Urunga Remediation

I refer to your letter dated 7 November 2014 advising of the exhibition of the development application and accompanying Environmental Impact Statement (EIS) for the Urunga Antimony Remediation Project (SSD 5357). The project has been reviewed by Council and the following comment on the proposal provided.

The EIS identifies the preferred option of treatment for the site as Option 3A - On-site treatment and disposal. This option has the in-principle support of Council.

The EIS provides that Crown Lands is committed to ongoing stakeholder consultation. This is applauded and Council emphasises the importance of ongoing community engagement throughout the remediation project. Effective community engagement should be implemented by the proponent before, during and after remediation works. The engagement process should ensure that the community is informed on the who, what, when, where and with what effect of the proposed works, having particular regard to the "minor short-term adverse impacts" identified in the EIS and both potentially affected residents and downstream users.

In addition, ongoing and meaningful stakeholder consultation and engagement is recommended in regard to the final use of the site. The Director General's Environmental Assessment Requirements for the development include the requirement for "details of the final use of the site." While the EIS identifies the objective to "allow the Site to be opened to public access without unacceptable risk to human health," the extent of use by the public, opportunities for interpretation of the former land use and remediation project, and realistic opportunities for the development of the land as a destination are recommended to be incorporated into the consultation.

To ensure that the public use of the site is "without unacceptable risk to human health," the monitoring over time for potential health risks post remediation works is recommended. Additionally, mitigation and management measures to prevent, control, abate or minimise any impacts or potential impacts identified by the monitoring program to public health and/or the environment should be established as a contingency plan. Such measures should incorporate adequate public notification.

The effect of "minor short-term adverse impacts" on the receiving environment should be managed to mitigate that impact in accordance with the EIS. This includes the minimisation and management of adverse impacts down-stream and off-site.

Concerning the nature of the remediation works and indications in the EIS of dust risk and the likely exceedance of acceptable noise criteria during works, a clear and accessible contact point for community concerns to be received and proactively addressed is supported. This contact point should address community concerns pertaining to any effect of the development to human and environmental receptors.

The Traffic Impact Assessment identifies the requirement for a Traffic Management Plan which would include, amongst other things, measures to provide safe access points from the adjacent road network to the site. Prior to undertaking work in the road reserve, including work to provide safe access points, consent for the work is required to be issued in pursuance to section 138 of the Roads Act 1993.

Council's sewer main traverses Lot 1 DP 874874 in the northwest and the adjoining Hillside Drive. All development works should ensure the integrity of this infrastructure.

Land in the northwest of Lot 1 DP 874874 has been identified by the Coffs Harbour and District Local Aboriginal Land Council (CHDLALC) as having a strong potential to contain potential archaeological deposits (PAD). To conserve Aboriginal objects and Aboriginal places of heritage significance, it is recommended that no work occurs within the PAD unless in accordance with the requirements of the CHDLALC and the Office of Environment and Heritage.

Thank you for the opportunity to place a submission on the proposed development.