Submission of Objection – Proposed Quarry Development

To Whom It May Concern,

I am writing to formally object to the proposed quarry development near my home. The impact on myself, my family, and the broader community would be significant and overwhelmingly negative.

1. Traffic and Road Safety Concerns
The projected increase of up to 500 heavy vehicles per day on Old Cooma Road and the Monaro Highway poses a serious risk to road safety. My family and I travel these roads daily, and the additional heavy vehicle traffic will greatly increase the likelihood of accidents. Furthermore, such volumes will cause significant road damage, which in turn increases costs to the community.

2. Impact on Protected Land and the Environment
The proposed site is classified as protected land. Developing a quarry here would destroy important woodlands and habitats, putting native flora and fauna at risk. This is an unacceptable environmental cost.

3. Dust, Silica, and Health Risks
Dust emissions, including crystalline silica, are a major concern. Silica exposure is known to cause cancer, and airborne particles will inevitably settle into rainwater tanks used by local residents, including my family. This poses a direct health hazard and contaminates our household water supply.

4. Pollution of Drinking Water and Waterways
Quarry runoff and dust will not only impact tanks but will also enter local waterways and ultimately flow into Lake Tuggeranong. This contamination risks polluting our drinking water sources, damaging aquatic ecosystems, and creating long-term health risks for people, animals, and the broader community.

5. Blasting, Noise, and Proximity to Homes
Blasting activities and the resulting dust clouds will have a significant and ongoing negative impact on the wellbeing of local residents. The proposed quarry is far too close to houses, which will amplify the effects of dust, noise, and vibration on families. There are many other locations available where a quarry could be built away from built-up residential areas. My understanding is that this site has been selected purely to reduce transport costs for the business and therefore maximise profits. I urge the government not to put money ahead of the welfare of residents and the protection of our environment.

6. Existing Quarries Operating Below Capacity
There are already several quarries in the region that are only operating at approximately 40% capacity. Given this under-utilisation, the development of yet another quarry in such close proximity to residential areas is unnecessary and unjustified.

Conclusion
The proposed quarry is unnecessary, unsafe, and harmful to both the community and the environment. The risks to traffic safety, drinking water, public health, protected lands, waterways, local ecosystems, and nearby households far outweigh any potential benefits.

For these reasons, I strongly oppose this quarry development and urge the responsible authorities to reject the proposal.

Sincerely,
Donna

I formally object to the Monaro Rock Quarry Project (SSD-27223807) on significant social grounds. While the Environmental Impact Statement (EIS) and its supporting documents present a series of technical assessments, they fail to adequately address the profound and irreversible social impacts that this project would have on the community of Royalla and surrounding areas.
The Social Impact Assessment (SIA) itself acknowledges that "social acceptability remains contested" and that "the burden lies with the Applicant to earn, and maintain, community trust over the life of the Project." This statement is a critical admission that, from a community perspective, the project's social risks have not been sufficiently mitigated.
My objection is centred on the following points, as highlighted in the EIS and informed by my personal experience as a resident:
1. Erosion of Community Identity and Sense of Place - The community of Royalla is defined by its rural, peaceful, and family-oriented character. As detailed in the SIA, residents deliberately chose to move here to escape the noise, pollution, and chaos of city living. They have a strong connection to the rural landscape and a deep sense of self-sufficiency and neighbourly trust. The introduction of an industrial quarry in a greenfield location, just 1.5km from the nearest residence, fundamentally changes this identity. The presence of heavy machinery, blasting, and truck movements—regardless of whether they technically meet regulatory thresholds—will permanently alter the rural character that is central to our well-being and sense of place.
2. Inadequate Mitigation of Amenity Impacts - While technical assessments claim that noise, dust, and visual impacts will be manageable, they cannot account for the lived experience of these changes.
• Noise and Blasting: The EIS states that noise and blasting will be within acceptable limits, but this does not mean they will be unheard or unfelt. Blasting, even at low levels, creates a constant state of anxiety and stress. Residents, particularly older individuals, will be continually reminded of the proximity of an industrial operation, disrupting the peace and quiet they cherish.
• Dust and Health Risks: The community has significant and enduring concerns about dust, specifically the risk of respirable crystalline silica (RCS). The HHRA found the risk to be "low and acceptable," but this conclusion is based on conservative assumptions and is not aligned with our direct experience of air quality in the region, which is often affected by bushfires and other pre-existing sources. The proposed mitigation measures, such as water carts and enclosures, rely heavily on human adherence and are not a guarantee against all impacts.
• Visual Impact: The proposed Visibility Barrier, while intended to screen the site, is itself a significant landform that will become a dominant feature of our landscape. We are concerned that its effectiveness is contingent on the successful establishment of vegetation, which is a long-term and uncertain process.
3. Heightened Stress and Anxiety - The SIA acknowledges that the project may compound existing stress from events like bushfires and the COVID-19 pandemic. The community's opposition is rooted in a deep-seated fear that the project represents an unacceptable cumulative impact on our quality of life. The perceived lack of control over local change and a distrust of regulatory processes—which the SIA also identifies—has already caused significant anxiety. The constant presence of heavy vehicles on the Monaro Highway, even with a dedicated access road, raises genuine fears for road safety and our families' well-being.
4. Failure to Address Cumulative Impacts - The community’s experience with existing quarries in the region has left residents with a sense of "fatigue" and a heightened sensitivity to this new proposal. We are concerned that the cumulative effect of an additional quarry, with its associated traffic, noise, and environmental pressures, will push the social and environmental fabric of our community beyond a breaking point. The EIS does not adequately address how the social and emotional burden of this cumulative impact will be managed.
5. Flawed Justification of Need - The project's economic justification hinges on a forecast resource shortfall that the community believes is overstated. Even if a shortfall exists, the costs to our community's health, well-being, and lifestyle are not justifiable. We believe the local social and environmental costs far outweigh the regional economic benefits, which primarily serve large-scale infrastructure projects.
In conclusion, the Monaro Rock Quarry Project represents a fundamental betrayal of the social contract that underpins our community. We chose to live here for a specific way of life, and this project threatens to destroy it. I urge you, as the planning minister, to consider the overwhelming social costs of this project and to reject the proposal.

This submission sets out a detailed opposition to the proposed Monaro Rock Quarry at Royalla. The project presents serious risks to human health, the environment, community amenity, and regional sustainability, while delivering only narrow private benefits and questionable economic returns.

Key concerns include:
Public Health Risks: The quarry would emit respirable crystalline silica dust, a proven cause of silicosis, lung cancer, and other respiratory illnesses. Tens of thousands of residents live within 10 km of the site, with some as close as 1.6 km, placing a large population at risk.
Environmental Damage: The quarry threatens to deplete groundwater, alter surface water runoff, pollute Tuggeranong Creek, and fragment habitats. These changes are largely irreversible and inconsistent with sustainable land management.
Social and Amenity Impacts: The proposal would generate up to 200 truck movements per day, significant noise from blasting and crushing, and dust deposition on nearby properties. These impacts will reduce quality of life, diminish property values, and erode the rural character of Royalla and surrounding areas.
Lack of Economic Necessity: Existing quarries in the region are under-utilised and already capable of meeting demand. The quarry provides minimal employment and economic benefit compared with the widespread costs imposed on local communities and infrastructure.
Planning and Legal Inconsistency: The project conflicts with ecologically sustainable development principles, the precautionary principle, and regional planning frameworks. The cumulative impact of another quarry in this area is unacceptable.

This submission argues that the Monaro Rock Quarry should not be approved. If, contrary to these arguments, approval is granted, it must be subject to stringent, enforceable conditions that protect health, environment, and community wellbeing.

1. Introduction and Context

1.1 Location and Setting
The Monaro Rock Quarry is proposed for a site in Royalla, located near the NSW/ACT border. The site lies close to the Monaro Highway and within commuting distance of Canberra. Surrounding land uses include rural-residential communities, small farms, and conservation areas.
Importantly:
* Royalla residents live as close as 1.6 km from the proposed site.
* Tuggeranong, a major ACT suburb, lies only 2.6 km away.
* There are approximately 31,000 residents within a 5 km radius and over 90,000 within a 10 km radius.
This is not an isolated industrial setting but a semi-rural landscape embedded within a growing metropolitan region. The quarry would therefore impose impacts on a substantial population.

1.2 Proposal Overview
The quarry proponents seek approval to extract up to one million tonnes of rock per year. Operations would include:
* Blasting, crushing, and screening of rock.
* Onsite stockpiling and loading.
* Up to 200 truck movements per day.
* Operation six days per week, up to 12 hours per day.

1.3 Planning Context
The proposal has been declared State Significant Development under NSW planning law. This status requires an Environmental Impact Statement (EIS) and allows the Department of Planning & Environment to determine the project. The assessment must be guided by the principles of ecologically sustainable development (ESD) and the public interest.

2. Health Impacts

2.1 Silica Dust as a Hazard
Respirable crystalline silica (RCS) dust is generated during quarrying, especially from blasting and crushing. According to Safe Work Australia, exposure to RCS can cause:
* Silicosis (an incurable and often fatal lung disease).
* Lung cancer.
* Chronic obstructive pulmonary disease (COPD).
* Kidney disease.
Silica dust particles are small enough (<10 microns) to penetrate deep into the lungs. Unlike larger dust particles, they are not effectively expelled by natural defence mechanisms.

2.2 Populations at Risk
The proximity of large residential populations greatly increases risk:
* Nearest homes are within 2 km.
* Schools, childcare centres, and aged care facilities exist within the 5–10 km zone.
* Prevailing winds can carry fine particles well beyond the immediate quarry boundary.
Children, the elderly, and those with asthma or other respiratory illnesses are particularly vulnerable.

2.3 Regulatory Standards and Compliance Challenges
NSW and WHO air quality standards set limits for PM2.5 and PM10 particulates. However, numerous studies show that even at levels below regulatory thresholds, long-term exposure increases health risks.
Dust suppression measures (water sprays, covers, vegetation) are not fail-safe. Equipment failures, drought, high winds, and human error all compromise performance.

2.4 Case Studies
Queensland quarries have faced enforcement actions after failing to control dust, with residents reporting health impacts and property damage.
Western Sydney silicosis cluster: Cases of accelerated silicosis among stonemasons highlight the dangers of silica dust even with modern controls.
The Monaro Rock Quarry risks exposing tens of thousands of residents to these hazards.

3. Environmental Impacts

3.1 Groundwater Depletion
Quarry operations require large volumes of water for dust suppression and processing. Extraction may lower the water table, affecting:
* Residential and farm bores.
* Springs and wetlands.
* Soil moisture and vegetation health.
Hydrogeological studies often underestimate cumulative impacts. Once groundwater systems are disrupted, recovery is slow or impossible.

3.2 Surface Water Runoff
Clearing, blasting, and stockpiling will alter drainage. Risks include:
* Increased erosion and sedimentation.
* Pollution of Tuggeranong Creek and connected waterways.
* Greater flood risk downstream due to changed hydrology.

3.3 Biodiversity Impacts
The quarry will clear habitat and create noise, dust, and light pollution that disrupt fauna. Impacts may include:
* Loss of native woodland and grassland.
* Fragmentation of wildlife corridors.
* Declines in threatened species populations.

3.4 Climate and Cumulative Stress
The project adds to cumulative environmental stress from existing quarries and urban expansion. It undermines climate resilience by destroying carbon-sequestering vegetation and increasing heavy vehicle emissions.

4. Amenity Impacts

4.1 Traffic
Up to 200 truck movements per day will:
* Increase accident risk on the Monaro Highway.
* Add congestion and noise.
* Deter cyclists and other road users.
* Accelerate road wear, imposing costs on government.

4.2 Noise and Vibration
Blasting, crushing, and truck movements will produce continuous noise and intermittent high-intensity vibration. Residents may experience:
* Sleep disturbance.
* Stress and anxiety.
* Structural damage to homes and water tanks.

4.3 Dust Deposition
Beyond health risks, dust will:
* Reduce visibility and outdoor amenity.
* Damage gardens, crops, and water tanks.
* Require ongoing cleaning and maintenance.

4.4 Visual Impact
The quarry will scar the landscape, replacing rolling hills with an industrial void. This is incompatible with the rural-residential character of Royalla and surrounding areas.

5. Social and Economic Considerations

5.1 Limited Employment Benefit
The quarry will employ relatively few staff compared to the number of people adversely affected.

5.2 Property Values
Noise, dust, and visual scarring typically reduce nearby property values by 10–30%. For hundreds of properties, this represents millions in lost equity.

5.3 Tourism and Lifestyle
Royalla and the broader region are valued for rural lifestyle and proximity to Canberra. The quarry threatens this appeal, undermining growth in tourism, recreation, and residential settlement.

5.4 Cost-Benefit Imbalance
Benefits: modest profits to a private company, limited jobs.
Costs: health burden, road upgrades, property value loss, environmental degradation.
The imbalance is stark and contrary to public interest.

6. Planning and Legal Considerations

6.1 Ecologically Sustainable Development (ESD)
Under NSW law, decision-makers must apply ESD principles, including:
The precautionary principle: where threats of irreversible damage exist, lack of scientific certainty should not justify approval.
Intergenerational equity: ensuring today’s actions do not compromise future generations’ needs.
Conservation of biodiversity.
The quarry fails these tests.

6.2 Cumulative Impacts
Several quarries already operate in the region. Adding another intensifies dust, noise, and traffic beyond acceptable limits.

6.3 Strategic Land Use Conflicts
The project conflicts with regional planning goals for sustainable rural-residential growth and environmental protection.

7. Comparisons with Other Projects

Bass Point Quarry (NSW): Strict conditions imposed after community opposition, including buffer zones and truck limits.
Newcastle Sand Quarry refusal: Rejected due to dust and traffic impacts near residential areas.
These precedents show that projects with significant community and environmental impacts should not proceed.

8. Community Concerns and Consultation

The Royalla and Tuggeranong communities have expressed strong opposition. Social licence is absent. Without community consent, the project will remain a source of conflict and resentment.

9. Conclusion and Recommendation

The Monaro Rock Quarry poses unacceptable risks:
To public health through silica dust.
To the environment through groundwater depletion and habitat loss.
To community amenity through traffic, noise, and visual scarring.
To regional sustainability by undermining planning goals and cumulative limits.
The limited private benefits do not outweigh these widespread costs.

I strongly urge that the Department of Planning & Environment refuse the Monaro Rock Quarry proposal. If, despite these objections, approval is granted, it must include stringent, enforceable conditions on dust, blasting, traffic, water use, and rehabilitation, with independent monitoring and community reporting.

The new quarry proposals in the Royalla area have been floated since I became a resident in 2004 (one of the early residents). Every proposal has been rejected by the community en masse.
This proposal does nothing to support the need for such a development and only continues to raise the ire, angst and anger of Royalla residents.
People choose to live in Royalla preciesly because it is a rural/residential environment where we can live and raise children in a clean, quiet natural setting free from noise pollution, dust pollution and industrial pollution.
As a long-term resident or Royalla I am totally opposed to this development for the following reasons:
- It is unnecessary. There are other existing quarries in the region that are not operating at full capacity.
- The predicted benefit of jobs/employment is disingenuous. Skilled employees will most likely be bought in from elsewhere.
- This proposal is rooted in the profiteering of individuals to the detriment of the cherished lifestyle of over 1,000 residents.
- There are no guarantees that residents will not be affected by noise and dust pollution. Mitigation has been shown in the past to be nothing more than lip service.
- The fact that the mitigation strategy for 'Impacts on surface and ground water' is nothing more than 'monitoring' is a farce. This is not a mitigation strategy! This is nothing more than an admission that it is likely the the surface and ground water WILL be affected. It says nothing about what they will do if contamination occurs. On those grounds alone the proposal should be rejected.
- My dwelling is well within the 5km zone of the proposal. That being the case then it is highly likely that my property value will be affected detrimentally and there is nothing in the mitigation strategy that addresses how this affect will be negated. It is simply assumed that I will have to cop it sweet.
- There has been communication with me as a resident about this proposal, either from the State, Local Council or the Developer. I only found out about this by word of mouth. As a Royalla resident, this is entirely unacceptable and I would have expected a letterbox drop at the very least. It would appear that this proposal is trying to sneak in under the radar as have similar proposals in the past affecting Royalla residents.

In conclusion, this proposal has no economic merit for the region, only the Developers. There are other existing quarries in the region that can fulfill current demand. The likelihood of significant environmental damage is high and the proposal in general represents a significant threat to the health and well-being of Royalla residents and the rural/residential lifestyle that we have chosen and enjoy with the added negative impact of reducing land and home values.

My first comments relate to the whole area and the increased traffic that will come about from both the school and the new Bunnings at the intersection of Allambie & Rodborough roads. Should the proposed roundabout at Aquatic Dr & Allambie Rd, be considered in conjunction with the intersections at Allambie & Rodborough Rds, Allambie & Warringah Rds & finally Rodborogh & Warringah Rds to develop an integrated solution that can manage the increased traffic volumes? It seems that a piecemeal approach to the management of traffic flows will lead to poor outcomes. One such outcome will be the increased utilisation of the "rat run" through Mortain Av, Kurrabi Rd, Wyarama St & Government Rd - the first 3 of those have no footpaths which forces pedestrians to walk on the road. Increased traffic has the potential to increse the risk of pedestrian/vehicle accidents.

My second comment relates to safe pedestrian crossing locations for students at the new Forest High School. The update to the roundabout at Aquatic drive does not provide information on safe cross locations for students. Along Allambie Road in that area, there are only two locations where students will be able to cross Allambie road safely at lights; they are at the intersection of Allambie Rd & Mortain Ave, approximately 375m away from the school and at the intersection of Allambie & Warringah Rds, some 385m away from the school. There is also the small pedestrian island located at the intersection of Allambie Rd & Sunlea Place. Are these to be the only crossing options for children walking to school?

I am in support of this project and those of the school relocation and bunnings - but want to ensure that traffic / pedestrian management in the local area has been well considered to ensure safety and local community quality of life is protected.