Mod 6 - Increased Extraction Area

In regards to the proposed expansion of the Dunmore Quarry, I and many other residents of the Southern Highlands commute to work daily on the South Coast via Macquarie Pass.
I like many other motorists who use this route are constantly being initmidated by the amount of large trucks who use this narrow winding road. This could not be more evident than on the top hairpin bend, where these trucks have to cross over to the other side of the road and jack knife their truck to get around the bend.
If you have the misfortune to meet one of these vehicles on this bend there is no room to get over to one side as it is a sheer drop to the forest below.
If this proposal is allowed to go ahead it will greatly increase the truck movements on this road and also increase the danger to other motorists.

Neighbourhood Forum 5

Wollongong's Heartland

Coniston, Figtree, Gwynneville, Keiraville, Mangerton, Mount Keira, Mount St Thomas, North Wollongong, West Wollongong, Wollongong City.




DUNMORE QUARRY MODIFICATION 6

for Increased Extraction Area and Road Haulage DA 470-11-2003 Mod 6.

SUBMISSION to the NSW Department of Planning and Infrastructure

from Wollongong City Neighbourhood Forum 5 February 2013


INTRODUCTION

Neighbourhood Forum 5 operates under the auspices of Wollongong City Council. At its meeting of 6 February 2013, Neighbourhood Forum 5 resolved to make a submission objecting to increasing road haulage of quarry products by 500,000 tonnes per annum without further examination of rail haulage.

Our concerns are similar to those raised by Neighbourhood Forum 5 in July 2011 in a submission to the Department to an application by Hanson Construction Materials Pty Ltd (Hanson) to expand the rate of production from a present level of about 1.5 million tonnes per annum (mtpa) to 4 mtpa over time, using both road and ship transport.

Neighbourhood Forum 5 (in submissions to the NSW Department of Planning) has called, inter alia, for a levy of $5 per tonne to be applied to additional road haulage of quarry products from Bass Point to Sydney, with the proceeds being applied to road improvements and the upgrading of noise walls along the F6 and the Mt Ousley Road. The amount of $5 per tonne was based on estimates of external costs or road and rail freight as noted by the 2012 report of the Independent Pricing and Regulatory Tribunal of New South Wales Review of Access Pricing for the NSW Grain Line Network.

The withdrawal of the ship, the Claudia I, was reported by the Sun Herald on 10 July 2011 (p19) in an article "Ship out, congestion in". In summary, More than 200 extra trucks are now on inner -city roads after a ship which used to carry more than 9000 tonnes of gravel into Sydney Harbour each week was withdrawn from service by Hanson Concrete of Glebe. The ship Claudia 1 which made three return trips a week from the company's quarry at Bass Port to Glebe, carried 3100 tonnes per trip. The company was reported as looking for a replacement vessel. However, it was also noted that this could take some time.

The withdrawal of this ship, and the delays in replacing this ship, means that there are also up to a further 200 extra trucks are now on the Mount Ousley Road and other main roads, not only in Wollongong City and Sutherland Shire, but also the City of Shellharbour.

Wollongong's main roads to Port Kembla have no shortage of coal trucks on public roads, over five million tonnes per annum (mtpa) to the Coal Terminal and the steel works with higher tonnages approved in 2009. In addition, there are grain trucks (with approval granted in 2011 for up to 0.5 mtpa of grain with options for more road haulage) and other freight associated with Port Kembla Outer Harbour Expansion approved in 2011.


THE PRESENT APPLICATION

Neighbourhood Forum 5 is concerned that it is proposed to increase the limit for road transport of product from the Dunmore Hard Rock Quarry from 1 Mtpa to 1.5 Mtpa.

The Environmental Assessment (EA) notes that (3.3.3 Alternatives)
" Boral has consulted with Pacific National Rail about the availability of additional rail paths to rail product to the St Peter's terminal. Pacific National indicated that they were unable to identify a suitable additional train path (see correspondence from Pacific National in Appendix A).

We would ask that more efforts be made to find additional train paths (even if at night or in weekends) by either Pacific National or another rail freight operator.

The Environmental Assessment (EA) and its Appendix re Traffic and Transport matters gives inadequate attention to current problems with the existing road network and the cumulative impacts of more heavy trucks on Illawarra Roads.

In fact, the Mt Ousley Road does not appear to be mentioned at all in the EA or Appendices. This is clearly an oversight, and unless the proponent is prepared to accept a condition that the modification will led to no extra trucks on the Mt Ousley Road, the impact of any extra trucks on the Mt Ousley road should be dealt with in detail.

A major question is the envisaged additional tonnage to be hauled on the Mt Ousley Road.

The total costs of any additional road transport, including those of the external costs of the increased cost of road crashes, plus more truck noise and air pollution, are not mentioned in the EA or appendices. These questions should be addressed.

Road Crash Risk

The Illawarra Mercury has ongoing reports of fatal crashes on major roads. These reports by the Illawarra Mercury have been going on for years, yet the risk of fatal road crashes do not appear to rate a mention in the Bass Point Quarry Project Environmental Assessment.

Road congestion

There is also the growing peak hour congestion on the Mt Ousley Road and the freeway to Sutherland.

These busy roads have had to deal with expansion of the population of Wollongong and Shellharbour with more people than ever commuting to Sydney for work. Plus the start up of car-carriers in 2008 following expansion of the Inner Harbour, and the lifting in 2009 of a long standing night etc curfew of export coal truck movements with approval to conditional double road haulage coal from a hefty 5 million tonnes per annum (mtpa) to a massive 10 mtpa.

In addition, the EA Conclusions note, inter alia, that "a negligible proportional increase in current vehicle movements along the Princes Highway and is unlikely to have significant impacts in terms of intersection performance, air quality or road traffic noise."

Neighbourhood Forum 5 suggests that the use of mere vehicle numbers, as opposed to measures such as Passenger Car Equivalent kilometres or Weighted Vehicle tonne kilometres, understates the real impact of the extra heavy truck movements.

Noise

More effort should be made by NSW government authorities to reduce truck noise, including late at night in the early hours of the morning.

The RTA notes (http://www.rta.nsw.gov.au/heavyvehicles/reducingnoise.html), "Noise from heavy vehicle engine compression brakes is a significant and on-going cause of complaint for many NSW residents."

This website notes that a pilot fixed noise camera site was constructed at Mt Ousley and has been operational since November 2007. Yet, truck noise has not abated since then.

There should be a demonstrable decrease in truck noise before any approval is given to allow for more heavy trucks to access Port Kembla.

Air pollution

Both diesel trucks and diesel trains are responsible for air pollution and small particle emissions. However, to move quarry products, trucks use about three times more diesel than trains to move a tonne of freight. This leads to three times the air pollution.

Rail adequacy questions

When the NSW Government granted approval, c2004, for the expansion of Port Kembla to accommodate car carriers, Wollongong people were assured that the existing road and rail infrastructure would be adequate. However, the NSW Parliamentary State Development Committee after conducting an Inquiry into Port Infrastructure in New South Wales in a report released 17 June 2005 made two important recommendations:
Recommendation 12. That following the anticipated transfer of general cargo stevedoring to Port Kembla in 2006, the NSW Government re-examine the freight task out of Port Kembla to ensure that the anticipated increase in freight traffic is supported by the necessary improvements in road and rail infrastructure.
Recommendation 13. That the NSW Government consider the feasibility of expanding rail infrastructure into Port Kembla, including consideration of the Maldon to Dombarton line, in conjunction with the AusLink program.

Despite not only the car carriers but the approvals to put more coal trucks on our main roads, and in 2011 further truck movements have been approved in connection with reclamation of part of the Outer Harbour and its Stage 1 operation. On top of Wollongong residents being asked to have more grain trucks on their roads comes the proposal to put more quarry trucks onto Mt Ousley


Encouraging rail and external costs

Keeping the output from Dunmore Quarry that is moved to metro Sydney on rail needs more examination by the proponent.

In addition, a levy of $5 per tonne to be applied to additional road haulage of quarry products from Dunmore to Sydney, with the proceeds being applied to road improvements and the upgrading of noise walls along the F6 and the Mt Ousley Road.

Cummulative Impacts

During 2008-09 the NSW Department of Planning processed a Major Projects application by the Port Kembla Coal Terminal (PKCT) to lift a long standing curfew on road deliveries by coal trucks to the PKCT and to lift already high levels of road haulage of coal of about 5 mtpa of coal to the PKCT to a maximum of 10 mtpa. The application resulted in the Department of Planning receiving 122 written objections. As noted by the 2009 Director-Generals Report concerned with the PKCT (p12),

"The main grounds for objection included:
- noise, road safety and driver behaviour, dust and air pollution, impact on infrastructure and greenhouse gas emissions due to an increase in heavy traffic movements;
- choice of road transport in preference to provision of a rail link, in particular the completion of the Maldon-Dombarton rail line to transport coal more efficiently from the Western Coalfield; ...
- limited community consultation during the environmental assessment process."

Car imports, of which the development consent stated that by December 2011, some 20 per cent are supposed to leave the port by rail, continue to all go by road. In addition to the high numbers of coal trucks combined with car carrying and other trucks, in March 2011, the NSW Department of Planning gave conditional approval to Stage 1 of an application (MP 08-0249) for Port Kembla Outer Harbour Expansion.

Neighbourhood Forum 5 notes that in 1990, Wollongong City Council formed a Coal Transportation Task Force. The report of this Task Force, adopted by Council noted, inter alia, that the NSW Roads and Traffic Authority had then suggested that an average external cost of pavement wear and tear due to bulk haulage is 3 cents per net tonne kilometre (see Task force praises proposed coal levy, The Advertiser, 20/6/90).

It is of note that in June 2010, the Submissions Report for the Port Kembla Outer Harbour Expansion released by the Department of Planning included comment by the NSW Roads and Traffic Authority that after consideration of the impact of Stage 1 Port Kembla outer harbour traffic volumes (bulk, general and limited containers) if the predicted rail mode share could not be achieved, there would be likely "... unacceptable impacts to road safety and traffic efficiency as well as environmental issues such as amenity, noise and air quality."

Attention is drawn to statements on page 4 of the 2006-2031 Illawarra Regional Strategy of the Department of Planning as follows: "It is important that the Region's transport networks support economic growth and maximise the efficiency of freight transport. In particular, what is required are strategic transport corridors to support development of the port of Port Kembla, increase the proportion of freight transported by rail, efficiently link regional centres and towns, and support public transport."

Wollongong does not want another approval that reduces the proportion of freight transported by rail.


Recommendations

The present proposal to lift road haulage of coal from Dunmore Quarry with inadequate consideration of transport proposals suggests that the Environmental Assessment be revised with a full discussion of transport options and impacts and resubmitted.

The new version should include detailed consideration of all cumulative impacts, together with consideration given to:

a. A nominated maximum tonnage of Dunmore quarry products on the Mt Ousley road ( a limit of 200,000 tonnes per annum).
b. An estimate of all of the external costs of any additional quarry product movements from Bass Point to Sydney on road.
c. A code of conduct for Quarry Products drivers (as per coal truck drivers) and specification of trucks to meet Euro 5 standards with locked black box monitoring.
d. An outline of measures to encourage more Dunmore Quarry Products onto rail. These should include a surcharge on road deliveries to cover the external costs for which we suggest a levy of $5 per tonne to be applied to additional road haulage of quarry products from Dunmore to Sydney, with the proceeds being applied to road improvements and the upgrading of noise walls along the F6 and the Mt Ousley Road.
e. Acceleration of completion of the Maldon Dombarton rail link.

If a limit of say 200,000 tonnes of Dunmore Quarry products on the Mt Ousley Road is not acceptable to the proponent, Neighbourhood Forum 5 would request reference of the application to the Planning and Assessment Commission, and holding a Public Hearing.

We have enough trucks on the F6 and Princess Highway as it currently is.
No rail paths is not valid and just shows how Rail Corp is not able to manage their infratructure. We hear freight trains running though the night and Rail Corps own ban on freight trains in peak times also shows thier mismanagement.
By allowing more trucks it is giving a financial advantage at tax / rate payers expense. The company does not have to build its own infrastructure to unload trains but would use the NSW peoples infrastructiure therefore giving them a financial advantage. It is the company's decission to change the operations of it curent unloading infrastructure and want the Illawarra people to bear the cost of using the NSW peoples infrastructure.
If the company wants in increase its output then it has to buy / build infrastructure to do it.

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