Sancrox Quarry Expansion Project

My objection to the proposal is on the grounds listed in ticked boxes below:

The Port Macquarie region is expanding rapidly. This development is in the Sancrox area, approximately 6km west of Port Macquarie, which is undergoing significant residential development that will be directly affected by the increased environmental impact of this 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 proposed ‘quarry expansion’ is more than that! It also includes two new additional operations, concrete batching and asphalt production. There are already other concrete and asphalt plants in the region that have the capacity to service the demand.

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. Daytime operation excluding Sundays is the maximum that should be allowed in a community precinct. The processes carried out do not have to run at night and can be easily shutdown/restarted.

The project includes “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)” with serious and irreversible environmental impact. (Ref: DA, Annex C)

During November 2019 a State of Emergency was declared in NSW due to the catastrophic bushfires. Hundreds of koalas may have been killed. Injured and now homeless koalas may migrate to, or have to be moved onto, the proposed development site.

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.

Insufficient field work was conducted in 2015, four years ago. A major flaw of the EIS is that it fails to record koalas at six locations and the presence of habitat critical to the endangered Swift Parrot. (Refs: Office of Environment and Heritage Records, 2008 -2013; Ref. DA Annex C)

The environmental impact is serious and irreversible. The proposed development site supports unique biodiversity with a total of 27 threatened species identified so far, including 17 birds and 9 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 in Australia. (Ref. https://www.environment.nsw.gov.au/topics/animals-and-plants/native-vegetation/why-is-native-vegetation-important)

Proposed “Ecosystem credits” system of payment by the developer to offset destruction of threatened species does not compensate for the serious and irreversible impact on the natural environment.

Native vegetation in NSW stores a significant amount of carbon. This deforestation and forest degradation will contribute to global greenhouse gas emissions and fewer trees in a region can contribute to drought by reducing the amount of local rainfall.

The natural water on the site, currently supporting native flora and fauna, will be diverted to industrial use and North and west alluvial flood plains of the Hastings River and Haydons Creek will be impacted.

The company operating this site has a poor track record of environmental compliance and were fined $15,000 by the Environmental Protection Authority in 2016 for breaches of their water management operational obligations. (Ref: EPA 24.03.2016).

The proposed works impact Aboriginal heritage sites, including a Scar Tree and ceremonial site of “high cultural significance.” (Ref: Annex D, Heritage Report)

Increased 24/7 heavy vehicle movements on the light duty local roads will compromise road safety and accelerate pavement failure.

I wish to object to the expansion of the Sancrox Quarry Expansion as it will further impact on the ever decreasing Koala habitat, which has been deemed viable habitat by the Port Macquarie City Council. With recent bushfires decimating large areas of Koala habitat it is imperative that any remaining areas are saved from development.

My name is Athena Baldwin. I am a resident of the Port Macquarie Hastings LGA.
I wish to formally object to the proposed Sancrox Quarry Expansion project based on the following:
Loss of Koala Habitat
The catastrophic bushfires of November 2019 in NSW, and in this LGA specifically, have resulted in the loss of hundreds of thousands of hectares of bushland. The local koala population has been severely affected by loss of habitat, as well a huge loss of life. It is beyond belief that the proponent wishes to raze a viable patch of intact koala habitat when so much in the region has been recently lost to fire.
The Greater Sancrox Structure Plan (Port Macquarie Hastings Council, 2014), identifies a portion of the land to be cleared as medium to high activity koala habitat. The Urban Growth Management Strategy 2017-2036(PMHC 2017) classifies the area as a ‘medium biodiversity asset/constraint’ and identifies that the site could provide a ‘major conceptual habitat link’. The Draft Coastal Koala Plan of Management 2018 (CKPOM) produced by Port Macquarie Hastings Council identifies the area as core koala habitat.
Clearing also destroys an identified critical link needed to maintain vegetation connectivity for animal movement. The proposed Sancrox Quarry Expansion will involve ‘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.
Koalas are already at risk of functional extinction. Offsetting does not increase populations. The offset 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. Offsetting at a State level via payment into a fund has several issues:
1. Genetic diversity: the importance of different genomes for koalas is widely understood for disease resistance. Removal of koala habitat, and its impact on local populations already decimated by the November 2019 bushfires, results in a failure to protect genomes in areas of high development pressure.
2. Community Value: Our community greatly values its koala population and does not want to see them offset away from the Port-Macquarie Hastings region.
The proposed offset site is a mere 49 hectares. Of the vegetation associations identified in the project area, two are not included in the proposed offset area. According to the Biodiversity Assessment ‘there are stands of Swamp Mahogany swamp forest and paperbark swamp forest in the proposed offset site, however no such vegetation occurs within the Development Site’. Within the Port Macquarie Hastings LGA paperbark is not considered a primary or secondary koala food tree species (https://www.savethekoala.com/…/20150212_AKF_National_Koala_…)
The removal of Spotted Gum (winter flowering), Grey Ironbark (winter, spring and summer flowering), Blackbutt (spring - summer flowering) and Pink Bloodwood (summer - autumn flowering) species from the local area will result in the loss of crucial winter and autumn flowering species. Paying into a fund will not compensate the fauna of the local area for the loss of valuable feed species.

Loss of Hollow-Bearing Trees
The loss of hollow-bearing trees is another concern – it takes approximately 75-100 years for a eucalypt to form a hollow. The majority of 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, 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.

Past EPA Breach by the Proponent
The Proponent - Hanson Construction Materials Pty Ltd was 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 even considering a proposal from a company with an existing record of environmental breaches at the site in question. (Ref: www.epa.nsw.gov.au/news/media-releases/2016/epamedia16032401).

This is a timely opportunity for the NSW state government to show leadership by listening to, and acting on, the concerns of communities who are feeling ignored and unheard. Please put the needs and interests of our local region before those of the proponent.
Yours sincerely,

Athena Baldwin

I live with my daughter approximately 10km from the proposed expansion site and would like to object to this project going ahead.
Noise and vibration can easily travel that distance when blasting in the quarry and the dust and particles that will be carried on the wind are not conducive to a healthy environment. The dust and particles will create more breathing difficulties for people suffering with breathing issues, asthma and bronchitis.
With the recent bushfires, the land which is to be cleared is a crucial wildlife habitat for koalas that have been decimated along with other animals and their habitat in the surrounding area within 10 - 20km and further afield. Clearing of trees, hollowed trees and vegetation is pushing koalas, snakes, lizards, flying foxes and many other species towards extinction with habitat destruction, we will leave our children with nothing.
I also worry about the increased truck traffic using the site and potential for more fatal accidents in the area.

I strongly object to the Sancrox Quarry Expansion Project. I am the owner of Lot 31 within the Le Close Sancrox Estate. My land is located proximate to the proposed new Sancrox quarry.
The Hanson Environmental Impact Statement (EIS) which was on exhibition fails to address issues as listed below.

Myths Being Perpetrated
1. The proposed Sancrox quarry is an expansion project. More accurately, it is an application for a new quarry.
2. There are no other supplies of rock in the area, or a quarry within 200km; More Accurately there are ample Reserves closer at Bago 20 km from Sancrox and there are several Hanson competitors with local operating quarries.
3. Hanson doesn’t own other resources in the area. More Accurately it does. Their Lot 2 DP 814356 at Milligans Road, Bago contains high quality rhyolite daicite.
Further
1. A core koala habitat at” high use” level exists in the centre of the proposed new quarry. Even now more than ever after the bushfires here we need to protect this.
2. An endangered biological community corridor runs right through the centre of the proposed new pit location.
3. 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?
4. The new Sancrox quarry project will fragment and alienate land and result in conflict with adjoining land uses.
5. The quarry is not ideally situated. In every direction over the range of 300m – 1,300m, there is residential development.
Omissions from the EIS
1. No mention is made of there 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 the impact upon the Billabong Koala Sanctuary less than 1 km from the pit.
4. 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.
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. The current freedom of movement of local residents may be impacted twice daily, from blasting.
5. 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. There may well be better local resources available to Hanson at DP814356 Milligans Rd, Bago to meet the Regional need other than the proposed “new” quarry at Sancrox.
All development in the growth corridor west of Port Macquarie and toward Wauchope is
important both to the local area and to the state. The community need for good quality
quarry material must be in balance with the social and economic costs of its extraction. It is
important that the approval processes at every level of Government be rigorously applied to
ensure right balance.
My land is part of an estate of some 51 Lots of approximately 2 Ha each. All Lot owners have
combined to make an application to the Port Macquarie Hasting Council, at their request, to
rezone the land from Rural to Residential. 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 industrial and residential community and, as well, a sensitive ecological zone.
I trust the approval processes standards being applied at every level of government are
rigorous, fair and balanced, and in particular that you look into the matter of Application SSD
9946 to validate that it actually meets the criteria of State Significant Development, and if it
does that the appropriate mitigation measures are established and an application review
mechanism at Hanson cost, that involves the impacted community is established for life of
quarry .
I look forward to your response to my submission

My name is Joshua Arthur, I live Port Macquarie, I work as a Heavy Diesel Fitter, Who loves getting out and camping around the local area.

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

Impacts on the Biodiversity Corridor
Project area falls directly within a sub-regional biodiversity corridor. It is absurd to suggest that the loss of vegetation in the project area will not result in habitat fragmentation or the loss of connectivity between the proposed offset area and the remaining vegetation south of the project area. The figures in Appendix E of the Biodiversity Assessment are incomplete – widths are missing, and they seem to suggest that Connecting Link 2 will persist despite the clearance of all vegetation and the presence of machinery. The removal of the vegetation in the project area will effectively isolate fauna that remain in the proposed offset area and the disconnection the offset area will greatly reduce its ecological viability.

Noise
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 environmental impact 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.

Past EPA Breach
The Proponent - 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 even considering a proposal from a company with an existing record of environmental breaches at the site in question.. (Ref: www.epa.nsw.gov.au/news/media-releases/2016/epamedia16032401).

Impacts on Water System and Aboriginal Heritage
The proposed development will also affect the local water system. In a time of drought it is unacceptable that the local watercourse that currently supports native flora and fauna will be diverted to industrial use. PMHC councilors have also noted possible risk to local water security if pollution from the project were to enter the water supply that has been carefully planned over decades. Furthermore, there will also be an impact on Aboriginal heritage sites, including a Scar Tree and ceremonial site of “high cultural significance.” (Ref: Annex D, Heritage Report).

Don’t let another industry destroy our beautiful local environment!

My name is Pat Clayton and I live in the Le Clos estate only Sancrox. I am against the development of the quarry at Sancrox. We are already experiencing extra noise and traffic on Sancrox Road with the new industrial area being built, Sancrox Road has a large number of pot holes and two low level bridges which barely handle the current traffic let alone more trucks. The extra blasting and 24 hour working in the quarry is totally unexceptionable for the local residents who have built in this area. There will extra dust and dirt from the 24 hour works. The trees around the quarry have already be bulldozed so now the quarry is fully exposed from the highway ( you could not see it before) so already we have lost Koala habitat.

Pls see attached submission.

Thank you for the opportunity to write and put forward our significant concerns and thus objection to the proposed quarry development at Sancrox.
This development proposal has so far attempted to fly under the radar for local residents. Proper consultation and acknowledgment of the impacts of the development is required and we call for the rejection of the proposal in its current form. Objective actions and penalties also need to be considered as it is significantly lacking in this submission.
We reject the proposal on the following grounds
1. Groundwater
a. This is one of the most concerning aspects to this proposal. We hold a bore licence which has not been taken into account. We are located in the Southern aspect of the modelling area with the greatest modelled drawdown (and greater than the acceptable drawdown considerations). Our property is also elevated, with a shared Byabbara aquafer bed with the mine, thorough the same fracture network. We are at a very high risk of impact, including drawdown of 3 to 7 metres or even more. Our basic water right is to be impacted. The response to “make good” is insufficient and concerning. Would the company pay for replacement pumps due to a deeper bore being needed? Would they pay for incremental electricity costs for the next 30 years due to a greater pump and head being required? How would residents achieve this commitment (through the courts if Hansen declined to come to the table)? Their “make good” as a motherhood statement is entirely insufficient. Additionally, this could have an impact on our ability to stock cattle or horses, to the point where is may also affect future property values.
b. Residents with bores need more time and more information to understand the real economic impacts to their properties and greater detail and commitment as to what the company would do to “make good”.
c. There is mention of annual reporting for groundwater impacts, but no mention of to whom that report is delivered, nor what the outcomes would mean. There are no penalties for breaching nor directions to correct the impacts.
d. There is mention that at the end of life, the quarry will be left as a “pit lake”. This is of great concern from an ecological perspective.
e. The company has a poor record of groundwater management and was fined in 2016 for breaches (ref: EPA 24.03.2016). There is a low level of trust that the company would honour “make good”.
2. Social and Economic Impact
a. The reports conclusion and discussion was based off the premise that “does not involve significant change to land uses at this location”. This is incorrect as the operations at the site would include an additional concrete batching and asphalt plant. Further operations of the site from business hours to 24 hours 7 days a week constitutes a significant change in usage. What follows is an incorrect assessment and inaccurate submission.
b. That the “efficient and cost effective delivery” is of social benefit. Rather this statement is misleading and false, as this is a business benefit to Hansen. This should be removed from consideration as to the social benefits of the proposal. Rock mining, asphalt and concrete crushing is and can be done at other sites, it is an additional service not a sole service in this area.
c. It must be noted that impact of this project is “likely to be positive…provided that the localised…negative social impacts are mitigated and monitored”, whilst there is only broad non-specific statements as to how these significant negative effects will actually be mitigated. Objective measurements must be undertaken, objective reporting and consequences for breaches must also be part of any project review for all parties. References such as “beyond control of Hansen”, “feasible and practical efforts” only demonstrate the inadequate means to which residents will be able to hold Hanson to account if/when they breach their requirements.
d. There is already poor record by the company in community consultation. Residents only found out about this by another residents letterbox drop. Hansen was not proactive or open about the plans. Submission time frames have been quick and does not allow residents proper scrutiny or response to the 1500+ page report. A proper consultation process should begin and submission time frames restarted. If this is the beginning of the process, Hansen have already demonstrated their contempt for the local residents and there is concern that they will only continue with this degree of engagement during the construction and into the future mine site.
e. 24 hour operation should be absolutely rejected, these processes do not need to run throughout the night.
3. Truck movements
a. There is a significant 24 hour a day increase in movement of trucks to almost 800 per day. This will have an incredible impact on the safety of Sancrox Road, and also push more local traffic to other local roads to avoid this heavy vehicle bottleneck. Data obtained for this report is inaccurate or old, given accident along Bushland Drive in 2019 was not in place. Not only will this have a safety impact as there is an increased population in Sancrox (which was NOT modelled properly), but it will have a cumulative noise impact in the entire area.
4. Fauna
a. Loss of a large amount of bushland is concerning. As veterinary scientists we can say that the ecological study was basic at best a few years ago, with rather dubious and brief techniques for survey. This is what Hansen has relied on to indicate the loss of bush is acceptable.
b. Given the extent of bush loss recently with fires and extreme koala population pressure, bush such as this should be retained for potential resettlement.
c. There is no analysis of light and noise pollution impact on fauna. This should be properly studied and understood. There is a small but viable Powerful owl population locally , for example, that may be impacted with hunting in the area.
d. Bush in this area provides a corridor for travel and not just for accommodation.
5. Noise Impacts
a. As stated in the report, this is a rural area. The area has a quiet disposition, with some impact of the highway. The highway is sporadic (NOT constant), and thus having another sporadic or even constant noise emission is of great significance. This cumulative effect cannot be misunderstood. This will become a 24/7 noise source with the only requirement that Hansen laughably “procure quietest machinery”, but as long as it still fulfils the machine function. This is a ridiculous and insulting mitigation strategy and only speaks to the lack of accountability to the residents should noise levels be breached.
b. Residents do not have complex or expensive monitoring equipment to be able to test and monitor noise emissions. Equipment should be supplied to residents and reports made public with strict penalties to exceeding acceptable levels.
c. Comment that cumulative noise levels are “beyond control of Hansen” is not true. If Hansen is contributing to the cumulative noise, then they are totally in control of the overall output. This should be corrected and refactored in control strategies prior to any further consideration.
d. According to the submission noise levels are going to exceed acceptable levels for properties South of the mine. This alone is enough to reject the proposal.
e. Report only indicated maximum background noise. It is possible that the noises were made from bird calls. It should be reported as to the cause of the peaks of the noises recorded. There is a significant difference between rural animal noises and mining activity, thus all noise cannot be treated equally.
f. Truck activity broadly will increase and along with it noise, thus there is 796 truck activities adding to the overall sound scape in the local area and along the highway, 24 hours a day.
g. It is entirely inadequate for the mitigation strategy to for the impact of noise pollution to “reduce by feasible and reasonable measures”. This is another example of unenforceable control measures plaguing this report and submission. Residents need a much greater objective understanding of the measures and fallbacks for this project prior to any further consideration.
h. Noise impacts only considered the “average person” and has not taken into account the noise (and light) impact on local animals, including nestings, breeding, hunting.
i. Adoption of sleep disturbance levels is high and over exaggerated given rural nature of the area. This should be refactored and reassessed.
j. We find that identified sleep disturbance levels south of the site for 12 months an incredible admission. This is a very long time and is totally unacceptable.
k. Controls and mitigations such as “Good practice construction necessary”, such that “ICNG focuses on minimising noise impacts rather than achieving numeric noise levels” is inadequate.
l. Findings “noise emissions would exceed the PSNL during all modelled conditions” excluding the additional cumulative road noise from trucks at 792 movements a day should mean rejection of the proposal.
m. Admission and context that “noise from construction sites is inevitable” provides an automatic “out” for any noise pollution at any time with no recourse.

There has been inadequate time to fully assess the submission and we call for rejection of the proposal. There is overstated and minimal employment benefits for what is an unnecessary 24 hour a day development with wide ranging environmental and social impacts.
Thank you for the opportunity to submit our concerns and look forward to being engaged properly in this process.

See attached

08th December, 2019
I am a local resident in Sancrox New South Wales,
I wish to make a formal objection to the proposed Sancrox Quarry Expansion.
The catastrophic bushfires in NSW recently 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. Most of the Eastern side of the Motorway has recently been cleared opposite the Quarry and the Bushfires have destroyed what was left.

The Greater Sancrox Structure Plan (Port Macquarie Hastings Council, 2014), identifies a portion of the land to be cleared as medium to high activity koala habitat. The Urban Growth Management Strategy 2017-2036(PMHC 2017) classifies the area as a ‘medium biodiversity asset/constraint’ and identifies that the site could provide a ‘major conceptual habitat link’. 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.

The Project area falls directly within a sub-regional biodiversity corridor. It is absurd to suggest that the loss of vegetation in the project area will not result in habitat fragmentation or the loss of connectivity between the proposed offset area and the remaining vegetation south of the project area. The figures in Appendix E of the Biodiversity Assessment are incomplete – widths are missing, and they seem to suggest that Connecting Link 2 will persist despite the clearance of all vegetation and the presence of machinery. The removal of the vegetation in the project area will effectively isolate fauna that remain in the proposed offset area and the disconnection the offset area will greatly reduce its ecological viability.

The project ‘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/.../List_of_countries_by_carbon...). 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. Port Macquarie Hastings Mayor has publicly acknowledged the grave costs that climate change poses to our community, including its link to the bushfires we face. This quarry undermines any action our community take to adapt to and mitigate climate change for our community health, safety and sustainable economic prosperity into the future.

The loss of hollow-bearing trees is another concern – it takes 75-100 years for a eucalypt to form a hollow. The majority of 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, 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.

The proposed development will also affect the local water system. In a time of drought it is unacceptable that the local watercourse that currently supports native flora and fauna will be diverted to industrial use. PMHC councilors have also noted possible risk to local water security if pollution from the project were to enter the water supply that has been carefully planned over decades. Furthermore, there will also be an impact on Aboriginal heritage sites, including a Scar Tree and ceremonial site of “high cultural significance.” (Ref: Annex D, Heritage Report).

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 environmental impact of the proposed quarry expansion. The Sancrox area where we live 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, the noise travels at night and the local residents will be impacted by this.

Thank you

Re: Public Submission for SSD – 7293, Sancrox Quarry Expansion Project

Thank you for the opportunity to comment on the development proposal.
I wish to formally object to the Sancrox Quarry Expansion project on the following grounds:
1. Vegetation clearance and fragmentation
- According to the EIS, the project will result in the:
• clearing of 43.1 ha of native forest vegetation, which includes 0.55 ha of the Subtropical coastal floodplain forest Threatened Ecological Community;
• loss of hollow-bearing trees, some of which may provide potential roost sites and breeding habitat for a selection of bird, arboreal mammal, reptile and microchiropteran bat species; and
• removal of foraging habitat for locally occurring native fauna, in particular for threatened microchiropteran bats species, ground mammals, arboreal mammals and a range of bird species.
- The project will result in loss of koala habitat and corridors at a time when the local population is threatened with extinction. Extra truck movements and road building will further alienate koalas from their corridors and cause roadkill.
- Grossly inadequate and unsuitable biodiversity offsets are suggested, particularly relating to koala habitat. Offset plantings are not acceptable as compensation for koala habitat clearing. “Like for like” offset – i.e. mature trees of the same vegetation species composition, capable of sustaining live adult koalas today, must be achieved before the project is approved.
2. Carbon dioxide emissions
- the project ‘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.
3. Local Economic Impacts due to threatening processes to Koalas

Please find the details of my objection in the attached PDF document

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

**Specific issues relating to Loss of Koala habitat
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 Structure Plan (Port Macquarie Hastings Council, 2014), identifies a portion of the the land to be cleared as medium to high activity koala habitat. The Urban Growth Management Strategy 2017-2036(PMHC 2017) classifies the area as a ‘medium biodiversity asset/constraint’ and identifies that the site could provide a ‘major conceptual habitat link’. 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.

**Impacts on the Biodiversity Corridor
Project area falls directly within a sub-regional biodiversity corridor. It is absurd to suggest that the loss of vegetation in the project area will not result in habitat fragmentation or the loss of connectivity between the proposed offset area and the remaining vegetation south of the project area. The figures in Appendix E of the Biodiversity Assessment are incomplete – widths are missing, and they seem to suggest that Connecting Link 2 will persist despite the clearance of all vegetation and the presence of machinery. The removal of the vegetation in the project area will effectively isolate fauna that remain in the proposed offset area and the disconnection the offset area will greatly reduce its ecological viability.

**Past EPA Breach
The Proponent - 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 even considering a proposal from a company with an existing record of environmental breaches at the site in question.. (Ref: www.epa.nsw.gov.au/news/media-releases/2016/epamedia16032401).

**Loss of Hollow-Bearing Trees
The loss of hollow-bearing trees is another concern – it takes 75-100 years for a eucalypt to form a hollow. The majority of 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, 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.

**Impacts on Water System and Aboriginal Heritage
The proposed development will also affect the local water system. In a time of drought it is unacceptable that the local watercourse that currently supports native flora and fauna will be diverted to industrial use. PMHC councilors have also noted possible risk to local water security if pollution from the project were to enter the water supply that has been carefully planned over decades. Furthermore, there will also be an impact on Aboriginal heritage sites, including a Scar Tree and ceremonial site of “high cultural significance.” (Ref: Annex D, Heritage Report).

**Noise
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 environmental impact 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.

**Viable Alternatives to the Quarry
Rather than quarry road base materials, a better option is to utiilse plastic bags, recycled glass and printer toner in the construction of new roads. Following China’s ban on foreign waste imports in 2018, Australia now has a glut of recyclables of which only a small fraction is repurposed. Through crushing glass back into sand, it is possible repurpose not only glass bottles and jars, but also plate glass, drinking ware, crockery and Pyrex into road base. As well as ensuring more glass can be recycled, transforming glass back into sand reduces the need to mine virgin material for road base and asphalt, decreasing road resealing costs and limiting truck movements on the road. Making road base and fill material from recycled products, rather than mining virgin materials, uses considerably less energy and water, and creates less air pollution.
Some examples include:
* • Downer’s $5million asphalt plant in Teralba, NSW - produces thousands of tonnes each year of sustainable road and pavement materials for the Hunter Region and Central Coast (https://www.lakemac.com.au/…/06/05/green-means-go-for-5m-pl…)
* • Northern Rivers Waste - the first road containing glass sand was constructed in June 2015 at Numulgi and they now use glass sand in much of their road base (https://www.northernriverswaste.com.au/cp_themes/…/page.asp…)
* • Hume City Council (Victoria) - in 2018 soft plastics from approximately 200,000 plastic bags and packaging, and 63,000 glass bottle equivalents were diverted from landfill to construct a Victorian road in an Australian-first trial (https://www.hume.vic.gov.au/…/Road_built_with_plastic_bags_…)
* • Tasmania – in 2018 a Tasmanian council used thousands of recycled glass bottles and plastic bags to build a road south of Hobart (https://mobile.abc.net.au/…/new-plastic-composite-…/10602294)
* • Sutherland Shire Council NSW - in 2018 a 250-metre long section was the first in NSW to be made out of plastic bags and glass in a trial of a cutting edge technology that could help tackle Australia’s waste crisis (https://www.smh.com.au/…/plastic-and-glass-road-that-could-…)

**IN DEPTH BACKGROUND FOR YOUR INFORMATION REGARDING KOALA HABITAT
In NSW, the Biodiversity Assessment Method (BAM) is the standard method used by accredited assessors to assesses impacts on biodiversity at development sites. Under the BAM, koalas are currently an ‘Ecosystem Credit Species’. This means that they can be offset in any compatible ecosystem**.
Native Vegetation Clearance
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. This project is yet another example of how biodiversity in the region is suffering ‘death by 1000 cuts’.

Threatened Species and Koala Activity
Seven threatened bat species were detected in the fauna survey and an additional 23 ‘ecosystem credit’ threatened fauna species were predicted to occur by the Biodiversity Assessment Credit Calculator. Unbelievably, however the BA Credit Calculator did not predict the Koala to occur in the area, despite the presence of PCT 1265 (Tallowwood -Small-fruited Grey Gum dry grassy open forest) – a trigger for the generation of koala ‘ecosystem credits’. Why?
In 2011 - two small areas of high koala activity were located within the development site. In 2013 - Koala scats and scratches on tree bark were recorded in the development site. As koala scats decompose over a short period of time, the presence of scats is indicative of recent Koala activity and has been incorrectly described as ‘not recent’ within the Biodiversity Assessment.

Offset Strategy and Suitability of Proposed Offset
Koalas are already at risk of functional extinction. Offsetting does not increase populations. The offset 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 offse

Whilst I do not entirely object to this project, I strongly object to it's proposed operating hours of 24/7. As a nearby resident I feel that if this quarry is approved as advertised, my peaceful lifestyle will be significantly impacted by this quarry operating around the clock seven days a week particularly with increased noise, dust, truck movements and blasting.
If approved, I believe the quarry should only be able to operate as per it's current operating hours.

I hereby lodge my Submission against SSD 7293 in the attached PDF Document, plus 1 PDF attachment.
Please acknowledge receipt of my submission in legible format before close date of 11.12.19
I request to be notified of the outcome of SSD 7293.
Thank you.

Please see attachment.

I am concerned that the environmental consequences of this development will have a significant impact on native wildlife and environment that is currently under increasing stress and range limiting developments. The corridor indicated on the plans doesn't seem to be adequately resolved with the proposed environmental offset particularly the issues of which food trees flower seasonally to our massively compromised wild life which rely on these few remnants of native flowers trees. ditto for the removal of environment habitat trees. If the season we are currently experiencing is any sign of things to come any longer term view to the future would need to consider the impact on so many rare and endangered species in this region. Is the proposed offset is adequate why is it not already loaded and if not why would it suddenly be adequate or desirable as an alternative if it is not already fully utilised. As a professional audiologist I also have concerns about the noise issues for locals as this area becomes more of a suburban populated area that will lead many I'm sure to question any decision to allow the development as Port macquarie heads to double its population according to some forecasts in the range of the life of this quarry. As we have sea to the east, national parks to the north and south it makes sense the population of port macquarie will move toward and adjacent to this proposed working quarry.

Please see letter attached

My partner Anthony McLennan and I, 30+ year Sancrox home owner and residents, are totally opposed to the Sancrox Quarry Expansion project - refer attached submission.

I object to the above development proposal, and believe that it should be rejected for reasons which include the following.
1. I own an interest in land on Riverpark Sancrox Estate, Sancrox Road, NSW 2444. This is a 142 Lot Sub-division which is currently being constructed, the eastern boundary of which is only 600 metres from the edge of the proposed new quarry pit. I believe that the Hanson Environmental Impact Statement (ERM Ref. 0418291) currently on exhibition does not properly address the issues arising from its proximity to a significant residential development. In particular noise pollution and dust, not to mention heavy vehicle traffic. All this is unacceptable, and will be severely exacerbated by the proposed 24x7 operations.
2. I also strongly object to the proposed clearing of over 43 hectares of native forest vegetation. We are in the middle of an extinctions crisis, the major contributor to which is loss of habitat. The land to be cleared is koala habitat, and especially after recent and current bushfires we cannot afford to lose more. Further, with climate change connectivity is even more important, to allow nature to adapt to global heating (and as we have seen drying) - and the proposed development interrupts critical south-north connectivity. Further, the Biodiversity Assessment Report is woefully inadequate, based as it is on inadequate field work conducted 4 years ago.
3. The proposed land-clearing will also contribute to climate change and to the reduction of local rainfall. It will also involve diversion of natural water flows for industrial use.
4. Another reason why the development should not be permitted to proceed is that it would impact on Aboriginal heritage sites, including a scar tree and ceremonial site of high cultural significance.
5. As I understand it the EIS is defective and inaccurate in a number of material respects.
• Hanson states that this application is for an extension of the existing quarry. In reality it is for a new quarry on adjacent land owned by Hanson.
• Hanson states that there are no supplies of similar rock in the area or a quarry within 200km. In fact I'm told Hanson owns land within 20km which is adjacent to a recently approved new quarry.
• Hanson states that the new quarry will not impact on any local existing and future land uses. This is manifestly false. Currently there are many houses situated within 300m to 1000m of the edge of the new quarry pit. In addition, no mention is made of the142 Lot Riverpark Sancrox Estate, the eastern edge of which is only 600m from the edge of the proposed new quarry pit. No mention either is made of the proposed new residential sub-division proposed on Le Clos Sancrox, the edge of which will be only 300m away, nor of the need for expansion of residential development being proposed by the Port Macquarie Hastings Council in the Port Macquarie to Wauchope corridor of which Le Clos Sancrox is the first part.
• 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 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. With the impact of the recent and current bush fires, as well the extensive land clearing around the State, retaining remaining Koala habitat is critically important. Further, for threatened species to be able to adapt to the impact of climate change it is critical to retain North-South wildlife corridors. This proposal would destroy that corridor. Offsets simply cannot make up for that kind of devastating impact.
• No mention is made of the fact that the corridor for the proposed East Coast High Speed Rail line runs through the new quarry pit.
• No real details have been included of mitigation measures – in fact no bund is proposed to be built to protect any development to the south (i.e. on Le Clos Sancrox). Will any proposed bund be sufficient anyway to mitigate the noise and dust?
• It is proposed that this new quarry (which includes an asphalt plant) operate 24 hours per day, 7 days per week. Hanson’s previous record of adhering to good practice operating conditions (imposed as conditions of ongoing consent) with the existing quarry is not good so how, without some remarkable change in culture, can we all be sure that any local residences will not be subjected to serious noise, vibration and dust problems bearing in mind that the new quarry is situated to the east of my land and the general prevailing wind is from the east.
In conclusion I ask that you ensure that Application SSD 7293 is assessed using proper fair and balanced approval processes and takes proper note of the overall needs of the Port Macquarie Hastings local community.