__________EcoNetwork – Port Stephens Inc.__________
All correspondence to: Secretary PO Box 97 firstname.lastname@example.org
9 April 2020
NSW Department of Planning Industry and Environment
OBJECTION: Stockton Sand Quarry Dredging
State Significant Development Application No SSD 9490
EcoNetwork-Port Stephens is a grassroots community-based environmental and sustainability network comprising 26 community and environment groups and eco-businesses with a focus on sustainable planning. We are non-party political and do not donate to political parties.
EcoNetwork-Port Stephens submits that this project is not acceptable on multiple grounds and should not be approved.
The sand quarry would significantly increase heavy vehicle movements (for the next 25 years) on a road system which has a number of unsuitable single carriageway sections and which is already overloaded in some areas at peak times. The impact of this proposal on heavy vehicle traffic cannot be considered in isolation from other existing and proposed sand extraction projects relying on the same inadequate road network.
The quarry is located in close proximity to the ‘red-zone’ affected by PFAS contamination originating from RAAF Base Williamtown. Given the uncertainty surrounding the level of risk, it would be grossly irresponsible to approve excavation well below ground and water table level (in Stages 2-6) over a 37ha site, disturbing the soil and affecting the groundwater. The project would involve a significant loss of valuable fauna habitat and other environmental damage, which would continue in perpetuity after the end of mining operations due to the large residual lake.
Along with the proposed mine at Bobs Farm – SSD 6395, this would be one of the first significant sand mines in the area to propose excavation well below groundwater level – most of the other mines are either harvesting windblown sand or taking surface deposits from vegetated land with consents typically limiting excavation to a metre or less below ground level, and above the water table. Excavation below the water table potentially exposes this important aquifer to impacts from short and long term pollution, jeopardising the aquifer as an important water source for the area. As such the proposal for ‘wet-mining’ represents a completely new and uncertain threat to the local hydrology (and ecology).
The EIS states that under the Port Stephens Comprehensive Koala Plan of nManagement (PSCKPoM) ‘The project site is mapped as ‘Supplementary’ Koala habitat …important to the long-term conservation of Koalas in Port Stephens’ (6.7.4) It appears that all of this habitat on the site will be cleared leaving a freshwater pond in perpetuityn(22.2). With the recent devastating and unprecedented fires in NSW over the 2019 summer, koalas are now being considered as endangered and every piece of acknowledged habitat is vital to their survival. Current legislation regarding koalas and habitat loss is therefore out of date and we should wait for a full assessment of impacts before making decisions on koala habitat. Further we submit that the project is not consistent with Direction 14 of the Hunter Regional Plan HRP which identifies the need to protect biodiversity and connect natural areas, despite the attempted re-assurance in the EIS (6.8.1) The permanent lake of approximately 25ha, to be left after the cessation of the quarry mine would significantly decrease the width of the current wildlife corridor.
The EIS suggests that Boral may buy bio-banking offset credits to offset unavoidable environmental losses (discussed above), although other options are mentioned, but no specific proposal is made (9.6)
We have fundamental concerns about the entire bio-banking and offset policy as currently implemented in NSW, and while we have to reluctantly accept that it is currently available to Boral for this project, we submit that the consent authority should not automatically accept that any environmental damage can just be ‘paid off’ with a cash payment to biodiversity protection in other geographic areas which are often of dubious longevity. (Legal action is currently under way against Whitehaven Coal for allegedly failing to secure the necessary biodiversity offsets for its Maules Creek coal mine, signed off on in 2013, which leads one to believe that bio banking offset credits are not a reliable way to compensate for habitat destruction.)
For further detail of our objections, please refer to the Tomaree Residents and Ratepayers Assoc Inc., which is one of our affiliates. We fully support all the of the objections and submissions in the TRRA objection.
Secretary EcoNetwork Port Stephens Inc. 0422 261 057