CURRENT ASSESSMENTS

Ongoing investigations

TRAFFIC

Will the Sand Quarry cause any problems with the additional traffic it generates?

The proposed Sutton Forest Quarry boundary is situated within 60 metres of the Hume Highway. This makes it an ideal location as Quarry traffic will enter the highway at a dedicated entry and exit point, linking the facility directly to the Hume, which will be the primary artery for material leaving the site and for incoming traffic as well. This avoids the need for traffic to use local roads in the vicinity of the Quarry.

While the facility will have a working population of 20 full-time site staff and 30 truck drivers, the daily traffic movements in and out of the site will be approximately 332. To put that into some perspective, the Hume Highway carries approximately 4,300 heavy vehicles a day and 12,600 light vehicles including cars.

No real impacts on the local road system, apart from deliveries and service vehicles that will attend the site, as required. Much of this traffic already exists.

The main volume of truck traffic will exit off the Hume southbound via a dedicated off-ramp deceleration lane and proceed over a grade separation flyover bridge before travelling the 30 or so metres to the Quarry entry point.

Traffic leaving the site will turn left for the northbound lanes and access the highway via an acceleration lane within the existing road reservation zone, 750 metres in length, which will allow these vehicles to join the traffic safely at freeway speed.

As these trucks are leaving individually, no discernable difference in traffic noise should be experienced by local land-owners.

Trucks arriving at the site will be doing under 50kph once off the highway, so noise should not present itself as a factor at these speeds as the engines will be virtually idling. These trucks would only be travelling on a sealed road at the southern boundary of the site. Internal roads as far as the weighbridge will also be sealed to ensure that dust liftoff is reduced.

When preparing the development application and Environmental Impact Statement for this facility, the proposed transport operations were assessed with the Quarry at maximum operating capacity. At this level, the Quarry would be producing 860,000 tonnes of product per annum.

In the Environmental Impact Statement, the access road from the motorway provided a looped design that impacted the existing Kingsbury VC Memorial. Following the reviewed feedback from interested community groups, changes have now been affected to ensure this does not happen.

Identified Issues of Concern

During the public exhibition of the Environmental Impact Statement and accompanying technical assessments, some concerns were raised in relation to the proposed traffic arrangements. These included:

The way the proposed road impacted the Kingsbury VC memorial, which has now been corrected;
The likely impact of the road construction arrangements on properties on the western and eastern side of the new road;
Impacts on traffic flows along the Hume Motorway and specifically the impact on vehicles utilising an existing stopping lane, adjoining the northbound lanes of the Hume Motorway north of the proposed new access road; and
Any likely impacts on traffic movements within the Hume Motorway near the Sally’s Corner interchange access road from the northbound lanes of the Hume Motorway. As the site has its own dedicated entry and exit system – this interchange should not see any noticeable changes at all.

Additional Investigations

Following a review of the traffic concerns raised in submissions to the Department of Planning & Environment, SFQ have appointed additional traffic engineers to review the original proposal, with a view to addressing the concerns raised by members of the community. That review is presently underway and is intended to:

Review overall road geometry and design so that the approach road to the Quarry will not impact the Kingsbury VC memorial;
Review the road design parameters for the entry and exit road on the northern side of the Hume Motorway;
Undertake traffic counts and review the traffic flows within the Hume Motorway, north of the proposed point of entry to the motorway, to provide arrangements that meet safety and Roads & Maritime Services (RMS) guidelines.

Our first step in completing this work will be to seek input from Roads and Maritime Services on the updated design. Once RMS is satisfied with the design we will present this to the community and provide a justification for the updated design. Further assessment of the potential noise and air quality impacts associated with this design will then be presented in the Response to Submissions documents.

SURFACE & GROUNDWATER

Surface Water

The establishment and operation of the Quarry will require the alteration of the natural landform within the identified boundary of the Quarry site. This work has the potential to alter surface water flows, rates and volumes. The EIS states that the establishment and operations could increase the amount of sediment carried in surface water runoff. As part of our obligations to assess any likely impact from surface water runoff, a risk assessment was completed in accordance with the DPE requirements and the respective guidelines for stormwater management. The risks of sediment laden runoff leaving the site and contaminating down stream waterways was assessed as part of the overall EIS process and found to be minimal.

The proposed development was placed on public exhibition by the NSW Department of Environment & Planning (DPE) from 24 May to 21 June 2018. During the exhibition of the proposed development and accompanying documents some concerns were raised in relation to the assessment and impact of surface water as part of the EIS process. The concerns are summarised below:

The impact of drought conditions on the assessment of the surface water models may have had an impact on the outcomes of the investigations.

Analytical data used and evaluated in the surface water modelling was not enough to adequately assess the management and control of surface water and the level of suspended solids within the surface water.
Insufficient sampling was undertaken to ensure that an adequate assessment of the surface waste quality was available for the assessment of any impact and for the conclusions, included within the EIS, to be substantiated as acceptable.
The EIS and associated surface water quality assessment did not adequately interpret the likely or possible impact on the nearby Long Swamp Endangered Ecological Community.

Groundwater

Groundwater around the proposed quarry is used for a range of purposes including, irrigation, stock water, the production of bottled water and other industrial purposes. The nearby creeks and Long Swamp also rely on groundwater. As part of its operations, the Quarry will use groundwater, which will be obtained from a bore located on the Quarry site and is licensed to access up to 45ML per year. The utilisation of and potential for impact on groundwater, in this location was the subject of independent investigations as part of the EIS and development application process. These investigations followed the guidelines provided by relevant government agencies and the findings of those investigations would be within the range of natural variation and satisfied the requirements of the guidelines.

The concerns raised in relation to the assessment of groundwater impacts are summarised below:

The threat to the clean water of the Sydney basin by removing the sand that filters water in the area and that filters water flowing through to the Sydney basin is an immediate threat to our water, our bushland, and our wildlife on a greater scale than suggested in the proposal.
The NSW Aquifer Interference Policy 2012 requires any development impacting on groundwater to have a neutral or beneficial impact on the water quality of the groundwater. The impact on quality is unknown and the cumulative impact is even less predictable.
Blasting the sandstone is likely to increase the permeability of the surrounding rock, thus increasing the flow into the pit. This is not considered in the water study provided in the EIS.
The Council raised concerns that the EIS acknowledges the anisotropic conditions across the area (and identified with the pump tests) and the difficulty this provides in the analysis of the groundwater flows. Given the potential impact on other users of the resource, Council wants to be assured that all possible analysis is undertaken to increase the level of certainty in the groundwater predictions so that no impact can be guaranteed to all other users.
No analysis of the impact of the planned regular (6-12 times per year) blasting on the permeability of the sandstone around and below the pit has been provided. Increased fracturing and greater groundwater movement might be expected.

Additional Investigations

Following a review of the concerns for surface and groundwater quality raised in submissions to the DPE, Sutton Forest Quarries Pty Ltd (SFQ) has requested the Project Hydrologists to review the original proposal with a view to addressing the concerns raised by members of the community. That review is presently underway and is intended to include the following:

Surface Water

Review and expand its consideration of meteorological conditions covering a wider time frame than previously considered.
Undertake a design review of surface water management strategies to ensure that effective and efficient controls are in place to meet water quality outfall guidelines.
Carry out additional water sampling campaigns within the area of Long Swamp so that possible impacts on the quality of Long Swamp and its ecological communities are suitably and effectively mitigated.

Groundwater

Review and assess the overall extraction operations of the Quarry to ensure that every opportunity for the protection and monitoring of the regional groundwater aquifer is considered and put in place as part of any ongoing quarrying activity.
Consider the likely impact on groundwater quality on the basis that blasting will not be included as part of the Quarry’s extraction operations.
Ensure that any recommendation for the ongoing monitoring of the regional groundwater aquifer is robust, efficient and effective.

Any design changes and alterations to the arrangements, proposed as part of the development, will be provided to the DPE in our Response to Submissions (RTS) which is expected to be lodged in June 2019.

ABORIGINAL CULTURAL HERITAGE

Development Proposal

Aboriginal and Cultural Heritage was assessed in conjunction with the preparation of the EIS. The extent to which that assessment was undertaken together with the issues and outcomes of that assessment are provided within Section 5.7 of the EIS, commencing on page 5-105.

During these investigations, the consultants appointed to undertake the work satisfied the requirements of the Director Generals Requirements (DGR’s) in relation to Aboriginal culture and heritage. The investigations included:

Consultation with a range of Aboriginal stakeholder;
A review of previously recorded Aboriginal cultural heritage sites within the area and the locality generally;
The undertaking of a range of field surveys and investigations to identify potential sites of archaeological sensitivity;
The identification and definition of design and operational safeguards to protect identified items of Aboriginal and/or cultural heritage;
A review of the cultural significance of the area and the identification and recording of sites within or immediately adjacent to the proposed development that had not been previously identified or recorded; and
The recommendation of suitable and effective strategies for the ongoing protection of any items of Aboriginal cultural heritage.

Identified issues of Concern

The proposed development was placed on public exhibition by the NSW Department of Environment & Planning (DPE) from 24 May to 21 June 2018. During the exhibition of the proposed development and accompanying documents some concerns were raised in relation to Aboriginal culture and heritage. These included:

The NSW Office of Environment and Heritage (OEH) identified several matters that they advise should be addressed in our Response to Submissions. They are:

The relationship of the rock art site to other recorded sites and Long Swamp.
Consideration of the Aboriginal cultural landscape of the proposed development area.
Additional details and evidence of the Aboriginal community consultation process.
The development of an Aboriginal Cultural Heritage Management Plan prior to approval.
The provision of a methodology for the proposed salvage of Aboriginal objects.
Deciding on the long-term management of any recovered Aboriginal objects.
The inclusion of updated literature review.
The concerns raised by OEH generally covered a range of similar concerns raised by other who made submissions in relation to this matter.

Additional Investigations

Following a review of the concerns raised in submissions to the DPE, Sutton Forest Quarries Pty Ltd (SFQ) has instructed its heritage consultants to undertake addition investigations and site reviews to address the concerns raised by the OEH and members of the community. That review is presently underway and is intended to cover all of the identified concerns.

The results and outcomes of the additional Aboriginal Cultural Heritage investigations will be provided to the DPE in our Response to Submissions (RTS) which is expected to be lodged in June 2019.

AIR QUALITY

Development Proposal

The establishment and operation of the Quarry may result in more deposited dust due to land disturbance, dry screening activities and the movement of heavy vehicles on unsealed roads. The air quality impact assessment, prepared in conjunction with the EIS, concluded that the Quarry would comply with the relevant assessment criteria for Total Suspended Particulates, PM10 and deposited dust for the relevant averaging period. The modelling predictions for PM2.5 were below the EPA criterion at all surrounding residences.

The completed Air Quality Impact Assessment is available for review on the DPE Major Projects website.

Identified Issues of Concern

The proposed development was placed on public exhibition by the NSW Department of Environment & Planning (DPE) from 24 May to 21 June 2018. During the exhibition of the proposed development and accompanying documents some concerns were raised in relation to the assessment and impact of dust as part of the EIS process. The concerns are summarised below:

Identified concerns around maximum predicted annual average levels of PM10 and PM5 are 32 μg/m3 and 15 μg/m3 respectively and indicated that assessment limited to Stages 2 and 4 rather than assessing all stages of the proposal.

A resident located 1.0km from the extraction site raised concerns in relation to the impact of dust on animals and the likely effect of dust on washing and internally within their residence.

The nearby monastery run by the Pauline Fathers is frequently used for both indoor and outdoor religious services. The property is open to the public daily with regular masses held in either English or Polish. Major mass services attract large crowds (more than 3000 people) to the monastery. There is no indication of specific measures that will be taken to protect users of the monastery from emissions.

Raised concerns that dust and other particulate matter will impact adversely on human health in the locality. Some members of the community have identified current respiratory conditions that are likely to be exacerbated because of dust emissions from the Quarry operations.

Additional Investigations

Following a review of the air quality concerns raised in submissions to the DPE, Sutton Forest Quarries Pty Ltd (SFQ) is intending to review the original assessment. That review is presently held in abeyance pending the completion of further traffic investigations, which may have a direct impact on dust generation. Further information will be published on this and the DPE website once those investigations have been concluded.

Any design changes and alterations to the arrangements, proposed as part of the development, will be provided to the DPE in our Response to Submissions (RTS) which is expected to be lodged in June 2019.

NOISE & VIBRATION

Development Proposal

The establishment and operation of the Quarry will require the alteration of the natural landform within the identified boundary of the Quarry site. This work and the operations of the Quarry have the potential to create noise and vibration. The EIS states that the potential noise impacts of the Quarry were modelled and assessed. The modelling confirms that the proposed mitigation measures would be effective in minimising noise impacts to acceptable levels. Predicted maximum noise levels at all locations assessed were well below the noise assessment criteria established by the NSW Noise policy for industry.

Occasional blasting would be conducted in the lower benches of the Quarry as extraction operations advanced. Blasting air blast overpressure and ground vibration levels would be well within the assessment criteria. Blasting would likely occur no more than 12 time per year.

Identified Issues of Concern

The proposed development was placed on public exhibition by the NSW Department of Environment & Planning (DPE) from 24 May to 21 June 2018. During the exhibition of the proposed development and accompanying documents some concerns were raised in relation to the assessment and impact of noise and vibration as part of the assessment process. The concerns are summarised below:

The assessment of the existing acoustic environment indicates that noise levels near the site are dominated by traffic on the nearby Hume Highway and environmental sources. It has been requested that these environmental sources should be clarified.
The Acoustic Report does not include any noise emission assessment of rock saws, crushers, hydraulic hammers or blasting. Blasting is expressly proposed for the development (section 5.3). Rock saws and hydraulic hammers would almost certainly be required, at least intermittently, in Quarry operations.
The Filetron Property located to the north of the Quarry site on the opposite side of Long Swamp Creek. The site is the subject of a 14 lot subdivision that is currently before Council. The subdivision configurations, if approved, will result in the potential for residential development significantly closer to the Quarry.
Some of these properties are religious / spiritual retreat centres of various kinds, meaning that noise and other impacts may compromise their utility moreso than might be the case for other land uses.

Additional Investigations

Following a review of the concerns for noise and vibration raised in submissions to the DPE, Sutton Forest Quarries Pty Ltd (SFQ) will request the project acoustic specialists to review the original investigations and findings with a view to addressing the concerns raised by members of the community. That review will be commissioned following the completion of the review of traffic and access arrangements for the Quarry as vehicle movements have the potential to impact the outcome of those investigations.

The need for blasting at the site has been re-assessed and it has been decided that blasting will no longer be required to complete extraction operations at the Quarry.

Any design and/or operational changes and alterations to the arrangements, proposed as part of the development, will be provided to the DPE in our Response to Submissions (RTS) which is expected to be lodged in June 2019.

ECOLOGY

Development Proposal

The establishment and operation of the Quarry will require the alteration of the natural landform and the clearing of approximately 63.2 Ha of native vegetation, within the identified boundary of the Quarry site. No endangered ecological communities or critically endangered communities have been identified within the proposed Quarry site. Impacts to threatened species was taken into consideration when calculating the biodiversity offsetting requirements. The biodiversity offset assessment identified that 3,901 ecosystem credits and 54 species credits would be required to offset biodiversity impacts.

There is no direct displacement or physical disturbance to Long Swam Creek and potential sediment laden water would be managed and retained within the Quarry. There is only limited risk of impacts to aquatic ecology within the Long Swamp Creek and Long Swamp ecosystems.

Identified Issues of Concern

The proposed development was placed on public exhibition by the NSW Department of Environment & Planning (DPE) from 24 May to 21 June 2018. During the exhibition of the proposed development and accompanying documents some concerns were raised in relation to the assessment and impact of the Quarry on the local ecology, as part of the assessment process. The concerns are summarised below:

Predicted changes in flow rates and impacts to Long Swamp Creek have been calculated by averaging figures over a 45-year period. No specific analysis has been conducted on the impact of reduced flows and lowered water tables on riparian and aquatic ecosystems during periods of heightened risk (ie drought conditions when vegetation communities are under greater stress). Additional analysis of changes to the frequency, duration, and severity of moisture deficits upon riparian and instream communities during drought periods resulting from the proposed development should be undertaken.

The proponent claims that the project will not be subject to the federal EPBC Act. We contend that impacts on Long Swamp Creek and Long Swamp itself are likely to be significant. Long Swamp is listed as endangered under the EPBC Act. Impacts on endangered species in the area affected are also potentially subject to a controlled action under this legislation.

The proponent should prepare an updated Biodiversity Assessment Report (BAR) in accordance with the requirements of the Biobanking Assessment Methodology (BBAM). The BAR needs to include the species credit species which were omitted from the submitted report to demonstrate how proposed offsets would “maintain or improve” biodiversity values in accordance with the DGRs.

Nine threatened species exist within the site, including the powerful owl, gang-gang cockatoo, glossy black cockatoo, scarlet Robin, varied sittella, squirrel glider, eastern bent wing bat, greater broad-nosed bat and large-eared pied bat. The nocturnal species in this list are likely to suffer considerable impact from the 24/7 industrial light and noise pollution from the mine, something inadequately considered in the EIS and documentation supporting an application for Director Generals’ Requirements.

Wingecarribee Shire Council has noted that the project site is in the Great Western Wildlife Corridor (GWWC), which is described in the Wingecarribee Local Environmental Plan (WLEP2010) as a Regional Wildlife Habitat Corridor and is mapped on the Natural Resources Sensitivity Council notes that the corridor is currently under review as part of its Green Web project. The EIS does not discuss the likely impacts on the wildlife corridor, including direct and indirect impacts.

Additional Investigations

Following a review of the concerns for ecology and biodiversity raised in submissions to the DPE, Sutton Forest Quarries Pty Ltd (SFQ) has engaged the project ecological specialists to review the original investigations and findings with a view to addressing the concerns raised by members of the community. In addition, the project ecological specialist will be undertaking further investigations in relation to biodiversity offset strategies associated with this development.

Following the completion of the additional ecological and biodiversity investigations the findings of those investigations, will be provided to the DPE in our Response to Submissions (RTS) which is expected to be lodged in June 2019.

VISIBILITY

Development Proposal

The establishment and operation of the Quarry will require the alteration of the natural landform and vegetation within the identified boundary of the Quarry site. The proposal also includes lighting that will be used at night for security and operations.

Views towards the Quarry from most privately-owned residences would be obscured by topographic features, vegetation and proposed amenity bunds. Glimpses of the Quarry from some residences more than 1.3 km away would be limited. Minimal overall changes in visual amenity would occur because of the development.

Identified Issues of Concern

The proposed development was placed on public exhibition by the NSW Department of Environment & Planning (DPE) from 24 May to 21 June 2018. During the exhibition of the proposed development and accompanying documents no specific concerns were raised in relation to the assessment and impact of the Quarry on views from adjoining properties or other locations within the area of the site, as part of the assessment process.

Additional Investigations

Following a review of the overall development proposal in submissions to the DPE, Sutton Forest Quarries Pty Ltd (SFQ) has not identified any specific issues raised in relation to visual amenity or impact on vistas in this location. Although no specific submissions were identified, SFQ is mindful of the possibility that the operations of the Quarry may impact other landholders in the future. Therefore, to address any possible impacts, SFQ will adopt the following mitigation measures:

Implementing an approved Lighting Management Plan for night operations to manage possible lighting impacts;

All lighting at the site would be directed downwards to ensure light spill is retained within the Quarry boundaries; and

The installation of amenity barriers and the revegetation of non-essential areas of the site would be undertaken to mitigation any likely visual impacts from the operations of the Quarry or Quarry related traffic.

SOCIAL & ECONOMIC IMPACT

Development Proposal

The establishment and operation of the Quarry will require the alteration of the natural landform and vegetation within the identified boundary of the Quarry site. The Quarry will provide a range of employment opportunities in association with both the establishment and operational stages of the Quarry. Employment opportunities will be by way of direct engagement or through contractual agreements. In addition, other local businesses will be able to provide a range of support services to the quarry site.

The results of environmental assessments undertaken to date indicated that it is unlikely that the Quarry would significantly change the existing amenity of the area. It is acknowledged that there could be changes to the local setting and that these changes may be experienced by some community members. Because these changes may be experienced by some members of the community to a greater degree than others, varying levels of sensitivity to these changes may result in perceived land use conflicts.

Identified Issues of Concern

The proposed development was placed on public exhibition by the NSW Department of Environment & Planning (DPE) from 24 May to 21 June 2018. During the exhibition of the proposed development and accompanying documents a range of concerns were raised in relation to the assessment and impact of the Quarry on the social and economic impacts, as part of the assessment process. The extent of the submission received by the DPE varied and they are summarised below:

An objection to the Quarries impact on the social environment. Many people in this area are elderly and retired to the Southern Highlands for its quiet, peaceful ambience and clean air. A 24 hour mine would spoil any pleasant lifestyle for those living near this site.

The EIS does not adequately assess social impacts that may occur because of this application. The Department requests that the RTS provide greater consideration of the proposal’s social impacts, particularly in relation to local amenity, having close regard to the Department’s Social Impact Assessment Guideline for State significant mining, petroleum production and extractive industry development (September 2017).

There has been no community consultation to speak of save a meeting held at short notice on June 2 by the proponent. Most Southern Highland residents were unaware of the meeting and as few as 20 attended. The DPE has not made the local community or Council aware that the project was imminent. Even many directly affected landowners were unaware of the proposed project until very recently and some have not had direct contact with the company at all.

Filetron Pty Ltd owns an extensive land holding immediately north of the proposal and shares a common boundary along Long Swamp Creek with the subject site. At no time has the proponent contacted or engaged with us to discuss the proposal despite assertions of ‘consultation with adjoining land owners’ within the Environmental Impact Statement;

The amenity of properties adjacent to the Quarry will be severely affected and the peace and tranquillity of Penrose Park is likely to be lost, given statements in the EIS that blasting will take place possibly just 0.5km from the Park.

The Shrine of Our Lady of Mercy is immediately adjacent the Quarry site and a huge drawcard to the area hosting more than 10,000 visitors a year. The shrines were set up for people to reflect and pray and it cannot be argued that the noise and air pollution from the Quarry will have none too little effect. As the priest there has said: “they used my consultation words as bullets against me.” This is a sacred place for many people, both local and international. That should be respected and maintained.

Additional Investigations

Following a review of the overall development proposal in submissions to the DPE, Sutton Forest Quarries Pty Ltd notes the specific issues raised in relation to the social and economic impacts on local community. As a result, SFQ has engaged additional consultants to address the range of concerns raised in those submissions. The following is being undertaken:

A review of the methodology for ongoing consultation during the remainder of the project’s assessment by the DPE;

The completion and implementation of a Community Consultation and Engagement Plan that will be implemented in conjunction with the ongoing assessment and evaluation of the project;

Convening additional public information forums as part of the ongoing consultation process;

The creation of a site-specific website (www.suttonforestquarries.com.au) where current information will be available for review and comment. A dedicated email address (info@suttonforestquarries.com.au) will also be available for those seeking further detailed information about the project.

The deletion of blasting from the development proposal; and

The Community Consultation and Engagement Plan is presently being finalised and will be submitted to the DPE as part of our RTS.