Please refer to the attached document

Submission attached.

Re: Ardmore Park Quarry HISTORY of JERRARA, MOUNTAIN ASH & OALLEN FORD
ROADS I have lived in the Bungonia area since 1960. I remember when
the now Mountain Ash Road, the Jerrara Road and the Oallen Ford Roads
were both gravel and 4 cars a day was a busy day. I have some
qualifications and much experience in road-building having built roads
in the Goulburn Mulwaree, Yarralumla, Palerang and Cooma Shires.
Further I have contracted under hire to the Dept of Main Roads, then
the Roads and Traffic Authority and many other construction
organisations over the past 30 years. Extensive roadworks were carried
out on both roads during the 1980s, commencing with upgrading the
gravel surface and subsequently spray-sealing both with bitumen. Since
that time very little maintenance has been carried out, and that which
has been undertaken has been at the expense of the ratepayers. The
Shire engineers did the best they could with the limited funds
available (this being prior to amalgamation of the 2 Shires). The
roads they built were good enough for the usage at that time. No one
envisaged the amount of traffic now traversing these roads. When
various quarries commenced operation in the Windellama region, the
Shire diverted traffic to the Braidwood Road via Cullala and Sandy
Point Roads. This prevented heavy vehicle usage of Oallen Ford and
Jerrara Roads. THE FACTS I have tested the gravel that was used on the
Mountain Ash, Oallen Ford and Jerrara Roads won from Carmichael's pit
on Mountain Ash Road. This product fails most of the Main Roads tests
(see attached file from MR documents). The Plasticity Index (PI) for
Carmichael's pit is 12-16, the California Bearing Ratio (CBR) test is
only 10 - both of these fall well outside recommendations. A suitable
gravel for a haul road, bearing in mind the extra weight of the
traffic, is a PI of 4-6 and a CBR of 46-70. These are only 2 of a
number of appropriate tests. To satisfy most main road requirements, a
gravel meeting DGB20 is required. It is plain to see from the above
analysis that the road base applicable to Jerrara, Oallen Ford and
Mountain Ash Roads is totally unsuitable for a haul road carrying the
tonnage envisaged in this Modification Request. Evidence of this is
available to anyone travelling these roads at present, even prior to
commencement of full quarry operations. CURRENT ACTIVITIES Ardmore
Park has done considerable widening of the haul route. I have not seen
the quality tests conducted by a NATA-approved laboratory, but would
like access to same. I would also like to see the density tests
conducted on the widening by a certified NATA testing officer, as I
have reservations as to the methods employed to achieve 100%
compaction on the strip sections attached to the pre-existing
thoroughfare. In my professional opinion, the roads in question will
deteriorate very quickly when the quarry trucks commence fully-loaded
operation at the new tonnages sought. The ratepayers should not be
responsible for funding Ardmore Park's enterprises. I note that the
Modification Request seeks a substitution of Section 94 contributions
with a Voluntary Planning Agreement. The original Section 94
contributions were miniscule but their replacement with a "VPA" needs
full explanation and investigation. The entire haul route would not be
adjudged acceptable by any competent engineer given the proposed
tonnage, additional truck movements plus the ever-increasing private
vehicle usage. The bitumen at total width inclusive of the widening
strips on the entire haul route should be removed. The existing road
base gravel is suitable only for "select material" and should be
compacted to 100%. Two layers of 150mm per layer, of DGB20 standard
gravel should be spread, compacted and certified to 100%. Testing
every 100 metres should be undertaken. A two or three coat seal (even
better a hot mix surface) should then be applied. A few overtaking
lanes would also be an advantage given the road alignment. ASSOCIATED
ISSUES Mountain Ash Road to Goulburn - same story, too many trucks
(not all the property of Ardmore Park and its subsidiary APE) and
sub-standard gravel. The only solution for this is to repair the road
and get trucks off it. Ardmore Park currently has the right to sell
and deliver product locally using the entire local road network
including the Mountain Ash Road to Goulburn. Because of this
additional usage, the road between Bungonia and Goulburn is so
destroyed as to be dangerous. I suggest a 15 tonne load limit for all
roads other than the haul route. This will not inconvenience companies
delivering product to residents along the road but will prevent
opportunistic travel as a thoroughfare or shortcut. This will
concentrate most heavy traffic onto the haul route except transit
through the village of Bungonia. Incidentally, it is a nonsense that
the Bungonia By-Pass is a private road and unavailable to other
trucking companies - it should have been gazetted and used for all
traffic in excess of 4 tonnes GVM. This could become a trade-off for
Ardmore Park's Modification Requests. CONCLUSION I draw attention in
brief to the following: 1. Ardmore Park makes much of the fact that
his new vehicles (not all his existing fleet) comply with NHVR
standards and, for some reason, are likely to do less damage than
conventional trucks. I would say that 2288 vehicle movements per annum
and 580,000 tonnes of freight at 8 tonnes per drive or load axle will
destroy any road that is not up to standard and even those that are,
viz. entry and exit to Marulan checking station. 2. Truck hours of
operation. In the initial, generous consent, trucks were permitted to
travel the haul route between 7 a.m. and 6 p.m., Monday to Friday and
between 8 a.m. and 1 p.m. on Saturdays. This was resisted by the local
residents but Ardomore Park now seeks a modification to allow the
hours to change to 5 a.m. to 10 p.m. Monday to Friday and 5 a.m. to 5
p.m. on Saturdays. The weekday time increase is 64% and the Saturday
increase is over 110%. I would remind the Minister that Friday
afternoon is the busiest time on Jerrara Road with the weekender peak
period between 6 p.m. and 10 p.m. - dark in winter for the entire
period and for at least 2 hours in the height of summer. Human and
wildlife carnage might be anticipated. In other local government
areas, where quarries are situated in rural residential areas, they
are often restricted to an 8-hour day, five days per week. Now my
comments are on record, they may be used in class actions if my
predictions prove correct - with particular reference to safety and
the cost of road repairs that will, of necessity, be borne by the
ratepayers.

I object as per the attached file attachment.

Ardmore Park Quarry Modification MP 07_Mod 3 PA 07_0155 Proposes
We only received this letter of Notification a few days ago and note
dated 21st February 2018
And wish to express concern about the lack of time to respond to the
above modification.

We have 2 properties on 4018 Oallen Ford Road, and 3814 Oallen Ford
Road Windellama 2580 and also commute on a regular basis to Wollongong
and have been doing so over the past 15 years.

Safety
Jerrara Rd, even with its planned improvements, is still only a basic
connecting country road, not designed for excessive truck movements,
with increased movements and weight limits the road condition will
deteriorate rapidly, who will be responsible for its upkeep? The
shoulders will still be rough and broken, accidents will happen.
The roadworks being undertaken on Jerrara Road has been spasmodic all
along the Road between Marulan and Bungonia, without little or no
notification of the stages of future works that are to be undertaken
in sections. The illuminated signs are inconsistent to the length of
road work being undertaken.
Major Road Works Signs about the stages of proposed works at both end
of Jerrara Road are non-existent.
Most major roads works projects have permanent signage to inform the
general public of the stages of works and the persons who has endorsed
/directed / funded and time frame for the major works conducted.
Is NSW Government subsidising the Multiquip Company? If so this should
also be disclosed.
Who is the engineering company contracted for the road works and where
is their name displayed professionally?
The people working on the site are often clearly not seen with the
colour clothing they wear. We express concerns for their own safety.

Extraction and further mining.
The company has not provided current sufficient information to the
general public, about the environmental impact.
An up to date drone aerial photo view would at least outline the
precise boundaries of the site’s progression, and display ongoing
impingement to the environment should at least be provided to
neighbouring properties and provide open disclosure to the general
public.
Ground water issues are still a major concern as flows on some
adjoining properties have significantly reduced over recent years.
These properties have operated for over a hundred years relying on
ground water flows and may become unviable if these flows reduce
further, where does this leave the property owners?
Noise and environmental pollution from product and transportation
should be further addressed. The owner does not appear to live
onsite, which means only those living on neighbouring properties will
be greatly affected.
Increased truck movements
Due to increased production will rip up the road, compromising safety
to the general public leaving continual road works to be undertaken.
Who benefits from unsafe roads?
Operational Bitumen pre- coating Plant on the Quarry Site
There is insufficient information provided about how this will be
undertaken. Again where is the professional requirement and conditions
to the amenity of the land and environment?
Is Ardmore Park proposing a factory site for bitumen production?
Risks Hazzard Pollution, Toxins and Fire.

Extending the life of the Quarry
This mean more traffic movements. Safety is compromised to the
general public and community..
What does the term Excavated Natural Mineral as back fill material
mean ? Insufficient information given professionally to the general
public and community. Does this also involve excess truck movements on
the public road?
Extending the life of the Quarry by 8 years
Extended road safety concerns.

What does the term Performance Based Scheme Trucks mean?
No information provided. More truck movements?.....

We object to the proposal of Ardmore Park Quarry Modification MP
07_Mod 3 PA 07_0155 Proposes.