Please see letter attached

Please see attachment.

I object to the above development, and believe that it should be rejected for reasons which include the following.
1. I own 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.

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.

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 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