Sancrox Quarry Expansion Project

Please see attached submission.

Please see attached submission.

Would you please register my objection to the proposed quarry expansion in the sancrox area. I live in the very close proximity of 28 Bushland Drive and feel that this project will impact my directly with noise and dust and also ecologically.

Many thanks
Patricia Lamont
0423 481 045

Attached is our submission objecting to the expansion of the Sancrox quarry.
I wish to emphasize the note I made at the bottom of the submission. We already hear noise from the present quarry when it is in operation, being quite loud at times at our house. My concern is that an expanded operation will be closer to our house, noisier still, and if it is operating 24 hours per day it will impact on our sleep.
Thank you
Adrian Smith
217 Verdun Drive, Sancrox NSW 2446. Ph. 0411 135 353

Please see attached submission from DPIE Water and the Natural Resources Access Regulator.

Re: Hanson Heidelberg Application SSD 15_7293 for a New Quarry at Sancrox NSW
I am the owner of Lot 16 DP 776681, Le Clos Sancrox. My land is located proximate to the proposed new Sancrox quarry. I am aware of the Hanson Environmental Impact Statement (EIS) on exhibition until 12th December 2019 and I am quite concerned that the Statement fails to address issues under the categories I have listed here in my letter.
I wish to object to the proposed quarry expansion – ERM Reference 0418291 (Environmental Assessment and Planning Act 1979). The current proposal seems to contain myths, omissions from the EIS, inconsistencies and unwanted impacts for local residents, business and future residents.
The proposed Sancrox quarry application has been presented as an expansion project. This appears to be incorrect as it would be more accurately described as a new quarry. The proposed expansion is to be located on a new Lot and DP and all plant is to be moved, and therefore it would be best described as a new quarry, especially given that the existing quarry was to be closed last century.
Port Macquarie is one of the fastest growth areas in NSW and all future development is to the west, it has less residential Lots than it has quarry rock. Hanson describe the resources found in their existing quarry and potential new quarry is in short supply. What they fail to disclose is the true number of quarries located in the local area with the similar material. Hanson claim they don’t own other resources in the area, but infact they own Lot 2 DP 814356 at Milligans Road, Bago were there are ample Reserves closer than the 200km claimed in their submissions. This quarry also contains high quality rhyolite daicite. Hanson claim that transport costs will be excessive because of 200km haulage distance. More accurately the supply from Bago is only 20km from Sancrox, so this would be negligible.
My land is part of an estate of some 51 Lots of approximately 2 Ha each. I, with a group of lot owners, are currently in the process of working with the local Council to have our land rezoned to Residential, from the current Primary Production (Primary production on this land has failed and it has been deemed by Council that Residential would be the best outcome for the city). PMHC indicated they would not support an application for Rural Residential land, as was originally presented to them. The Council advised that Sancrox land is earmarked for Residential development and the adopted UGMS has indicated Fernbank Creek and Sancrox to be the next areas of investigation. I along with a group of likeminded Lot owners have been working with the local Council to begin the investigations and we have engaged the services of a local Land Development company, Land Dynamics Australia, to assist in this process.
Hanson claim in their submission that Port Macquarie has a 15 year supply of Residential land. It is worth noting that the Council has acknowledged that the new Biodiversity Legislation introduced in 2016 has meant that the estimated 15 year supply of Residential land as stated in the UGMS and referred to in the Hanson letter, may be grossly overestimated. It is believed by the local Land Development experts, including LDA, that the amount of Residential land remaining in Port Macquarie is only approx. 5-7 years. This figure is to be confirmed by a study currently being conducted in conjunction with the PMHC.
The standards we have experienced appropriately being applied at the Local level for approval of our application are rigorous indeed. Our expectation is that an even more rigorous process be applied in consideration of a State Significant Development application for a quarry in an area where there is an existing and rapidly growing residential community and, as well, a sensitive ecological zone.
When considering this application from Hanson for the new quarry please consider the attached letter with my submission.
Inconvenient Truths -
1. A core koala habitat of “high use” level exists in the centre of the proposed new quarry, as shown in the Greater Sancrox study concluded in 2015.
2. A very large portion of the proposed new pit is a “medium use” koala habitat.
a. Given the devastating bushfires currently threatening this already endangered species, now more than ever we need to protect their habitat.
3. A subregional biological linkage corridor runs right through the centre of the proposed new pit location.
4. An Endangered Ecological Community (EEC) of Flax leaved paperbark, prickly-leaved tea tree is located in the area of the new pit.
5. Significant swamp oak and mixed eucalypt open forest areas will have to be destroyed.
6. Previous studies revealed 5 hollow bearing trees for koala habitat in the proposed pit area. The EIS prepared by Hanson says there is 1.
7. Twice daily blasting will impact traffic on Sancrox Rd and may impact the Pacific Highway, every blast. How this will be managed is uncertain but there is a code of conduct for blast guarding which has been developed by the Australian Explosives Industry and Safety Group which Hanson should consider adopting.
8. Hanson has not been able to comply with the screens of trees conditional requirements for the existing quarry. How therefore will they cope with the requirements of significantly higher standard mitigation measures given the dimension of the proposed larger new pit?
9. Possibly the impacted areas cannot be contained within the Hanson owned land simply via management of mitigation measures.
10. Evidence is that the culture at the Sancrox Quarry is not capable of managing mitigation measures for existing operational conditions. There is no indication that Hanson proposes significantly different behaviours to support the management of mitigation measures in the proposed new quarry.
11. The new Sancrox quarry project will fragment and alienate land and result in conflict with adjoining land uses.
The quarry is not ideally situated. In every direction over the range of 300m – 1,300m, there is both current and potential residential development and this new proposal is not consistent with the needs for this local government area.
Omissions from the EIS -
1. No mention is made of the currently being constructed 142 Lot Rural Residential sub-division to the west of the site (Le Clos Verdun), the eastern boundary of which is only 600m from the western edge of the new quarry.
2. No mention is made of the existing houses located on Le Clos Sancrox, the nearest of which is less than 1km from the edge of the proposed new quarry and the proposal currently being considered by PMHC to rezone the whole Le Clos Sancrox as residential, the closest parts of which will be approximately 300m from the southern edge of the proposed new quarry.
3. No mention is made of any bund to the south of the last stage of the new quarry which is essential to protect anything on Le Clos Sancrox. Furthermore, will any bund be effective anyway?
4. No mention is made of the high-speed rail corridor which goes right through the middle of the deepest part of the quarry. This will require the high-speed corridor to be moved onto the adjoining land owned by Jeff Freeman.
5. No mention is made of the impact upon the Billabong Wildlife Park and Koala Sanctuary less than 1 km from the pit.
6. Hanson has not made appropriate recognition of the biological community corridor nor identified how to manage its removal and create alternatives.
Inconsistencies in the EIS
1. Page 39 of the EIS shows the bitumen plant being coal fired. Page 40 of the EIS says the bitumen plant is gas fired, therefore how can this information be relied upon.
Unwanted impacts
1. It will probably not be advisable for local residents to drink their tank water because of the dust impact.
2. The efficiency of solar panels for hot water heating and electricity will diminish significantly over time because of a build-up of dust.
3. Costs of home maintenance will increase with more frequent painting, cleaning of roof and down pipes and windows, all from a build-up of dust.
4. Local residents can expect their sleep will be disrupted from noise from the quarry 24/7. Sleep deprivation can adversely impact health.
5. The current freedom of movement of local residents may be impacted twice daily, from blasting.
6. Blasting from the current operations are already impacting on the local businesses of Cassegrain Winery and Expressway spares, as debris is regularly raining down on their respective rooves, (as reported by them).
7. There may be a higher concentration of dust particles within the air within the region for the next 10 – 30 years.
Considerations not given enough attention
1. The community need for good quality quarry material must be in balance with the social and economic costs of its extraction.
2. Port Macquarie is the fastest growth area in NSW and all future development is to the west, it has less residential Lots than it has quarry rock
3. Quarry operation within the PMHC area are quite competitive.
4. Hanson’s has not adhered to approval conditions for operations at the existing Sancrox quarry why expect a different outcome with a substantially more difficult to operate quarry?
5. A “new” quarry at Sancrox will deliver Hanson all the upside, and PMHC and existing and future communities all the downside. An approval for a “new” quarry also gives Hanson a significantly enhanced competitive position.
6. Round the clock quarry operation, blasting vibration, showering from rock and dust, noise and truck movements and the cost of dust removal over a long-haul period requires a very substantial and much more detailed / e

As a landowner on Glen Ewan Road, Sancrox I wish to make a formal submission. I object to the Sancrox Quarry Expansion Project.
I am concerned about the proposed operation of quarry activities to operate on a 24/7 basis. The noise from blasting and crushing of rocks will be unbearable.
I also have concerns about the pollution and what this may do to the air quality.
Thank you for taking my objection into account.
Yours Sincerely,
George

My name is Rachel Sheppard. I am 35 years old. I am a local psychologist, soccer player and mother. I grew up in the Hastings hinterland, and now live just south of port Macquarie.

I wish to make a formal objection to the proposed Sancrox Quarry Expansion.

I understand that proponent seeks to expand the current quarry by 31.43 hectares – an area just under twice the size of the existing quarry area, to extend the hours of operation to 24 hours a day 7 days a week.

I note the following:
- Local environmental impact: the project will involve the “clearing 43.1 hectares of native forest vegetation, 0.55 ha of which is identified as the threatened ecological community Subtropical coastal floodplain forest (NR117)”. The clearing will result in serious and irreversible environmental impacts at both local and regional scales. The proposed development site supports unique biodiversity including 17 threatened birds and 9 threatened mammals, including 7 vulnerable bats. The native vegetation on site should be retained to combat Australia’s abysmal record of extinction of plants and animals. (Ref. https://www.environment.nsw.gov.au/topics/animals-and-plants/native-vegetation/why-is-native-vegetation-important).

- Inadequate biodiversity offset: The proposed offset site is a mere 49 hectares - not even a 2:1 offset, as required by most projects, particularly those that involve tree planting. Furthermore, of the vegetation associations identified in the project area, two are not included in the proposed offset area and an inadequate amount of a third (Tallowwood -Small-fruited Grey Gum dry grassy open forest). The loss of hollow-bearing trees is another concern – it takes 75-100 years for a eucalypt to form a hollow. I note that most of the hollow bearing trees recorded in the Biodiversity Assessment Report occur in the Spotted Gum - Grey Ironbark open forest – this association does not occur in the proposed offset area. Furthermore, I note that no hollow-bearing trees were recorded in the proposed offset area and there is no mention of the provision of nest boxes as part of the proposed offset strategy.

- Recently emerged need to consider biodiversity loss (recent and now predicted with increasing bushfires): The recent catastrophic bushfires in NSW have resulted in the loss of hundreds of thousands of hectares of bushland habitat and hundreds of koalas. Injured and now homeless koalas may migrate to, or have to be moved onto, the proposed development site. It is unbelievable that proponent wishes to clear a viable patch of intact koala habitat when so much habitat in the region has been recently lost to fire. The Greater Sancrox Area Structure Plan (Port Macquarie Hastings Council, 2014), identifies the land to be cleared as medium to high activity koala habitat. More recently the Draft Coastal Koala Plan of Management 2018 (CKPOM) produced by PMHC identifies the area as core koala habitat. The clearing also destroys an identified critical link needed to maintain vegetation connectivity for animal movement.

- local hydrology: The proposed development will also affect the local hydrology. In a time of drought it is disgusting that the local watercourse that currently supports native flora and fauna will be diverted to industrial use. Our local council also noted the concern that the expansion would potentially jeopardise our water security via pollution, a real risk given the proposing company has a history of breaching environmental legislation.

- cultural impacts: Furthermore, there will also be an impact on Aboriginal heritage sites, including a Scar Tree and ceremonial site of “high cultural significance.” (Annex D, Heritage Report).

- Noise pollution: The Port Macquarie region is expanding rapidly. The quarry development is approximately 6km west of Port Macquarie, which is undergoing significant residential development that will be directly affected by the increased noise of the proposed quarry expansion. The Sancrox area has already had a substantial increase in noise (24/7), due to the upgrading of the highway to a motorway. Despite noise mitigation measures, the rural ambience is already reduced and any extra noise generation, especially at night, will only make it worse. The noise impact of a 24 hour, 7 days a week operation is particularly concerning. There will be no respite from constant noisy plant and equipment.

- exacerbation ofclimate change: ‘over its entire life cycle is estimated to release approximately 48.4 million tonnes of CO2-e into the atmosphere’ – 2.5 million tonnes less than Sweden’s total emissions in 2017 (https://en.wikipedia.org/wiki/List_of_countries_by_carbon_dioxide_emissions). It is unacceptable that the proponent seeks to contribute greenhouse gas emissions to the atmosphere equivalent to those of an entire country at a time when the planet is warming, and the effects of climate change are affecting all life on earth. Around the world people are working to combat climate change, yet this project will counteract the efforts of others.Projects contributing such emissions are increasingly finding it difficult to be insured.

- history of breaching environmental conditions: Hanson Construction Materials Pty Ltd were fined $15,000 in 2016 for breaching the conditions of its Environment Protection Licence at the Sancrox Quarry. It is unacceptable that the NSW Government is considering a proposal from a company with an existing record of environmental breaches. (Ref: www.epa.nsw.gov.au/news/media-releases/2016/epamedia16032401).

On these basis I formally lodge my objection to the proposed development.

I have not included a discussion of alternative ways to achieve the short term economic benefits the project is projected to create. I am happy to do so if wanted.

Please do feel free to contact me regarding this submission.

Regards,

Rachel Sheppard

As a landholder in the Hastings, I urge you to reject the proposed Sancrox Quarry expansion.

Our region has recently suffered devastating fires coupled with drought, and hundreds of thousands of hectares of forest have been burnt. While fire is an integral part of the Australian landscape, the scale and extent of these fires is unprecedented, and threatens a permanently altered ecosystem in the years to come. Collapsing biodiversity, loss of topsoils, diminished water retention leading to increased fire risk, aridity and poor water quality, dwindling pollination and succession are just a few of the consequence we face.
Any unburnt areas of native vegetation are now vitally important in providing a refuge to wildlife including critically endangered species under even greater pressure. They are also a source of seeds and spores, and provide support for the seed dispersing fauna that will spread them over the landscape, in the hope that the forest ecosystems might recover over time.

VEGETATION CLEARING: The proposed Sancrox Quarry Expansion will involve the ‘clearing 43.1 hectares of native forest vegetation, 0.55 ha of which is identified as the threatened ecological community Subtropical Coastal Floodplain Forest (NR117)’. The clearing will result in serious and irreversible environmental impacts at both local and regional scales.

According to the Biodiversity report:
‘Approximately 44ha (44%) native vegetation will remain within the inner assessment circle after clearing for the proposed development and around 411ha (41%) of native vegetation will remain in the outer assessment circle after development’

One can therefore conclude that 56% of native vegetation within a 100ha buffer of the centroid of the project area and 59% of vegetation within a 1000ha buffer of the centroid of the project area will be cleared. The Biodiversity Report has not considered the cumulative impact of vegetation clearance within a regional context and the continued fragmentation of remaining vegetation across the landscape.

OFFSET: The proposed offset for this project will be secured either through purchasing and retirement of 2,449 ecosystem credits from the credit market (with some ecosystem credits to be generated by potential offset lands within the study area) or payment of an equivalent monetary value into the recently established Biodiversity Conservation Fund.
An offset area of land will NOT provide the critically important ecosystem services that are needed in this time: the land must be in proximity to the burnt sites. A payment to a Biodiversity fund will NOT reseed and repopulate our lands.

I urge you to suspend vegetation-clearing development projects such as the Sancrox Quarry Expansion and forestry operations until such time as the drought breaks and clear signs of broad scale ecosystem recovery are seen.

Attn: Director – Coal and Quarry Assessments


Dear Sirs.
Re: Sancrox Quarry Expansion Project
State Significant Development application number SSD-7293

1. I own land on Le Clos Verdun Estate which is a 142 lotrural residential subdivision located at Sancrox Road, Sancrox within the Port Macquarie Hastings Local Government area (“Sancrox Estate”).

2. Sancrox Estate is itself a State Significant Development with application number MP06_0212.Sancrox Estate is now currently under development and construction.

3. The purpose of this letter is to express my opposition to the State Significant Development application number SSD-7293 lodged by Hanson Construction Materials Pty Ltd (the “Application”), for the expansion and development of the hard rock quarry known as Sancrox Quarry, that is located on Sancrox Road, Sancrox, and in close proximity to the Sancrox Estate.

4. Relevantly the Application proposes that the current 20 year life of the Sancrox Quarry be extended by 30 years by:

a) expanding the quarry footprint from an existing size of 17.18 ha to 48.61ha, being a 182% increase in the existing foot print of the quarry;

b) increasing the annual extraction limit from 455,000 tonnes per annum to 750,000tpa, representing at 65% increase on the current annual extraction limit of the quarry;

c) building a new concrete batching plant, with a 20,000tpa capacity, to operate 365 days a yearfrom the site of Sancrox Quarry;

d) building an new asphalt production plant, with a 50,000tpa capacity, to operate 365 days a year from the site of the Sancrox Quary;

e) building a concrete new recycling plant, with a 20,000tpa capacity, to operate 365 days a yearfrom the site of the Sancrox Quarry;

f) changing the current approved hours of operation of the Sancrox Quarry from 7am to 5pm Monday to Friday, and 7am to 1pm on Saturdays, to a 24 hours a day, 7 days a week, 365 days a year;

g) changing approved truck movements and equipment hours of operation from 7am to 11pm Monday to Friday and 7am to 1pm Saturday, Sundays and Public Holidays, to 24 hours, 7 days a week, 365 days a year; and

h) allowing for blasting to take place from 8am to 5pm Monday to Friday.

(the “Project”)
Opposition to the Project
5. I oppose the Project on the following grounds.

a) Failure to adequately recognise Surrounding Land Use

The Environmental Impact Statement (“EIS”)lodged in support of the Project completely fails to address the potential impact of the Project onthe 142 rural residential housing lots being developed at Sancrox Estate.

As far as I can tell, the only reference to the Sancrox Estate contained in the EIS is that a “rural residential residence is located approximately 1km to the west” (see part 14.2.1 of the EIS) which I presume is a reference to the Sancrox Estate, however the EIS otherwise contains absolutely no direct reference to the Sancrox Estate.

Further, Part E.3 of the EIS states that the “quarry is ideally located away from substantial residential development”. However given that 142 rural residential Sancrox Estate development is presently only 1km to the West of the existing quarry, any suggestion that the “quarry is ideally located away from substantial residential development” is plainly false and misleading.
The EIS also does not identify how close the Project and quarry boundary will be to the boundary of Sancrox Estate, should the Project go ahead. The Project proposes that the footprint of the quarry be extended by 31.43ha. Based on the information contained in the EIS, it appears that should the Project go ahead, the boundary of the Project/ quarry will be about 500 meters from the boundary of the Sancrox Estate.
I consider that by failing to directly identify or address the impact the Project will have on the142 residential homes to be built at SancroxEstate, the EIS is deficient and fails to adequately address the Project’s compatibility with other land uses in the vicinity of the Project in accordance with clause 12 of the State Environment Planning Policy (Mining, Petroleum Production and Extractive Industries) 2007 Act.

On this basis the Application should be refused.

b) Scale of the Project

The scale of the Project is vast. The quarry footprint to be increased by 182%. Its extraction limit to be increased by 65%. It will no longer just be a mine, but will offer additional concreate batching, recycling and asphalt production services. Its hours of operation will be 24 hours, 7 days, 365 days a year, resulting in an enormous increase in the volume of traffic associated with the mine.

The EIS attempts to address each of these matters as a separate issue, however considering these matters separately is not a proper assessment of the effect they will have on the environment. These matters must be viewed collectively and the impact they will have on the environment should be considered to becumulative. When viewed collectively and cumulatively, it is apparent that the impact of these matters on the environment and surrounding areas will be far more significant that the EIS would indicate.

c) Impact on environment

The Project will require the clearing of 43.1 ha of native forest vegetation, including habitat for at least one threatened species. (EIS part E.6). While the EIS identifies a “preferred offset strategy” of “ecosystem credits”, I consider that this strategy is grossly inadequate and will never truly serve as a replacement of the flora and fauna that the Project proposes to destroy.

I consider that the destruction of 43.1ha of native vegetation including habitat for least one threatened species, purely for the commercial benefit of the privately owned Hanson Construction Materials Pty Ltd, is a matter that needs serious consideration when determining whether approval should be granted to the Project.

I disagree that “significant public benefit will be provided by the alteration [ie destruction] of this currently unutilised land [ie 43.1ha of native vegetation including habitat for at least one endangered species] by the Project, with a longer term, reliable supply of rock for local development projects becoming available” (EIS part E.10).

Equivalent sources of rock are readily available to the public from sources other than Hanson. The Project (and the destruction of the 43.1ha of native vegetation) will not benefit the public, whereas the same cannot be said for Hanson’s shareholders.

Any public benefit will be significantly outweighed by the detriment that the environment will suffer as a result of the destruction of the 43.1ha of native vegetation proposed by the Project.

As I write vast swaths of the State of NSW, and national parks, burn in unprecedented bush fires. As such I consider that any suggestion that the public will benefit from the destruction of 43.1ha of native vegetation including habitat for at least one endangered species, for the commercial benefit of a private company, needs to be view with great scepticism.

Further the Biodiversity Assessment Report prepared in support of the Application was based on insufficient and outdated field work conducted in 2015. Current, independent and comprehensive field surveys are required to validate the finding in the Biodiversity Assessment Report.

For the above reasons the Application should be refused.

d) Misrepresented on the NSW online Planning Portal

The location of the Project is grossly misrepresented on the NSW online Planning Portal, which represents that the Project is to be located on Peats Ridge Road, west of Gosford, when in fact the Project is actually located approximately 315km north of Gosford, on Sancrox Road being approximately 8km west of Port Macquarie.

The misrepresentation of the location of the Project on the NSW online Planning Portal means that the Application has not followed due process and will not be coming to the attention of persons who will be potentially effected by the Project.

On this basis the Application should be refused.

e) Noise impact

The noise impact of a 24 hour, 7 day a week open cut mine will be substantial. The Sancroxarea has already had a substantial increase in noise (24/7), due to the upgrading of the pacific highway to a motorway.

Those noise impacts are all the more noticeable, and intrusive at night.

On the basis that the Application seeks that the Project be operated 24 hours a day, 365 days a year, the Application should be refused.

f) Misrepresentations contained in the EIS

The EIS does not properly address issues affecting the determination of the Application and in fact appears to ignore and/or omit many factors that should properly have been addressed. Further the EIS contains several statements that Iconsider to be inaccurate. Instances of some of the inaccurate statements are as follows.

i) The EIS states that the “Project will allow for the sourcing of construction materials to be produced at a site that is highly disturbed”. This statement is false as the Project requires the destruction of 43.1ha of native vegetation including habitat for at least one endangered species.

ii) No mention is made of the fact that there is an Endangered biological corridor (identified in 2015) which runs right through the middle of the proposed new quarry pit nor of the fact that the new pit will wipe out a “high and medium use” koala habitat as well as destroy significant swamp oak and eucalypt open forest areas which include several ecologically sensitive hollow bearing trees.

iii) The traffic study in the EIS is defective and fails to accurately and honestly record the traffic to be generated by the development of the areas surrounding the Project, which have already been approved for development, such as the Sancrox Estate.

Conclusion

For the reasons set out above, I object to the Application, and consider that it should properly be refused.

I OBJECT to the Project and provide a response in the document attached herein.

DPIE Crown Lands has no comments for this proposal.