Proposed development of international boutique five star hotel

13 December 2011

RE: Arrawarra Rest Area Environmental Assessment Report

Dear Sir

I'm writing in response to the Environmental Assessment Report undertaken as part of the Sapphire to Arrawarra Pacific Highway upgrade. I do not support the current proposal for the Rest Stop. I believe the location to be inappropriate on environmental grounds and the current Environmental Assessment to be inadequate.

Potential Flooding of Local Communal and residential area

The Arrawarra area already experiences problems with regard to stormwater run-off and consequent erosion particularly on the southern tip of the Coffs Coast Regional Park, (adjacent to Yarrawarra Creek), which contains SEPP 26 Remnant Littoral Rainforest. In times of heavy rain, water already backs up on the low-lying acreages in the area around Arrawarra Beach Road and Eggins Drive.

No scientific evidence is necessary to determine that raising the height of land at the Rest Area (by filling) will increase the fast flowing stormwater run-off to create major pooling in slow flowing flood prone low lying areas.

Coffs Harbour Coastal Processes and Hazards Definition Study and DECC Floodplain Risk Management Guideline, Practical Consideration of Climate Change - flag more significant impacts.

Habitat Corridor

In my experience some of the most reliably accurate information about flora and fauna activities in an area can be gleaned from local residents. First hand recounts from residents observing the current road works and effect on residential wildlife with homes in hollow bearing trees which are removed in a moment are embarrassingly inhumane.

Submissions have been presented about the effect this interchange will have on various populations. Notwithstanding the suggestion that such concerns have been addressed for the whole of the Sapphire to Woolgoolga project, the real effect on sensitive wildlife populations specific to smaller locations within this broader context remains inadequate.

The Arrawarra, Mullaway, Darlington, Garby area supports an important Squirrel Glider population which is otherwise very rare along the Coffs Coast. As well these forests link with the broader coastal reserve which provide other important fauna (Wallum Froglet, Glossy Black-cockatoo and Grey-headed Flying-fox) with critical habitat.

The Arrawarra Regional Habitat Corridor links Garby Nature Reserve and Coffs Coast Regional Park to Wedding Bells State Forest and hinterland forests beyond. The corridor was mapped as part of the Coffs Harbour City Council's Priority Habitats and Corridors Strategy and is regarded as one of the most important coast to hinterland corridor links along the Coffs Coast. Fragmentation and general disturbance could well compromise this Reserve if it becomes functionally isolated from large forest areas to its west.

The state government has recognised this area as a State Significant Corridor under the Biodiversity Conservation Lands layer endorsed by the then Department of Planning. Local environmental planning also shows this area to be Category 2 - High Conservation Lands - under Coffs Harbour City Council's draft Priority Habitats and Corridors Strategy.

The construction of the interchange, Rest Area and extensive highway system at Arrawarra will impact adversely on the free movement of all the native fauna.
Little consideration has been given to providing appropriate safe crossings (as provided during construction of other sections of the highway upgrade - Bonville for example) for free and uninterrupted fauna movement. Current wildlife carnage from road traffic is significant.


Woolgoolga industrial area more appropriate for commercial use

Is it true that licences for fast food outlets for this proposed rest stop have already been awarded before community consultation is finalised? If so it seems to suggest a fait accompli' over this matter and presents this whole process as farcical. I hope this information does not turn out to be accurate.

Submissions have been presented suggesting Woolgoolga industrial area as a more appropriate site for this Rest Area. I concur. It could not be more suitable given the current infrastructure in immediate surrounds similar to the Southern Service Centre in Isles Drive Industrial Estate.


Yours sincerely
Elizabeth Dray

8 December 2011

RE: Arrawarra Rest Area Environmental Assessment Report

Dear Lisa
I'm writing in response to the Environmental Assessment Report undertaken as part of the Sapphire to Arrawarra Pacific Highway upgrade. I have several areas of concern:
* Community consultation has been unclear and misleading, to put it politely.
* The industrial area of Woolgoolga is far more appropriate for a stopping place for commercial vehicles than the Arrawarra forest.
* The Environmental Assessment has not addressed comments made in previous submissions regarding the Squirrel Gliders and other fauna resident in the area.
* The EA has not acknowledged the area is an important habitat corridor.
* Previous designs for fauna crossings have been removed, leaving very long pipes and culverts (often with water lying in them) for animals to crawl through.
* The current stormwater issues on Arrawarra Beach Road, surrounding low-lying areas and the junction of creeks at Arrawarra Beach Caravan Park will be exacerbated by a raised Rest Area.

Community consultation
In the May 2010 Community Update which came with an accompanying letter dated 5 May, the back page clearly states under "What happens next" that "an environmental assessment of the preferred rest area will be prepared and displayed for community comment. Following the display of the environmental assessment, the RTA will again consider community submissions. The RTA may modify the proposal further to help reduce the impacts on the environment".

It is my view that the exhibition period for the EA Report has been so confusing that even people who got the CD and accompanying letter (dated April 2010) believed the EA to be a fait accompli, especially after reading the following statement, "The RTA will now seek planning approval for the proposed Arrawarra rest area as a modification to the Sapphire to Woolgoolga upgrade project".

I believe it was an important oversight that the letter accompanying the Environmental Assessment Report CD did not mention that an exhibition period was underway, which brings into question whether or not the CD and misleading accompanying letter make the consulting process invalid. People who made earlier submissions are the very people most likely to have been interested in commenting again, but the cover letter indicated that the reporting had now finished.

The newspaper ad looked like a simple announcement of the information I'd received with the CD, so I didn't notice it included an opportunity for another submission. That was my mistake, but others have done the same.

Lack of consultation
I have just been told this week that Ms Danielle Wallace, who for two years has owned #1 Arrawarra Beach Road, (the property closest to the Rest Area), was never notified of the proposal until I sent her some information. She had to contact the RTA herself to ask what was happening almost next door to her entrance. This is another major oversight.

Woolgoolga industrial area more appropriate for commercial use
As expressed in my previous submission, the environmental impact would have been virtually nil in constructing the Rest Area and Service Centre at South Woolgoolga on old banana lands, whilst the environmental impact on Arrawarra and its heavily forested environs will be dramatic.

A Rest Area / Service Centre, by virtue of what it accommodates, is certainly commercial in nature, and building such a complex adjacent to an industrial area is highly compatible, whereas to build the same complex virtually in the middle of the bush will impact on the area greatly.

To suggest this complex was unsuitable for an industrial area is a contradiction of terms. You only have to look at the South Coffs Service Centre, fully integrated within the Isles Drive Industrial Estate, to refute that.

Benchmark (2009) outlined the ecological values of the two alternatives and presented clear evidence that the Arrawarra alternative had far greater environmental impact than the South Woolgoolga alternative. Despite this, the RTA has selected the Arrawarra site as its preferred option.
Even though Benchmark (2009) identified important ecological values for the Arrawarra alternative, the site's importance to biodiversity conservation appears not to have been fully grasped. This location is core habitat for threatened forest fauna, including an important population of the Squirrel Glider, and its linking habitat corridor values are vital in a regional conservation context.

Squirrel Gliders
I am disappointed that the EA Report chooses to totally ignore specific comments made by several respondents in their earlier submissions by stating, "These areas were addressed for the whole of the Sapphire to Woolgoolga project in the environmental assessment", chapter 17 (Flora and fauna). There is still no mention of anybody doing anything to address the known presence of arboreal mammals raised in several earlier submissions.

A study undertaken in Nov 2005 by Umwelt, (required by CHCC in respect of a DA that was before Council), mentions Squirrel Glider and Hoary Wattled Bat sightings.

As a result of the judgement, the Land and Environment Court requested a further comprehensive Species Impact Statement be undertaken. Eco-Logical were contracted by Astoria, the owners of Arrawarra Caravan Park, between the 5th and 9th of February, 2007, to undertake the study. It involved set-trapping, calling and spotlighting. The study found five microbat species, including one unnamed species, and several sightings of Squirrel Gliders.

The Arrawarra, Mullaway, Darlington, Garby area supports an important Squirrel Glider population which is otherwise very rare along the Coffs Coast. While the Koala is often recognized as Coffs Harbour's fauna icon, it is uncommon in the northern part of the Coffs Harbour shire where the forests grow on less fertile soils.

These forests become correspondingly important for the Squirrel Glider, which relies on nectar and other associated foods for its existence. The Arrawarra area provides the Squirrel Glider and other important fauna with critical habitat which will be severely compromised by the imposition of the proposed rest area.

Arrawarra Regional Habitat Corridor
The Arrawarra Regional Habitat Corridor links Garby Nature Reserve and Coffs Coast Regional Park to Wedding Bells State Forest and hinterland forests beyond. The corridor was mapped as part of the Coffs Harbour City Council's Priority Habitats and Corridors Strategy and is regarded as one of the most important coast to hinterland corridor links along the Coffs Coast.

If it is compromised through vegetation clearance, fragmentation and general disturbance associated with the proposed Arrawarra Rest Area, then long-term impacts could be severe for the area's forest fauna. The known biodiversity values of Garby Nature Reserve could well be compromised if it becomes functionally isolated from large forest areas to its west.

The state government has recognised this area as a State Significant Corridor under the Biodiversity Conservation Lands layer endorsed by the then Department of Planning. Local environmental planning also shows this area to be Category 2 - High Conservation Lands - under Coffs Harbour City Council's draft Priority Habitats and Corridors Strategy.

Lack of fauna crossings
The proposed Arrawarra Rest Area site is also known to be important as part of a broader habitat core for other threatened fauna species including the Wallum Froglet, Glossy Black-cockatoo and Grey-headed Flying-fox. This habitat core includes Garby Nature Reserve, meaning that impacts at the Arrawarra site are likely to have flow-on impacts to this important coastal reserve. The construction of the interchange, Rest Area and extensive highway system at Arrawarra will impact adversely on the free movement of all the native fauna.
As a result, it's very, very disappointing to note that no consideration has been given to providing appropriate safe crossings (as provided during construction of other sections of the highway upgrade - Bonville for example) for free and uninterrupted fauna movement, as these were removed from the original plans for the rest of the Highway Upgrade Sapphire to Woolgoolga.

Running water in the culverts, pipes and bridge underpasses will prevent animals from being able to cross under the highway safely. That's saying nothing in regard to the expectation that animals may, in desperation, try making their way through long, severely confined drainage pipes with possible dire consequences. I can't imagine there will be adequate headroom for kangaroos to jump through pipes even when they are dry.

Native animals currently access a natural, uninterrupted vegetation corridor between Arrawarra Creek and Arrawarra Beach Road, the proposed entrance to this Rest Area. This corridor also enables these species to travel freely between the vegetation located east and west of the highway, linking the Garby Reserve to the Wedding Bells Forest, and vice versa. This is of significance to some of the arboreal mammals, such as Squirrel Gliders, Yellow Bellied Gliders and Sugar Gliders that are currently able to cross the existing highway by accessing the canopy trees now available near the Arrawarra Creek Bridge.

What is of even more concern now other parts of the upgrade Sapphire to Woolgoolga are well underway it's now quite apparent the RTA has no intention of making a serious attempt to protect wildlfife and motorists from one another. For the most part they have simpley constructed a 5 line barbed wire fence separating people and wildlife from the road corridore they are creating.

Now our Eastern Greys Kangaroos will run the gauntlet of the equivelent of 8 lanes (4x100kph and 2x80kph plus the bit in the middle of the highway left for future expansion) as they make there way east to west, that situation will do nothing to prevent the slaughter witnessed daily by road users I guess until we manage to wipe out out Eastern Grey population altogether.

Stormwater and Climate Change
I also have concerns as to whether the stormwater issue has been adequately addressed, especially in relation to increased run-off from the hard surfaced area of the Rest Area and finished highway. There is bound to be an increased, detrimental impact on water levels at the junction of Arrawarra and Yarrawarra Creeks where the Arrawarra Caravan Park already faces an increasing problem of areas of inundation and erosion on the southern tip of the Coffs Coast Regional Park, (adjacent to Yarrawarra Creek), which contains SEPP 26 Remnant Littoral Rainforest.

In times of heavy rain, water already backs up on the low-lying acreages in the area around Arrawarra Beach Road and Eggins Drive. The raising of the Rest Area with fill will most certainly exacerbate this problem, even without taking into consideration the expected impacts climate change will have on sea levels and rainfall patterns and densities into the future (Coffs Harbour Coastal Processes and Hazards Definition Study and DECC Floodplain Risk Management Guideline, Practical Consideration of Climate Change).

In Summary
In summary I do not consider this latest Rest Area Environmental Assessment Report to be an open, genuine attempt to address the real impact of locating such a facility at Arrawarra. Sadly, the report even goes as far as to mislead the reader when referring to the same mature forested area by stating "mature forest to be protected and retained" (figure 6.1 EA Report Landscape Strategy) when clearly protecting and retaining the mature forest will be impossible, because the report reveals earlier the real intention was to only "retain existing vegetation until required for future highway service centre" (figure 1.1 EA Report Proposed Layout for Arrawarra Service Centre). Which raises another interesting issue. Investigation reveal that at least one licesnse has changed hands for a fast food outlet on the "proposed" site which will eventually accomodate a BP Service Station, Kentucky Fried Chicken, Subway and MacDonalds hardly worthy of the terminolagy "proposed"

It is disappointing, to say the least, that the Environmental Assessment Report has done nothing to address the advice given in several previous submissions. I believe this Environmental Assessment falls way short of the detail required and as such has provided a totally inadequate level of survey. Therefore it should be rejected and a completely new study be commissioned that properly addresses the very real issues present in the area.

thank you for the opportunity to comment

DON'T DO THIS!!!

i think tomatoes r tomatoes potatoes r potatoes so introducing new assets to already existing assets should be the coarse of decision .you have already got green and wild at arrawarra ,and u want to dump a macas and a BP and a KFC at a prestine site , when u already have a commercial site not too far back at woolgoolga i cant understand your thinking , i drive a truck and there is no difference between stopping at woolgoolga and arrawarra accept for the services i may need at woolgoolga when i need to stop and rest ,eg chemist ,doctor, police,etc .instead you choose a lovely hand picked site like arrawarra why ? is it because it has that slight infastucture there, or its too expensive to develope at woolgoolga . in my estimation it is more practical to have a commercial operation in a commercial area and the more we can keep green lets keep green . thank u for letting me have my say ,and please consider what people already have ,and then aprove a development that people don't want .

See attachment.

Mining and Industry Projects
NSW Department of Planning & Infrastructure
GPO Box 39
Sydney NSW 2001
Dear Sir/Madam,
Part 3A Modification 4 - Invincible Mine Extension (07_0127 MOD 4) and
Part 3A Modification 2 - Cullen Valley Mine Extension (DA 200-5-2003 MOD 2)
I object to these proposed modifications to the Invincible and Cullen Valley coal mines because they will adversely impact on the internationally significant pagoda landform complex located on the western edge of the Great Dividing Range in Ben Bullen State Forest. This public forest should be fully protected from open-cut mining in a state conservation area for nature conservation, recreation and tourism.
The coal in this proposal is of poor quality and there are better quality substitute resources that can provide at least 25 years electricity generation by the two power plants in the Lithgow Region. The claim of increased costs to electricity consumers if the Coalpac proposal does not proceed is a wild exaggeration. Nearby underground mines have provided for local electricity power plants for over 20 years.
The proposal will destroy by open-cut mining the unique biodiversity, scenery and geological values associated with the pagoda landform complex. Its outstanding values including a Grassy Box Woodland - a nationally endangered ecological community, many nationally endangered Clandulla geebung shrubs and 2,300 threatened Capertee Stringybark trees. The Planning Assessment Commission recommendation for independent vegetation study should not have been ignored.
The proposal fails to provide the 300 metre minimum buffer recommended by the Planning Assessment Commission from the base of the pagoda rock formations and the open-cut area. The buffer provides protection for wildlife including many Lyre Birds and the threatened broad headed snake. If such a buffer were provided, there would be no mine.
The proposal is less than two kilometres from Cullen Bullen and dust from this project will lead to increased morbidity and mortality in the community from respiratory and cardiovascular disease. Noise, truck movements and blasting will also adversely impact on residents. The proposal intends to vastly increase water extraction from underground workings from 26Ml/year to 750Ml/year, but fails to address the ongoing fires underground and in waste heaps. Where 2Ml/day of water pumped from old workings is to be released in not explained.
The Aboriginal cultural heritage assessment lacks credibility because it did not find a cave art site in the proposed disturbance area for the Cullen Valley Mine. Previous studies had missed other important Aboriginal cave art sites in the area.
Despite Coalpac's claim ecosystems cannot be replanted on farmland and especially after open-cut mining. No mature woodland has ever been established in mine rehabilitation. The biodiversity offsets are inadequate, and cannot replace a Gardens of Stone Stage 2 reserve.
I declare that I have not made any donations to political parties in the last year.
Yours sincerely,
Daniel Barrow

Mining and Industry Projects
NSW Department of Planning & Infrastructure
GPO Box 39
Sydney NSW 2001

Dear Sir/Madam,
Part 3A Modification 4 - Invincible Mine Extension (07_0127 MOD 4) and
Part 3A Modification 2 - Cullen Valley Mine Extension (DA 200-5-2003 MOD 2)

I object to these proposed modifications to the Invincible and Cullen Valley coal mines because they will adversely impact on the internationally significant pagoda landform complex located on the western edge of the Great Dividing Range in Ben Bullen State Forest. This public forest should be fully protected from open-cut mining in a state conservation area for nature conservation, recreation and tourism.
The coal in this proposal is of poor quality and there are better quality substitute resources that can provide at least 25 years electricity generation by the two power plants in the Lithgow Region. The claim of increased costs to electricity consumers if the Coalpac proposal does not proceed is a wild exaggeration. Nearby underground mines have provided for local electricity power plants for over 20 years.
The proposal will destroy by open-cut mining the unique biodiversity, scenery and geological values associated with the pagoda landform complex. Its outstanding values including a Grassy Box Woodland - a nationally endangered ecological community, many nationally endangered Clandulla geebung shrubs and 2,300 threatened Capertee Stringybark trees. The Planning Assessment Commission recommendation for independent vegetation study should not have been ignored.
The proposal fails to provide the 300 metre minimum buffer recommended by the Planning Assessment Commission from the base of the pagoda rock formations and the open-cut area. The buffer provides protection for wildlife including many Lyre Birds and the threatened broad headed snake. If such a buffer were provided, there would be no mine.
The proposal is less than two kilometres from Cullen Bullen and dust from this project will lead to increased morbidity and mortality in the community from respiratory and cardiovascular disease. Noise, truck movements and blasting will also adversely impact on residents. The proposal intends to vastly increase water extraction from underground workings from 26Ml/year to 750Ml/year, but fails to address the ongoing fires underground and in waste heaps. Where 2Ml/day of water pumped from old workings is to be released in not explained.
The Aboriginal cultural heritage assessment lacks credibility because it did not find a cave art site in the proposed disturbance area for the Cullen Valley Mine. Previous studies had missed other important Aboriginal cave art sites in the area.
Despite Coalpac's claim ecosystems cannot be replanted on farmland and especially after open-cut mining. No mature woodland has ever been established in mine rehabilitation. The biodiversity offsets are inadequate, and cannot replace a Gardens of Stone Stage 2 reserve.
I declare that I have not made any donations to political parties in the last year.
Yours sincerely,
Annabel Murray

Mining and Industry Projects
NSW Department of Planning & Infrastructure
GPO Box 39
Sydney NSW 2001

Dear Sir/Madam,

Part 3A Modification 4 - Invincible Mine Extension (07_0127 MOD 4) and
Part 3A Modification 2 - Cullen Valley Mine Extension (DA 200-5-2003 MOD 2)

I wish to object to these proposed modifications to the Invincible and Cullen Valley coal mines for the following reasons:

1. the modifications will adversely impact on the internationally significant pagoda landform complex located on the western edge of the Great Dividing Range in Ben Bullen State Forest.

2. open-cut mining threatens the long-term protection of public land in a state conservation area for nature conservation, recreation and tourism.

3. the proposal will destroy by open-cut mining the unique biodiversity, scenery and geological values associated with the pagoda landform complex. Its outstanding values include a Grassy Box Woodland - a nationally endangered ecological community, many nationally endangered Clandulla geebung shrubs and 2,300 threatened Capertee Stringybark trees.

4. the proposals threatens an important natural environment, and the Planning Assessment Commission's recommendation for an independent vegetation study should not have been ignored by Coalpac in its current environmental assessment.

5. the proposal fails to provide the 300 metre minimum buffer recommended by the Planning Assessment Commission from the base of the pagoda rock formations. Such a buffer, providing protection for wildlife, including many Lyre Birds and the threatened broad headed snake, if provided, there would prohibit a mine.

There are better quality substitute resources that can provide for at least 25 years of electricity generation by the two power plants in the Lithgow Region. Nearby underground mines have provided for local electricity power plants for over 20 years. The risk to the environment is not justified by the extraction of cheaper, poor quality coal.

I support the view that ecosystems cannot be replanted on farmland nor after open-cut mining of native forests. No mature woodland has ever been established through mine rehabilitation. The biodiversity offsets are inadequate, and cannot replace a Gardens of Stone Stage 2 reserve over Ben Bullen State Forest.

I urge that consent to both proposed modifications is refused.

Open-cut mining in the Gardens of Stone region should be stopped.

Thank you for the opportunity to make a submission.

Yours sincerely,

Christopher Levins

At a regional meeting of Rivers SOS in Lithgow, our committee resolved to support action to prevent mining which might threaten the priceless stone pagodas of the Gardens of Stone. Subsequently we attended and helped to organise a rally there, involving hundreds of conservationists, where many saw, for the first time, the unique beauty of these natural structures. The ongoing damage and despoliation of natural beauty spots and tourist attractions in our country: the stone pagodas, the Barrier Reef, the Thirlmere Lakes and several major river systems, must be halted. The greed and corruption of our generation will result in the handing down of a sadly depleted country for future generations. In this case, even the (inadequate) buffer zone of 300m recommended by the PAC is not adhered to. The wild life and habitat surrounding the wonderful stone pagodas is also under threat, all for the sake of low grade coal and the temporary enrichment of so few. We ask you to refuse this plan outright and give adequate protection to one of the country's most beautiful natural wonders.