Mod 5 – Timing of Hazards Studies

Thank you for the opportunity to comment on the Modification 5 to the Syerston Mine application.

Council is supportive of the proposed modification to conditions 52 and 53 of the development consent to enable the construction of preliminary works.

This modification seeks to reduce the obligations currently imposed on the proponent in the existing DA in respect of hazard studies for the limestone quarry, the rail siding and the water pipeline. As a neighbour to this project, and a concerned community member, I make the following objections to the modifications now proposed:

1. The requested addition of the words "unless otherwise agreed by the Secretary" to clauses 52 and 53 of Schedule 3 of the DA implies that the proponent will have the option to seek to make a closed-door deal with the DoP towards the objective of not having to commission any hazard studies at all for this project. This proposal does not engender public confidence in the transparency of the planning process and nor does it say much for the proponent's concern for the neighbouring properties to this development. It should, in my submission, be rejected.

2. The proponent seeks, in the substantive parts of the modification application, to reduce it's obligations in respect of the hazard studies it must undertake before any development works can commence. However to allow this request would, in my submission, encourage the proponent to put the community at risk by not investigating the potential hazards associated with each aspect of the development.

An analysis of the likely hazards associated with each separate component of the proposed development (other than the main processing plant) was outside the scope and objectives of the Preliminary Hazard Assessment (PHA) undertaken by SHE Pacific Pty Ltd dated 15 September 2000. The Objectives and Scope (section 1.1) and Study Methodology (section 1.2) clearly states that the focus of the report was on the "proposed nickel and cobalt extraction plant", and not on the broader aspects of the development proposal as a whole. This focus is clearly borne out in the report that follows. In that report, there is scant mention of the limestone quarry, rail siding and pipelines on pages 26 and 27 and certainly no discussion of the potential hazards associated with those aspects of the project.

The DA currently requires the proponent to undertake the studies listed in conditions 52 and 53 prior to carrying out any further development. In my submission, this requirement represents a deliberate recognition on behalf of the planning authority that no appropriate hazard studies have been undertaken at all in respect of some aspects of the development.

It's an old saying that "you don't know what you don't know". In relation to this proposed development, not knowing the hazards associated with each aspect of this development could be disastrous for the local community.

Thank you for considering my submission.

I object to Clean Teq seeking to have the Hazard Analysis obligations limited to the mine site only

Truck and train transport, pipelines and power poles all present significant risks to the community during construction and operation phase and should be included in the hazard analysis as per the current approvals.

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