensure only the approved guns with the most noise impact were and have been tested in controlled circumstances to date, before this application is even considered!! Such current noise testing to be witnessed by the HTRAGI representatives and gun expert as has previously been afforded and agreed by the Minister for Sport. The range didn't' come into use till 1986 actually and obviously numerous changes have been made since that time that have escalated the use to be considered "future range" under the guideline which was first established in 1986. The "guideline today is an update of that original guidelines" only which has always considered the status of the 800m range to be "future range" when it is considered in any way under the current development consent and obviously as it is still undergoing major works in relation to the consent. No "new legislation" is being attempted to be applied here that changes that "future range" status as if it existed before the new legislation!! - by implementing the EPA guideline - the only thing in the guideline that is proposed to be newly applied is "averaging". That guideline proposal has been attempted previously under Chapter 164.
In 2007 and 2010 significant changes were made that increased noise that can emanate from the 800m range and which to date has not even occurred to its full extent - as clearly the escalation of use from 1000 shooters pa on that range to what is now approved 4200 shooters per annum (according to DoS consent) has not even occurred yet.
Any consideration in this application for any range on the complex, of the noise limit, is premature and non evidence based.

The 75dbl limit must apply to the whole complex restricting all use to 4 concurrent days per week (no nights) and including any army use.

There is no way to differentiate what range is emitting noise from the resident perspective nor to replicate or monitor any breach of noise over time after the fact if averaging is implemented.

One absolute noise limit for the whole complex is the only workable solution a has been confirmed time and again by all independent experts for compliance monitoring and approval authorities over the lasts 10 years for this development.

If the Department of Sport truly can say they will be less noisy then why are they applying to increase the noise permissible!!!!????

I opposed any change to the noise limit from ab absolute limit of 75dbl for the use of any range of the complex on any day.
My family and property value are severely and adversely impacted by the use of the ranges and we refuse to be further disadvantaged by a lessening of the only noise control that has been afforded us.
Obviously the result of allowing averaging permits louder noise !! THIS IS NOT ACCEPTABLE TO US.
It PERMITS FOR EXAMPLE shooing NOISE at 100dbL for half an hour and then 50db for half an hour and just call it 75~!~!! ABSOLUTELY outrageous!! Unacceptable and unfair.
According to the EPA guideline, if we have to put up with noise at our home of 100dbl the complex isn't even permitted to operate!!.
Any increase in permissible noise levels at residences can be averaged down to 75 and will result in an even higher level of noise at the national parks than that measured to date which makes the surrounds entirely dangerous for all other stakeholders. The shooters have to wear ear protection what about protection for other stakeholders?
If a new method of assessment relating to averaging of noise for this new development is to be adopted, despite applications for such a change failing many times previously when considered by all stakeholders and government appointed officers and independent experts, then they also need to provide noise attenuation measures at our home to allow a respectful amenity for residents having regard to ambient conditions and our ability to enjoy the outdoors of our own property .
NO community consultation with us was offered or undertaken when the EPA guideline was written despite the EPAs absolute knowledge of the request by local resident group HTRAGI to be consulted due to the key role residents play in this saga and the adverse impact hoist upon them. Clearly there was obviously a vested interest based on political imperatives which implies bias and corruption of due process and natural justice.

In the interests of transparency and equity and in light of the obvious pecuniary interest of the Department of Sports Noise Consultant related to literally dozens of consultancies for other shooting clubs in relation to noise reporting:

The Department of Sport should be required to engage a noise consultant TO BE APPOINTED in consultant with the Department of Planning and the Hill Top Resident Action Group so as to afford all parties equity and to provide a transparent process which is accountable to the community stakeholders as well as the proponent. There is no reason for the Department of Planning as compliance authority to not instruct such action
Such action would reassure the community that the Department of Planning are not complicit with the Department of Sport in servicing only the needs of the Shooters and are affording all stakeholders equity in the process. THE EPA should be the Noise Consultant on all occasion into the future.
This Range licence has been renewed with amendments regularly up to 2010 and undoubtedly will have been since - the Department of Planning should investigate with the Police Department - NSW Firearms Registry what further changes since 2010 have been approved and ensure only the approved guns with the most noise impact were and have been tested in controlled circumstances to date, before this application is even considered!! Such current noise testing to be witnessed by the HTRAGI representatives and gun expert as has previously been afforded and agreed by the Minister for Sport. The range didn't' come into use till 1986 actually and obviously numerous changes have been made since that time that have escalated the use to be considered "future range" under the guideline which was first established in 1986. The "guideline today is an update of that original guidelines" only which has always considered the status of the 800m range to be "future range" when it is considered in any way under the current development consent and obviously as it is still undergoing major works in relation to the consent. No "new legislation" is being attempted to be applied here that changes that "future range" status as if it existed before the new legislation!! - by implementing the EPA guideline - the only thing in the guideline that is proposed to be newly applied is "averaging". That guideline proposal has been attempted previously under Chapter 164.
In 2007 and 2010 significant changes were made that increased noise that can emanate from the 800m range and which to date has not even occurred to its full extent - as clearly the escalation of use from 1000 shooters pa on that range to what is now approved 4200 shooters per annum (according to DoS consent) has not even occurred yet.
Any consideration in this application for any range on the complex, of the noise limit, is premature and non evidence based.

The 75dbl limit must apply to the whole complex restricting all use to 4 concurrent days per week (no nights) and including any army use.

There is no way to differentiate what range is emitting noise from the resident perspective nor to replicate or monitor any breach of noise over time after the fact if averaging is implemented.

One absolute noise limit for the whole complex is the only workable solution a has been confirmed time and again by all independent experts for compliance monitoring and approval authorities over the lasts 10 years for this development.

If the Department of Sport truly can say they will be less noisy then why are they applying to increase the noise permissible!!!!????

I am against any changes to the shooting range. I live in Elizabeth Way Hill Top. I can hear the shooting range from my place. So any changes to the shooting range would make it louder. Sitting having a lovely BBQ last Saturday and you can hear the shooting range in the background. Any louder and it would have been very annoying. It would ruin our weekends, our leisure time. When the shooting range moved there is was supposed to be temporary and there was only half a dozen people using it. We couldn't hear it and it didn't impact on our lives. We moved to Hill top 30 years ago to get away from the noise. If we wanted to live with all the noise we could have stayed in Sydney.
The people who are using the shooting range do not live in the affected area. They travel to the range and cause a disruption to our lives and then go home. I understand that this might be their recreational activity but it has a direct impact on my recreational time and my life.
The shooting range is in a very bad spot anyway as it is in a very high fire danger area and in the middle of a lot of native animal's homes. At the moment I share my place with kangaroos, wombats and a lot of native birds. If the noise gets any louder or more traffic the animals will move on. Also a bigger shooting range means more traffic in Hill Top that our roads cannot take, they are bad enough as it is. There will be a further impact to the value of my property; nobody would want to live to live with that noise. The range is much too close to the village of Hill Top and surrounding small farms .I believe that the present noise is bad enough, so please protect this rural property from such a disturbance generated by rifle shooting.
it is totally unacceptable to think that the Department Of Planning would allow this to go ahead, that would have such negative impact and cause an intolerable situation year round to those of us that live in the area. I am not against shooting, just not in my backyard. Please protect our rural properties and our native animals from such a disturbance generated by rifle shooting.

I oppose any changes to the noise limit from the existing absolute limit of 75dB to averaging.

As one of the most affected residences in Hill Top, the change to averaging would obviously allow increased noise which would further impact on my family and that is unacceptable. Averaging would permit noise in excess of 100dB which goes against EPA guidelines. This is not the first application to change the method of assessment to averaging. It has been refused in the past and for very good reasons.
I understand that steps have been taken at the shooting range complex to reduce the noise perceived by residents by installing sound barriers and the like. We are now being assured that through noise testing with barriers in place, noise levels are now below the absolute limit of 75dB. So why request the change to averaging? If noise levels are below the current absolute maximum, it is unnecessary.
If consent is given to a new method of noise assessment then we should be provided with noise attenuation measures at our home to allow a respectful amenity and the ability to enjoy the outdoors at our property.

I also oppose any changes to existing hours of operation which would include night time shooting. We are already impacted by day time shooting noise for up to four days a week with an absolute maximum of 75dB. To further impact us by allowing shooting from 5pm - 10pm and with a lesser restriction on noise levels by averaging would be unthinkable. We all know how noise travels in the calm of the night and as a farm worker who has to rise at dawn, early nights are a must for me. Sleep disruption from gun noise would have an affect on my day to day working routine of operating machinery putting me and my co-workers at risk.

I would like to add that currently, noise testing is NOT being carried out in accordance to guidelines or consent where testing should be conducted within 30 metres of the most affected residence. An interim tests carried out in March 2016 were performed at location B2 which has given favourable results for the applicant. Location B2 has previously been identified by The Acoustic Group as giving lesser variation results in noise levels than those taken at location B2A. The reason for this being a ridge on the northern side of Starlight Place which provides a grazing incidence to location B2. Evidence of these results can be seen in the report from The Acoustic Group dated 10th July 2012.

B2A is our residence which is one of the worst affected by shooting noise. When approached, I have always given permission for testing to be carried out here. I wasn't contacted for permission for the interim March 2016 testing and was unaware that it has been carried out. Also, when annual testing first commenced, it was mid-year. There have been occasions where testing has been delayed due to adverse weather conditions. However, the last annual test carried out was 20th October 2015. This test was not delayed in any way but nevertheless is was 4 months overdue. It is now the end of January 2017 and as yet I have still not been approached regarding the annual testing for 2016. In effect, it is more than 6 month overdue and it is clear that consent has been breached.

I therefore ask, that to avoid any further breach of consent, the Department of Sport should be required to appoint the EPA as an independent noise consultant in conjunction with the Department of Planning and the Hill Top Residents' Action Group to perform any future annual or other testing. This would help to reassure the community that the Department of Sport is following correct procedure.

Finally, as the shooting complex is not yet fully operational, noise testing has never been carried out under the full effect of it's impact on residences. Single shots recorded from a flat bed truck are no comparison to what would actually be heard from all day shooting, night shooting, military shooting, all weekend state competition shooting (including public holidays) all with averaging of noise levels permitted. It would be totally unfair to the people of Hill Top for the Department of Planning to consent to this application in any form because of this. For that reason alone, this application should be rejected.

I object to the application for the following reasons:

I'm one of the closest residents to the shooting range and I'm already adversely impacted by the noise from it and so is the rest of my family. To change the method of noise measurement to averaging would only make it worse. Everyone knows that averaging allows for greater numbers and this is no exception. The lower the lesser number is, the higher the highest number can be. It's also obvious that current compliance of the 75dB limit can't be enforced by the applicant even with sound barriers otherwise why else would the change be needed?
No-one has heard the full impact from the range yet because full operational testing has never been done. What impact are the 4200 shooters per annum, that the Department of Sport say will use the range, going to have on us? Can the Department of Planning assure me that the simultaneous shooting that will occur at a State/regional competition, plus military use, plus night time shooting with noise limits eased to averaging, will not produce any more noise than the single shots that are fired during testing? What will it be like from a residents perspective? How can something like this be even considered for approval with such lack of evidence.

Operation of the complex should continue to have the current maximum level of 75bD applied to it plus the 4 days a week (without nights) for these reasons alone.

Please find attached my submission I will send it in two lots so as to ensure you get the main document prior to close of exhibition - attachments to follow

Dear Sir/Madam,

Please find attached a submission as an objection from the Colong Foundation for Wilderness Ltd.

As attached

Please find attached the documents that support my submission

Please see attachments