Stockton Sand Quarry Dredging

Comments attached

DPI Agriculture has nil comment

I am not opposed to this development as such, except that with the advertised numbers I cannot see that it wont impact our Aqua-fer that we and a lot of others including some public park areas, rely on.
Water is more valuable then sand, so if the water table is to be affected in any way, I cannot see how this proposal could be seriously considered.

No comments from Ausgrid.

My objection is the 15 metre below sea level depth that will result from the sand dredging component of sand mining. This proposed excavation will connect our groundwater table with the dredging pond, this connection poses an extreme risk of an uncontrolled contamination of the ground water system following any environmental spill or contamination that may occur on the site during mining and into the future as the excavation will remain when mining is complete. This is a real threat when considering the PFAS contamination from the nearby Williamtown RAAF base where our groundwater has been contaminated with PFAS chemicals. The main source of groundwater contamination has occurred through a water body excavation on the base established as a storm water buffer (known as Lake Cocheran) where the excavation connected with the water table. PFAS laden fire fighting foam used on base was washed into the lake and entered the water table. As a result we now have a 25 square kilometer contamination zone . The current environmental controls currently in place at the Fullerton Cove site must not be weakened to allow any dredging activity to be approved.

see attachment

As per attched submission

I object to the project because the resultant impacts are not known and the precautionary principle should apply.

The quarry is located in close proximity to the ‘red-zone’ affected by PFAS contamination originating from RAAF Base Williamtown. Given the uncertainty surrounding the level of risk, it would be grossly irresponsible to approve excavation well below ground and water table level (in Stages 2-6) over a 37ha site, disturbing the soil and affecting the groundwater.

The sand quarry would significantly increase heavy vehicle movements (for the next 25 years) on a road system which has a number of unsuitable single carriageway sections and which is already overloaded in some areas at peak times. The impact of this proposal on heavy vehicle traffic cannot be considered in isolation from other existing and proposed sand extraction projects relying on the same inadequate road network.

The quarry is located in close proximity to the ‘red-zone’ affected by PFAS contamination originating from RAAF Base Williamtown. Given the uncertainty surrounding the level of risk, it would be grossly irresponsible to approve excavation well below ground and water table level (in Stages 2-6) over a 37ha site, disturbing the soil and affecting the groundwater.

The project would involve a significant loss of valuable fauna habitat and other environmental damage, which would continue in perpetuity after the end of mining operations due to the large residual lake.

Along with the proposed mine at Bobs Farm – SSD 6395 this would be one of the first significant sand mines in the area to propose excavation
well below groundwater level – most of the others are either harvesting windblown sand or taking surface deposits from vegetated land with consents
typically limiting excavation to a metre or less below ground level, and above the water table. As such the proposal for ‘wet-mining’ represents a completely new and uncertain threat to the local hydrology (and ecology).

For these reasons the DA for Stockton Sand Dredging should be rejected.

On the following grounds:
1. That the section of Nelson Bay Road that is most likely to be affected has already been significantly compromised for the future. In Fern Bay the development of a retirement village appears to have limited the ability for RMS to widen the road into a dual carriageway as planned, and recently a new merge road from the Seaspray suburban development has been opened north-east of the round-about, that may also compromise the duplication and will add an unknown quantity of traffic to this already very busy road during peak periods. Adding more heavy vehicles, up to 200 per day, to this stretch of road that is already under pressure does give concerns of both congestion and safety.
2. If Cox's Lane is used to gain access to Cabbage Tree Road, it is evident that Fullerton Road would need to be completely rebuilt to acomodate heavy vehicle traffic. Fullerton Road currently requires constant maintenance at the expense of ratepayers for existing light traffic and is in a very poor condition.
3. Concerned for long term environmental impacts. Stockton Beach is already very mobile and excavating below sea-level may cause significant destabilisation of dunes. All of the Tomaree and Tilligerry peninsulars rely on this link to Newcastle and beyond.

__________EcoNetwork – Port Stephens Inc.__________
All correspondence to: Secretary PO Box 97 [email protected]
_____________________________Mob. 0422 261 057 _________________________________

9 April 2020

NSW Department of Planning Industry and Environment

OBJECTION: Stockton Sand Quarry Dredging

State Significant Development Application No SSD 9490

We have no objection to this submission being published in full, without any redaction.

About Us
EcoNetwork-Port Stephens is a grassroots community-based environmental and sustainability network comprising 26 community and environment groups and eco-businesses with a focus on sustainable planning. We are non-party political and do not donate to political parties.

Objection
EcoNetwork-Port Stephens submits that this project is not acceptable on multiple grounds and should not be approved.
 The sand quarry would significantly increase heavy vehicle movements (for the next 25 years) on a road system which has a number of unsuitable single carriageway sections and which is already overloaded in some areas at peak times. The impact of this proposal on heavy vehicle traffic cannot be considered in isolation from other existing and proposed sand extraction projects relying on the same inadequate road network.

 The quarry is located in close proximity to the ‘red-zone’ affected by PFAS contamination originating from RAAF Base Williamtown. Given the uncertainty surrounding the level of risk, it would be grossly irresponsible to approve excavation well below ground and water table level (in Stages 2-6) over a 37ha site, disturbing the soil and affecting the groundwater.
The project would involve a significant loss of valuable fauna habitat and other environmental damage, which would continue in perpetuity after the end of mining operations due to the large residual lake.

 Along with the proposed mine at Bobs Farm – SSD 6395, this
would be one of the first significant sand mines in the area to propose excavation
well below groundwater level – most of the other mines are either harvesting windblown sand or taking surface deposits from vegetated land with consents typically limiting excavation to a metre or less below ground level, and above the water table. Excavation below the water table potentially exposes this important aquifer to impacts from short and long term pollution, jeopardising the aquifer as an important water source for the area. As such the proposal for ‘wet-mining’ represents a completely new and uncertain threat to the local hydrology (and ecology).

 The EIS states that under the Port Stephens Comprehensive Koala Plan of
Management (PSCKPoM) ‘The project site is mapped as ‘Supplementary’ Koala habitat …
important to the long-term conservation of Koalas in Port Stephens’ (6.7.4) It appears that all of this habitat on the site will be cleared leaving a freshwater pond in perpetuity
(22.2). With the recent devastating and unprecedented fires in NSW over the 2019 summer, koalas are now being considered as endangered and every piece of acknowledged habitat is vital to their survival. Current legislation regarding koalas and habitat loss is therefore out of date and we should wait for a full assessment of impacts before making decisions on koala habitat. Further we submit that the project is not consistent with Direction 14 of the Hunter Regional Plan HRP which identifies the need to protect biodiversity and connect natural areas, despite the attempted re-assurance in the EIS (6.8.1) The permanent lake of approximately 25ha, to be left after the cessation of the quarry mine would significantly decrease the width of the current wildlife corridor.

 The EIS suggests that Boral may buy bio-banking offset credits to offset unavoidable environmental losses (discussed above), although other options are mentioned, but no specific proposal is made (9.6)

We have fundamental concerns about the entire bio-banking and offset policy as currently implemented in NSW, and while we have to reluctantly accept that it is currently available to Boral for this project, we submit that the consent authority should not automatically accept that any environmental damage can just be ‘paid off’ with a cash payment to biodiversity protection in other geographic areas which are often of dubious longevity. (Legal action is currently under way against Whitehaven Coal for allegedly failing to secure the necessary biodiversity offsets for its Maules Creek coal mine, signed off on in 2013 , which leads one to believe that bio banking offset credits are not a reliable way to compensate for habitat destruction.)

For further detail of our objections, please refer to the Tomaree Residents and Ratepayers Assoc Inc., which is one of our affiliates. We fully support all the of the objections and submissions in the TRRA objection.

Kathy Brown
Secretary EcoNetwork Port Stephens Inc. 0422 261 057
[email protected] http://www.econetworkps.org
https://www.facebook.com/groups/EconetworkPortStephens/



_________EcoNetwork - affiliated groups & eco-businesses________
National Parks Association (Hunter Branch) Inc. Port Stephens Koalas Inc.
Native Animal Trust Fund Inc. Tilligerry Habitat Inc.
Port Stephens Park Residents Association Inc. Soldiers Point/Salamander Bay Tidy Towns Inc.
Myall Koala & Envir. Support Group Inc. Mambo Wanda Wetlands Reserves C’ttee Inc.
Pindimar/Bundabah Community Association Inc. Ocean & Coastal Care Initiatives (OCCI) Inc.
Shoal Bay Community Association Inc. North Arm Cove Residents Association Inc.
Soldiers Point Community Group Inc. Port Stephens Marine Park Association Inc.
South Tomaree Community Association Inc. Boomerang Park Preservation Group Inc
Mambo-Wanda Wetlands Conservation Group Wanderers Retreat
Salamander Recycling Inc. Tomaree Ratepayers and Residents Assn. Inc.
Destination Port Stephens Inc. Irukandji Shark & Ray Encounters
Tomaree Bird Watchers Williamtown Residents Action Group Inc.
Port Stephens Native Flora Gardens Marine Parks Association Inc.
Tomaree Museum Association Hunter Botanic Gardens

The Soldiers Point Community Group object to this project as we believe the proposal is not ecologically sustainable given that we understand that the project proposes a 50% increase in the maximum permitted annual despatch volumes (for the existing windblown sand operation and the new project combined) - from 500,000 tonnes to 750,000 tonnes - until 2028, reverting to the currently approved limit of 500,000 tonnes for the extended extraction period from 2029 to (potentially) 2045 (EIS 4.2). In addition, the project would involve the movement onto the site of up to 70,000 tpa of VENM material for stabilisation (EIS 4.27). This is simply not ecologically sustainable regardless of any other specific impact described below .

The site is serviced primarily by Nelson Bay Road and Cabbage Tree Road, both of which have lengthy single carriageway sections – with no short or medium term proposals for improvement. These roads are two of the three which link the Tomaree and Tilligerry peninsulas with the rest of the country. The peninsulas have a resident population of 30,000 which more than doubles in the peak tourist season.

There are already 7 operating sand mines/quarries with a further three new or expanded operations currently proposed in addition to this one. See attachment Appendix A Figure 1. The SPCG submits that the assessment must consider the cumulative impact of all existing and proposed sand mining operations in the eastern part of Port Stephens LGA.

This assessment should also take into account the potential for additional truck movement over and above current levels from existing approvals – if some or all of the existing operations are currently operating below their approved limits, then the future load on the road network may include additional traffic from those operations as well as from any new approvals.

The EIS summarises the proposed truck movements stating only that:
‘The project will generate 30 heavy vehicle movements per hour during a maximum hour of production, equating to approximately 284 laden vehicle movements per day.
The maximum traffic generation for the project comprises 26 heavy vehicles transporting sand product per hour, and four heavy vehicles importing VENM to the project site per hour.’ (4.29)
We note that Table 4.2 in the EIS compares up to 284 truck movements (per day) with a maximum of 152 from the existing windblown sand operation. This would be an 87% increase – nearly double. More detailed figures are given in Chapter 12 of the EIS and Appendix H – Traffic Impact Assessment.

The EIS asserts that ‘Traffic generated by the project would not result in detrimental impact to the surrounding and arterial road network.’ (Table 6.3)

The application seeks the same hours of operation as the existing (2006) consent i.e. 06.15-1700 Monday to Friday, with an extra hour (to 1800) during major supply contracts (which could presumably be for any period). This means that the heavy truck movements would potentially occur during morning and afternoon commuter peak times, compounding the load and associated safety risk.

We have been unable to locate any reference in the EIS to the number of truck movements from the other sand mines already located or approved around Williamtown and Salt Ash. The numbers already involved is significant, particularly around the Richardson road and Medowie road roundabouts. Significant increases are now generated by the approved expansion of the Salt Ash Quarry at Janet Parade. The approved quarry on Cabbage Tree Road will be commencing operations in the near future and there are applications being assessed for further quarries at Bobs Farm and Anna Bay. . We assert that if the applicant was required to document, and the assessment consider, the cumulative number of truck movements when all existing and proposed mines reach capacity would in itself draw a conclusion that the project should not be approved until such time as the surrounding roads have the capacity to deal with this traffic that poses a serious risk to all those , including the residents of Soldiers Point.

Given the sand quarry would significantly increase heavy vehicle movements (for the next 25 years) on a road system which has a number of unsuitable single carriageway sections and which is already overloaded in some areas at peak times, we assert that the impact of this proposal on heavy vehicle traffic cannot be considered in isolation from other existing and proposed sand extraction projects relying on the same inadequate road network. In particular we note that

That the section of Nelson Bay Road that is most likely to be affected has already been significantly compromised for the future. In Fern Bay the development of a retirement village appears to have limited the ability for RMS to widen the road into a dual carriageway as planned, and recently a new merge road from the Seaspray suburban development has been opened north-east of the round-about, that may also compromise the duplication and will add an unknown quantity of traffic to this already very busy road during peak periods. Adding more heavy vehicles, up to 200 per day, to this stretch of road that is already under pressure does give concerns of both congestion and safety. If Cox's Lane is used to gain access to Cabbage Tree Road, it is evident that Fullerton Road would need to be completely rebuilt to accommodate heavy vehicle traffic. Fullerton Road currently requires constant maintenance at the expense of ratepayers for existing light traffic and is in a very poor condition therefore putting at risk the safety of residents of Fullerton Cove, Williamtown, Salt Ash, Lemon Tree Passage, Tanilba Bay, Nelson Bay , Shoal Bay and Soldiers Point who have no option but to use this road as the prime access to Newcastle City including the facilities of The Newcastle University, Public Hospitals Inter City and Inter State Transport Terminals .

The site is unstable and the resulting disturbance of soils has the potential to affect groundwater. The large residual lake would mean that environmental impacts would continue in perpetuity. The quarry is located in close proximity to the ‘red-zone’ affected by PFAS contamination originating from RAAF Base Williamtown. Given the uncertainty surrounding the level of risk, it would be grossly irresponsible to approve excavation well below ground and water table level (in Stages 2-6) over a 37ha site, disturbing the soil and affecting the groundwater.

Stockton Beach is already very mobile and excavating below sea-level may cause significant destabilisation of dunes. Along with the proposed mine at Bobs Farm – SSD 6395 this would be one of the first significant sand mines in the area to propose excavation well below groundwater level – most of the others are either harvesting windblown sand or taking surface deposits from vegetated land with consents typically limiting excavation to a metre or less below ground level, and above the water table. As such the proposal for ‘wet-mining’ represents a completely new and uncertain threat to the local, including that of Soldiers Point which is a peninsula,by hydrology (and ecology).

The economic base of the Tomaree Peninsula and therefore that of Soldiers Point is Tourism. The EIS states that under the Port Stephens Comprehensive Koala Plan of Management (PSCKPoM) ‘The project site is mapped as ‘Supplementary’ Koala habitat …important to the long-term conservation of Koalas in Port Stephens’ (6.7.4) It appears that all of this habitat on the site will be cleared leaving a freshwater pond in perpetuity while destroying much needed habitat. The impact of this on Tourism nationally after the recent national bushfires of 2019 and 2020 has been well documented and is just as applicable to that of the Tomaree Peninsula, including Soldiers Point, as it is in other areas.

Given the environmental, economic and road safety factors of this project that will negatively impact on the community of Soldiers Point The Soldiers Point Community Group asks that the application be withdrawn and the project not go a head.

HBOC is objecting to some aspects of the project. See attached submission

See attached letter of objection

Please see attached response.

Attached is the DRG response to the request for comment on the EIS documents for Stockton Sand Quarry Dredging

DPIE Crown Lands provide the following comments
· Access to the Boral Sand Quarry site is via a track in use over Crown reserve R170039 for Public Recreation

· Boral hold Crown licence 196915 for “access” over Part Reserve 170039 (being part Lot 7300 DP 1130730)

· The Department will continue to work with the Proponent to update the Schedule 2 Licence diagram to accurately reflect the location of the track in use

· Landowners consent from the Department of Industry Planning and Environment – Crown Lands is not required as the Development Application relates to the use of the land for a purpose for which a licence has been granted under the Crown Lands Management Act

See attached

Refer to attached letter.

TfNSW Response