Monaro Rock Quarry Project

Submission in Strong Opposition — Monaro Rock (Royalla) Quarry (SSD / Major Project)
To: NSW Department of Planning & Environment — Assessment Directorate
Re: Monaro Rock Quarry Project (Royalla) — SSD-27223807 (EIS on exhibition)
From: [Alex Tine — Resident, living within 1.5 km of the proposed quarry site]
Date: 22/09/2025

Executive statement — my position (short, unequivocal)
I STRONGLY OPPOSE the Monaro Rock quarry proposal. As a resident who lives 1.5 km from the proposed pit, I am speaking from direct lived experience and local knowledge. This project would bring daily, sustained and unacceptable harm to my health, my family’s wellbeing, our property, our wildlife, our Indigenous heritage and the integrity of the local environment for decades. The EIS does not justify placing this heavy industry in a rapidly growing residential and peri-urban area. The project must be refused. If it is not refused, it must face legally enforceable, non-negotiable conditions (listed below) that protect the community — starting with an absolute ban on any quarry truck movements on Old Cooma Road.
(Planning filing & project facts for the record: Monaro Rock proposes up to 1,000,000 tpa and a multi-decade operation; project documents confirm road haulage by heavy vehicles is fundamental to the proposal.)
NSW Planning Portal+1
My lived reasons for opposition (personal, detailed)
1) Dust and respirable crystalline silica (RCS): an immediate health threat — worse on windy days

Hard-rock quarries and crushing plants generate airborne dust that contains respirable crystalline silica (RCS) — a proven cause of silicosis, lung cancer and chronic respiratory disease. The EIS itself acknowledges dust and RCS emissions are possible; the proponent’s claims that “levels will be below acceptable limits” do not reassure me because real world quarry and construction projects frequently record exceedances on windy days despite controls. The science and national guidance require conservative, independent community protection measures (continuous monitoring, automatic shutdown triggers, funded health surveillance), not voluntary partial measures. I will not accept a guarantee based only on proponent monitoring plans.
Safe Work Australia+1
Demand: Binding, enforceable protections including continuous, third-party PM10/PM2.5 and RCS monitoring at multiple community receptor sites (public live feeds), immediate automatic operational shutdown triggers when levels exceed conservative community protection thresholds, and a developer-funded long-term community health surveillance and medical fund (life of project + 10 years).
2) Truck movements, road safety and haul routes — absolute ban on Old Cooma Road
The EIS and community summary show the project will generate huge heavy vehicle movements — Monaro Rock documents indicate up to 500 heavy vehicle movements per day (the applicant’s community summary). This number, and the presence of concrete / asphalt dispatch vehicles and other heavy plant, will move across local roads. I refuse to accept the use of Old Cooma Road by quarry trucks for any reason.
Old Cooma Road runs through residential peri-urban areas and is not an acceptable haul route for sustained heavy-truck traffic. I demand:
• No trucks at any time to or from the quarry on Old Cooma Road (absolute prohibition).
• The road must carry a 12 tonne maximum vehicle limit for any regular traffic classification; quarry trucks are specifically excluded. (Apply and enforce local Council / RMS weight limits and install physical controls, signage and enforcement cameras.)
• All proponent haulage must use the Monaro Highway or other designated, upgraded heavy-vehicle corridors (but only if those routes have been independently assessed and funded for the expected volumes).
• Legally binding haul route agreements and an indexed bond to pay for road repair, intersection upgrades and long-term maintenance if quarry traffic is permitted on any road elsewhere.
Monaro Rock Pty Ltd - Royalla Quarry+1
Old Cooma Road is already subject to staged duplication upgrades by Council — it is being prepared for residential growth, not industrial trucking. The quarry must not hijack local road planning for its own freight needs.
qprc.nsw.gov.au
3) Scale: 500 trucks/day, population growth and cumulative impacts
The community summary and EIS documents indicate up to 500 heavy vehicle movements per day at peak — this is not a small rural pit, it is an industrial operation sized to support major regional construction. That traffic will intersect with a community that is growing rapidly. Local government population forecasts show the Queanbeyan-Palerang region and surrounding Canberra southern districts are experiencing substantial growth (tens of thousands of additional residents over coming decades), increasing exposure and vulnerability to dust, noise and safety impacts. The Department cannot approve a major industrial freight generator into a locality that is transitioning to higher population density.
Monaro Rock Pty Ltd - Royalla Quarry+1
Demand: The application must be refused on the grounds of cumulative unacceptable amenity and safety impacts; at minimum the Department must require an independent cumulative impact assessment that includes projected regional population growth and the full life-of-project vehicle movements.
4) Threatened ecological communities and species — clearing is unacceptable
The proposed quarry would directly remove and fragment remnant native woodland that is part of the White Box – Yellow Box – Blakely’s Red Gum grassy woodland ecological community — listed as critically endangered in NSW and nationally. These woodlands are irreplaceable, host hollow-bearing trees and groundcover communities, and support threatened fauna. The surrounding region is habitat for threatened woodland birds and fauna (for example, the Superb Parrot, Brown Treecreeper (south-eastern subspecies) and Hooded Robin (south-eastern) are representative threatened species of woodland remnants in this part of NSW/ACT). Loss of remnant woodland cannot be adequately offset and must be avoided.
Climate and Water Dept+3
Environment and Heritage+3
DCCEEW+3
Demand: Absolute avoidance of all remnant woodland and CEEC; if any ground disturbance would harm CEEC, the project must be refused. If the Department entertains offsets, they must be independent, in-perpetuity, and demonstrated to be ecologically equivalent — but avoiding clearance is the only acceptable standard.
5) Aboriginal cultural heritage — precaution and statutory protections
The area around Royalla has Aboriginal heritage value and the NSW guidelines (and AHIMS checks) require thorough assessment, consultation with Traditional Owners / Local Aboriginal Land Councils and meaningful mitigation before any approval. The EIS references a Preliminary Aboriginal Cultural Heritage Assessment, but the Department cannot approve a project with the risk of irreversible harm to Aboriginal objects, places and intangible heritage. The proponent must satisfy the Due Diligence Code and seek any necessary Aboriginal Heritage Impact Permit only after robust consultation.
Environment and Heritage+1
Demand: Independent, properly resourced Aboriginal cultural heritage assessment with local Traditional Owner leadership; no disturbance to identified sites; refusal if harm cannot be avoided.
6) Groundwater, surface water and wetlands — high uncertainty, irreversible consequences
Quarrying and dewatering can change groundwater levels and flow paths, threatening groundwater-dependent ecosystems and private water supplies (wells), and potentially affecting downstream springs and agricultural uses. The EIS must provide independent hydrogeological modelling, conservative worst-case scenarios, and legally enforceable monitoring, remediation and financial assurance. The risk of drying and water quality impacts to neighbouring properties is unacceptable without ironclad guarantees.
Major Projects
Demand: Refuse if groundwater impacts cannot be excluded. If not refused, require independent peer review of groundwater modelling and an unconditional, indexed rehabilitation and impact bond large enough to fund remediation, compensation and long-term monitoring.
7) Noise, blasting and vibration — unacceptable for nearby homes and wildlife
Blasting, crushing and constant heavy vehicle noise will materially reduce amenity and could damage homes and farm infrastructure. Blasting also affects fauna, causes sleep disturbance and will be felt by the growing nearby population and by wildlife within remnant woodland. I demand a precautionary approach — refusal unless the proponent can show blasting and noise will not exceed conservative limits at the nearest homes and sensitive ecological receptors for all operations and for the project’s full life.
Monaro Rock Pty Ltd - Royalla Quarry
8) Property values and social/economic harms
There is substantial empirical evidence that large pits and quarries depress nearby property values and that public announcements of haul routes can reduce buyer demand — losses that are borne by homeowners, not the proponent. I (and my neighbours) should not be forced to assume the financial risk of permanently reduced land values because a private business wants cheaper aggregate close to its batching plants. The Department must treat expected property value harm as a material social impact.
Appraisal Institute of Canada+1
Demand: If approval is considered then require an independent property-impact valuation study paid for by the proponent, with a developer-funded compensation scheme for any demonstrable loss to homeowners within a defined buffer (minimum 5 km, with a higher compensation scale within 1.5 km).
Concrete, non-negotiable demands (if the Department permits any further assessment rather than refusing outright)
Absolute ban on Old Cooma Road for quarry traffic.

I wouldn’t normally go through the effort of making a submission such as this, however I feel morally compelled to do so following the very strong negative feelings which I have heard amongst the local community. The health risks of silica dust being propagated into the air is my primary concern, however I have many secondary concerns such as the added traffic from large machinery on the Monary Hwy and the risk of negatively affecting the housing market in the region due to the added noise from the site’s operation and the increased silica dust levels in suburban areas.

From my research, it is my understanding that similar facilities such as this are operating at present, however are not at full capacity. It seems disgraceful that a facility such as this could be considered when the benefit is for very few, when the repercussions could be felt by so many.

This is why myself and many who I have spoken to in the community are in deep opposition to this project.

Due to health this would affect me and my kids

This quarry will impact my parents home and a place where I spend significant time. As a young adult, I am concerned about the impact to our environment from the removal of critically endangered habitat. I am concerned about my long term health and the cumulative impacts of quarrying. I am concerned about the direct impact to my parents in overlapping quarry impact areas and may friends who reside close to the new quarry. It's upsetting when these decisions are for the greed of people, not for the good of the community. It's not needed and it impacts Royalla, Tuggeranong and more.
I object. The independent minister should review and not let this quarry be decided by those who don't know the impact to our heritage. Australia needs conservation for our future. This is what matters. Our lands matter and as an indigenous person, this quarry is not ok. Let the indigenous people of the area have more say on this quarry. They will say no. Bring the indigenous people to the planning table and let them speak their truth about these lands. They were not meant to be dug up and destroyed.

I am objecting to the Monaro Rock quarry.

I request that the Independent Planning Commissioner review the request

These are a summary of my objections:

There are already enough quarries in the local area and they are not at
capacity.

All existing quarries have capacity to meet the growing need.

There will be dust, noise and traffic impacts that will compound with the
two other quarries using the roads in the immediate vicinity.

The dust from quarrying is a known documented risk via silica. The
non-industrial risks from silica are under-studies but emerging as a genuine
risk.

The road intersection on Monaro will require a major speed reduction in the
overtaking section meaning there will be more risk in the single carriageway
section. Already I see the most appalling overtaking and dangerous driving
on this section of single carriageway. Reducing the speed limit in the
overtaking section (the only viable option) will, with certainty, cause
accident in the area where the overtaking lane ends. I have genuine concern
for my own safety travelling that highway every day already. The proposed
intersection makes it worse.

Mates Drive should not be used for heavy vehicles as it is unsuitable and
puts an unacceptable impact on residents.

Royalla will be impacted from a property value perspective.

I work in the heavy vehicle repair industry. The EIS does not cover enough
detail on the workshop on site and the fuel storage arrangements. The lack
of detail means there is a direct risk.

There will be a direct dust impact to the solar farm at Royalla damaging or
degrading Canberra power infrastructure.

I completely object the unnecessary quarry proposed.

Monaro Rail Trail Inc is a community organization that wishes to convert the disused 213 km long Monaro rail corridor from Queanbeyan to Bombala into a recreation facility, known as a rail trail, and which supports, walking, running and cycling activities for people of all ages and abilities. MRT Inc does not oppose the quarry proposal but does wish to comment on some aspects of its proposed development and its activities
The MRT project brings benefits to community health and gives rise to a new form of tourism which will help boost economic activity in the bypassed villages and towns along the rail corridor. The project has widespread support from, individuals, business operators, resident associations, and importantly the two key stakeholders – Queanbeyan-Palerang Regional Council and Snowy Monaro Regional Councils who have funded feasibility studies. The NSW Government has funded the supporting business case and the project is now shovel ready.
One of the most used segments on the trail will be the section Queanbeyan to Michelago, it is anticipated that each year over 100,000 people will make use of the trail between those two points. Although the actual quarry will not be visible to users of the rail trail, the proposed quarry access road and the suggested daily 500 vehicle movements, will be close to the rail corridor for approximately 800m as the road approaches the Monaro highway. Consequently, MRT Inc feels it is appropriate to comment on the proposal to establish the Monaro Rock Quarry on land bordering the rail corridor.
Dust suppression: During the dry summer months, December to April, when dust suppression may be most difficult, the prevailing wind direction is easterly and users of the rail trail could be subject to poor air quality. If the access road is unsealed then trail users will certainly be subject to dust as trucks travel parallel and close to the rail corridor. We do note that the EIS statement reports that there will be no discernible changes to the air quality. However, an assurance that the access road is to be sealed along that section close to the rail corridor would alleviate concerns from MRT Inc.
Noise suppression: The EIS reports that 500 heavy trucks will be entering/leaving the quarry per day (page 35). These will all travel along the access road and in proximity to users of the rail trail and although the trucks will be travelling slowly, there will still be the noise linked with general movement, and particularly acceleration and braking. This will certainly intrude into the space of trail users. However, we believe that increasing the distance between the access road and the rail corridor plus screening with vegetation would help to alleviate this issue. An alternative option is to consider the proposed fence on the east side of the access road, could it be built on the west side of the access road for that 800metre section where it is parallel to the rail corridor? Tree and shrub planting on both sides of the access road will also help buffer noise.
Visual abatement: Our comments here mirror those on noise suppression. Users of the trail, in an otherwise rural setting, do not wish to feel they are walking/running/cycling alongside heavy trucks. The EIS reports up to 500 heavy vehicle movements per day, which means for an 8-hour day there will be a truck on the road every minute. Installation of a fence on the west side of the access road would reduce rail trail user’s views of truck movements. Furthermore, dense planting of appropriate plant species would enhance visual screening of, not only vehicles but also the proposed 3m high fence.
Traffic movement: MRT Inc is pleased that the proposal has planned for the access road to include a bridge over the rail corridor. This immediately removes all risks to trail users as vehicles will be separated from trail users. We note that the planners are sensitive to routing quarry traffic through local roads and have instead wisely chosen to use the Monaro Highway. However, we do have a general concern about the number of slow-moving trucks that will enter the Monaro Highway and pose a potential risk to fast moving highway traffic. We urge that the intersection of the quarry access road and the Monaro Highway be planned carefully.
Thank you for the opportunity to comment on the proposal.
Andrew Carter
Secretary MRT Inc

Royalla is the gateway to the Snowy Monaro region. It's the first settlement that travellers from Canberra and further afield see when travelling south, with its natural beauty and rural ambiance. The proposal to turn it into a rock quarry and cement processing plant is jarring to say the least.
As the project proposal documents note, Royalla is also slated for significant new housing developments - surely a priority for the New South Wales government, and likely to be adversely impacted by the proposed quarry.
Most importantly for residents of the Monaro Highway further south, however, is the impact of the proposal on the traffic on, and condition of, the Monaro Highway. Road damage is increased with the 4th power of vehicle weight, so doubling the weight of the vehicle will increase the damage by 16 x. Eg if a car is 2 tonnes, and a truck is 20 tonnes (10 x heavier) it creates 10,000 times more road damage. According to Appendix 1 to the EIS, '[t]he despatch of quarry products would principally use truck and dog trailer combinations, with a load capacity between 32.5 tonnes (t) and 37.5 t.'. https://www.denenapoints.com/relationship-vehicle-weight-road-damage/
Moreover, increasing the traffic on the Monaro Highway by approximately 500 heavy truck movements per day will create increased congestion and danger to commuters from Michelago and other settlements south of Royalla, many of whom are young families working in Canberra and with children in Canberra schools.
I urge the decision makers not to approve this project.

I do not like that this quary has even been proposed. Being in the construction industry and learning so much about scilica dust. This raises so many health concerns for my now new home. Scilica can kill people and with how windy it is out near us this raises major concerns. Is the nsw government going to 100% guarantee that 0% health risks will come to the Tralee community ? Our residence has had plans and promises change so many times since we purchased and now there is a risk that Tralee and royalla could turn into wittenoom in coming years like how the WA government did to those residents.


There are plenty of locations away from residential properties that can keep this isolated and preformed safely and no reason to be so close.

Can you confirm that my family, friends and neighbours will never get scilica? Can you confirm that the trucks will not cause damage to the area? Can you confirm that no dust from the quary would come into the area?

Do not let this go ahead

I am significantly concerned about this proposed project. I am a new resident to Tralee intending to start a family in the suburb and am relying on the appreciation of my property for my retirement. The proposed quarry and its negative impacts on its surrounds will inevitably decrease the value of my property. We moved to Tralee to enjoy the benefits of rural suburban living including less traffic, less noise and cleaner air. The proposed quarry will have the opposite effect on all these categories. I have deep concern and fear raising a young family in such close proximity to known lethal silica dust within their environment, a place I hoped they would be able to live, breath and play safety and I now fear than instead of enjoying the quiet and safe streets I will be forced to remain inside during times of major works. If I had known this were the case I may as well have bought an apartment in the CBD to raise a family. Additionally I have significant concerns about my husbands health who has worked as a tradesman for years having being exposed to silica dust and asbestos on many occasions during his career. If this proposal goes through he will no longer be safe from workplace hazards within the comfort and safety of his own home.

Thank you for considering my submission. I trust the right decision will be made for the sake of the safety of the community.

Rachel

I am writing to object to the Monaro Rock Quarry proposal. After reviewing the available documentation, I believe the project is inconsistent with planning principles and would have unacceptable impacts in the areas of traffic, amenity, economic necessity, biodiversity, and water resources, particularly local aquifers.

1. Road Safety and Traffic Capacity
The quarry is projected to generate up to 500 heavy vehicle movements per day, equating to a truck entering or leaving the site every 1–2 minutes during operating hours.
Old Cooma Road is a single-lane rural road that is already unsuitable for its current use:
• In several sections, it is barely wide enough for two cars to pass, creating danger when larger vehicles approach. I personally feel unsafe when trucks come toward me due to the lack of road width. This situation is complicated if a cyclist happens to be on the road, and will undoubtedly lead to an accident at some point.
• After rain, potholes become unavoidable, creating further hazards for all road users.
• The road will face increasing traffic from the growing Googong development, which will add pressure even without the quarry.
The Monaro Highway, while a major road, is also frequently congested. During peak periods, such as the snow season and summer holiday traffic, traffic often banks up for many kilometres, especially around the entry and exit points near the proposed quarry. Adding hundreds of slow-moving, fully loaded quarry trucks to this highway will significantly worsen congestion and safety risks.
Even with upgrades, intersections near the site have limited sight distances, increasing the likelihood of collisions. There is no viable alternative route that would prevent these impacts from spilling into residential and community areas.

2. Noise, Dust, and Blasting Impacts
Operations are planned for 12 hours per day, six days per week, including blasting, crushing, and concrete/asphalt production. This will create ongoing industrial noise and vibration, impacting nearby residences.
The quarry will process 1,000,000 tonnes of material annually, generating dust containing respirable crystalline silica, a recognised health hazard. Fine particles can travel up to 16 km, placing approximately 92,000 residents within 10 km of the site at risk.
Almost all of the households in the area rely on rainwater tanks, which could become contaminated by dust. Dust suppression depends on substantial water use, which may not be sustainable during droughts.

3. Economic Redundancy
There are four existing quarries within 30 km of the site, including Williamsdale and Cooma Road quarries. These operate well below capacity, with an estimated 70 years of reserves remaining.
The Monaro Rock Quarry would duplicate existing supply, leading to oversaturation without clear public benefit. Even the proponent’s Environmental Impact Statement states it would supply only 25–30% of regional demand, indicating most demand is already met by current operations.
The limited employment benefits (approximately 20–30 jobs) do not justify the scale of impacts.

4. Biodiversity and Environmental Loss
The project would clear 77.83 hectares of native vegetation, including 22.44 hectares of critically endangered Box Gum Grassy Woodland, protected under NSW and Commonwealth legislation.
The site also provides habitat for threatened species, including:
• Pink-tailed Legless Lizard – 40 ha of potential habitat
• Key’s Matchstick Grasshopper – 2.35 ha
• Pale Pomaderris – 0.56 ha
• Small Purple-pea – 0.13 ha
• Silky Swainson-pea – 2.66 ha
This area is partly zoned C2 Environmental Conservation, reflecting its ecological value. Offsets cannot fully compensate for the permanent loss of this habitat.

5. Groundwater and Aquifer Impacts
The quarry will require up to 42.4 million litres of groundwater annually for dust suppression, processing, and concrete production.
This region has a history of groundwater stress. During the 2020 drought, many residential and agricultural bores ran dry. Extracting water at this scale risks lowering aquifer levels, which would reduce supply for residents and farms and impact surrounding ecosystems.
Aquifer depletion could also affect baseflows to Tuggeranong Creek, degrading water quality and threatening downstream ecosystems.

In summary, the Monaro Rock Quarry would:
• Overburden unsuitable roads like Old Cooma Road, already narrow and hazardous, and worsen congestion on the Monaro Highway.
• Reduce residential amenity through constant dust, noise, and blasting, risking drinking water quality from tank water
• Duplicate existing quarry capacity, which I believe already sufficient to meet regional demand for decades.
• Destroy critically endangered habitat and increase pressure on limited groundwater resources.

Given these significant and irreversible risks, I respectfully request that NSW Planning refuse approval for this project.

Too close to the suburbs. Don’t want this to go ahead. I object to this project. Do not proceed.

Too close to suburbs, do not want the mine to go ahead

I object to this project as I live nearby and I think the added truck traffic on the local roads will be dangetous and noisy. The roads are already terrible and if we are to get up to 500 more trucks a day, it will be a great danger to anyone on the road.
I am also concerned about the health impacts of any silica dust that will drift across the local area. We live in the country because we love the clean fresh air.
I am also concerned about potential increase in noise - again we choose to live in the country for the peace and quiet lifestyle.
I am also concerned for the endangered flora and fauna in the area.

To whom it may concern,
I object to the proposed quarry project in Royalla. Please see document attached.

I object to this project due to the proximity of my home.

I object to the project due to the proximity to suburban areas and the potential impact on sensitive environment.

I am writing to formally object to the proposed Monaro Rock quarry in Royalla. I have recently learned that, contrary to initial advice, it is not solely a blasting quarry but rather an industrial-scale operation which includes rock crushing, concrete recycling, and asphalt manufacturing.

The increase in traffic, particularly heavy trucks, will significantly affect residents of Royalla, Mount Pleasant, Fernleigh Park, Googong, and surrounding areas. Currently, navigating these roads for school and work involves considerable risk, and an escalation in traffic volume will only heighten these safety concerns. There are limited alternative routes available to bypass truck traffic. The infrastructure of rural residential roads near the proposed quarry site is not designed to accommodate large vehicles and is already in a state of disrepair; this already results to damage to vehicles, especially those with specialised wheels. Furthermore, increased truck presence on the major highway will add pressure to a route that already experiences a high incidence of accidents and fatalities due to challenging road conditions, adverse weather, limited visibility, and driver error. This will make the highway less accessible to local residents.

There is also an environmental impact associated with establishing a quarry in a residential area. The proposed development plans involve the removal of hectares of native vegetation, including Box Gum Grassy Woodland, which is classified as endangered, as well as habitat for hundreds of animal species. This will result in these animals moving into other built up residential areas and onto roads, increasing their exposure to vehicular traffic and loss of life.

Although they are claiming that dust levels will be maintained within "acceptable" limits, there remain concerns regarding the potential long-term health impacts, such as silicosis resulting from prolonged exposure. The possibility of dust contamination in water tanks and on properties raises important questions about responsibility for future medical expenses related to these health issues.

In light of these concerns, I urge the NSW Department of Planning to reject the Monaro Rock quarry proposal. The long-term costs to public health, environmental integrity, and community wellbeing far outweigh any short-term economic gains.

Traffic on the Monaro hwy and in particular truck traffic, is already at dangerous levels due to design, construction and width and road surface

This road has seen multitude of deaths, serious accidents and we as locals live with an un- policed raceway on the Monaro hwy during winter that clogs the hwy with ski traffic and is dangerous to be on from 2 pm Friday until 8 pm Sunday the entire ski season
Adding more truck and construction traffic to this mix will result in death

1. Central flaws in the Human Health Risk Assessment (HHRA)

The HHRA is presented as the basis for concluding health risks are “low.” However, its methodology and scope are insufficient and biased towards minimising impacts:

Restricted receptor focus – The HHRA concentrates on a small number of nearby NSW receptor points. It asserts that more distant locations will experience “smaller/lower” pollutant concentrations but provides no detailed modelling outputs to support this. The ACT, which contains dense residential suburbs, schools, hospitals, and aged-care facilities, is excluded from meaningful assessment. This is not scientifically or ethically defensible.

Lack of cross-border modelling – Prevailing winds often blow towards the ACT. Failing to model ACT receptors ignores a large exposed population. This omission is especially concerning given the ACT’s role as a health, education, and administrative centre, where vulnerable groups are concentrated.

Insufficient transparency – The HHRA does not provide continuous contour maps, gridded receptor results, or raw model outputs. Without these, the public cannot validate the claim that ACT exposures are negligible.

Over-reliance on operational controls – The HHRA assumes perfect, continuous functioning of dust suppression and management systems over 30 years. No sensitivity or failure analysis is provided for drought, strong winds, system breakdowns, or bushfire interactions. Real-world experience shows such controls degrade, fail, or are poorly enforced.

Narrow pollutant scope – The HHRA focuses on respirable crystalline silica and coarse dust but does not adequately consider PM2.5, diesel particulate matter, NOx, or cumulative pollutant exposures. Long-term public health impacts from fine particulates and combined pollutants are excluded.

No independent review – The assessment is proponent-funded and has not undergone independent epidemiological peer review. For a project of this scale and duration, independent public health review is essential.

In short: the HHRA’s narrow scope, lack of cross-border modelling, and assumption of perfect controls render its conclusions unreliable.

2. Public health significance

Respirable crystalline silica (RCS): Silica is a known cause of silicosis and lung cancer. Even low-level, long-term exposures can cause population-level health impacts.

PM2.5 and PM10: Chronic exposure is strongly linked to respiratory and cardiovascular disease. Children, elderly people, and those with asthma or COPD are most vulnerable.

Cumulative exposure: A 30-year project timeframe means decades of low-level exposure that compounds over time.

Sensitive receptors: Canberra’s hospitals, aged-care facilities, and schools must be explicitly assessed. Excluding them is a breach of the precautionary principle and of public health due diligence.

3. Traffic, safety and amenity

The proposal involves extracting up to 1,000,000 tonnes per year, implying significant heavy-vehicle traffic:

At 30 tonnes per load: ≈ 91 loaded trips per day, or ≈ 180–200 two-way movements.

At 25 tonnes per load: ≈ 110 loaded trips per day, or ≈ 220 two-way movements.

Consequences include increased crash risk, road degradation, noise, diesel emissions, and safety risks to local and cross-border communities. The EIS does not adequately address ACT road networks that will carry quarry traffic, nor does it commit to binding upgrades or safety measures. The costs of road damage will fall on the public unless enforceable contributions are imposed.

4. Groundwater and ecological impacts

The quarry has potential to alter groundwater recharge and drawdown aquifers. Once groundwater regimes are changed, restoration is uncertain or impossible. The EIS relies on consultant models but does not provide independent hydrological review, baseline biomonitoring, or precautionary worst-case analysis. This creates a risk of irreversible ecological damage.

5. Cultural heritage

The Monaro region holds Aboriginal cultural sites and intangible heritage. The EIS does not demonstrate robust, independent engagement with Traditional Owners or credible avoidance strategies. Legally binding protections and independent monitoring are essential.

6. Cumulative and failure-mode risks

The EIS treats issues separately, but the real risk is cumulative: dust + diesel particulates + traffic + groundwater impacts + heritage loss = compounded harm. Failure-mode scenarios (e.g., dust suppression breakdown, extended drought, bushfire ash interactions) are omitted. These scenarios are plausible and must be assessed before approval.

7. Governance and cross-border fairness

Because the quarry is in NSW but downwind communities are in the ACT, excluding ACT receptors from modelling and consultation creates an unfair governance gap. ACT Health and environment agencies must be formally engaged. Current consultation is inadequate and inequitable.

8. Minimum requirements before any approval

If the project is not refused outright, the following are non-negotiable minimums:

Comprehensive cross-border HHRA – Include ACT receptors with detailed concentration contours and raw model outputs.

Independent peer review – Air quality modelling and health risk assessment reviewed by independent experts nominated by government.

Failure-mode analysis – Explicit scenarios for equipment failure, extended drought/wind events, and bushfire conditions.

Independent Health Impact Assessment – Conducted by public health specialists and reviewed by ACT and NSW health authorities.

Groundwater audit – Independent review plus long-term biomonitoring.

Binding monitoring and enforcement – Real-time, public air-quality data, enforceable suspension triggers, and financial bonds for remediation.

Traffic safety conditions – Daily truck limits, defined haul routes, full proponent funding for upgrades, and fatigue/safety measures.

Cultural heritage protections – Legally binding avoidance zones with Traditional Owner oversight.

Conclusion

The Monaro Rock Quarry project, as currently assessed, cannot be considered safe, fair, or scientifically robust. The HHRA’s exclusion of ACT communities, lack of transparency, and assumption of flawless controls fatally undermine its credibility. Given the scale (1,000,000 tonnes per annum for 30 years), the project represents a long-term public health, environmental, and cross-border governance risk.

I therefore request that the consent authority refuse the project. At minimum, determination should be deferred until an independent, comprehensive, cross-border HHRA and peer-reviewed Health Impact Assessment are completed and enforceable protections are in place.

As a resident of the Tuggeranong region in the A.C.T. I am highly concerned about the negative impacts that this proposed development will have upon mine and my family’s health, safety and wellbeing. The increased traffic, noise, blasting, silica dust and pollution and the reduction in my property value are just some of the major factors as to why I object to this project. In our family we have people who have disabilities and asthma. I believe that this will have devastating effects upon our lives. Please, do not allow this project to proceed.