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Information Response MCU12/0216
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Resources. Environment. Land Use Planning
2 April 2013
Our Ref: 1271_DA1_320_001
Council Application Ref: MCU12/0216 ;>
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Attention: Marcus Brennan (Assessment Manager) ,,>), .;l
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Dear Marcus
INFORMATION REQUEST RESPONSE
S278 SUSTAINABLE PLANNING ACT 2009
DEVELOPMENT APPLICATION FOR A DEVELOPMENT PERMIT FOR MATERIAL CHANGE OF USE _
EXTRACTIVE INDUSTRY (INDUSTRIAL BUSINESS TYPE 3 EXTRACTIVE) AND ASSOCIATED _
ENVIRONMENTALLY RELEVANT ACTIVITIES (ERAs) 16(2)(c) AND 16(3)(b) ON LAND SITUATED AT 300
KENNEDYS ROAD AND 271 LAKE MACDONALD DRIVE, LAKE MACDONALD QLD 4563
(DESCRIBEDAS LOT 2 ON SP108094 AND LOT 3ON SP108094)
SUNSHINE COAST REGIONAL COUNCIL APPLICATION REFERENCE:MCU1210216
On behalf of the applicant, CSR Building Products Limited ("CSRlJ), Groundwork Plus provides the following
response to Sunshine Coast Regional Council’s ("Council") Information Request dated 12 February 2013 relating to
the abovementioned application.
This response comprises a response to all of the items in Council’s Information Request and as such, it is
requested that Council continue with their assessment of the application.
Pursuant to Section 278 of the Sustainable Planning Act 2009, we provide the following response to Council’s
Information Request:
Issue
It is understood that the mines have approximately 7 to 12 years of clay material available for use in making bricks
and that were this to continue the material would be mined over a long period of time. This proposal comparatively
seeks to remove the material in a much shorter, intensive period (i.e. 2 years) and therefore has the potential to
have greater or additional impacts.
Information Required
1 A comparison between the past operations that have been conducted under current approved
Environment Authority for the mining lease and the proposed operations. This should include:
(a) extraction rates;
(b) intemal and external vehicle movements;
(c) staff numbers; and
(d) machinery/equipment required. ~~ <Z;~~.~~~
ecs Cf33
Level 2, 15 Lang Parade, Milton Qld 4064 PO Box 1779, Milton Be. Old 4064
www. groundwork.com.au
I P: +61738710411
ABN: 80 829145 906
F: +617 38710021 E: [email protected]
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RESPONSE:
A comparison between the past operations that have been conducted under the current approved Environment
Authority for the mining lease and the proposed operations on-site are as follows:
(a) Extraction rates:
The proposed rehabilitation of Neales Quarry and White Pit Quarry will involve the extraction of up to 900,000
tonnes over a 2 year period (Le.450,000 tonnes per annum).
The total extraction volumes conducted under past operations (under the existing approved Environment
Authority for all of the CSR mining lease operations in Cooroy) was 178,000 tonnes per annum. The
extraction rate for the Westridge Quarry site was 65,000 tonnes per annum.
Although the proposal involves increasing the extraction rates from the Westridge Quarry, our representations
below demonstrate that.the increase will result in negligible environmental impacts on the surrounding
environment and Council’s road network.
(b) Internal and external vehicle movements:
External Vehicle Movements and Vehicle Movements at the Brickworks Factory Site
The Traffic Impact Assessment Report prepared by TIM Consulting (SC) Pty LTD (’TIM"), included as
Attachment 7 of the Planning Assessment Report submitted to Council, identifies that a total of 60,000 vehicle
movements over the life of the project (Le. 2 years) for the proposed operations will be required to enter and
exit the Site in order to haul the extracted material to the re iving sites (Le. Neales Quarry and White Pit
Quarry). This represents 30,000 movements per year x 2 years.
CSR have advised that this is less than the vehicle traffic movements for the past mining lease operations
associated with the former brickworks operation.
CSR have advised that approximately 32,400 vehicle movements were generated by the brickworks operation
over a 1 year period (for the past operations) for haulage of material into the brickworks factory site and
delivery of brick products to the market.
As such, the traffic volumes for the proposed operations are less than the traffic volumes for the past
operations associated with the brickworks factory.
It should also be noted that the former brickworks operation, owned by CSSR and located on Lot 2 on
SP108094 will not be operational during the life of the proposed operations.
Internal Vehicle Movements
The internal vehicle movements will increase from approximately 4,433 vehicle movements per year to 30,000
vehicle movements per year however this will be limited to a 2 year extraction period. The internal vehicle
movements on-site will be managed appropriately by the approved Site Based Management Plan ("SBMP")
which outlines measures for the following:
. managing driver behaviour;
maintaining internal haulage roads in a safe and convenient standard; and
managing noise and dust impacts to approved environmental standards.
The SBMP includes provisions to address any non compliance issues in the event they arise.
It is also relevant to note that the Site is located in a rural setting adjacent to other primary industry activities
and the nearest sensitive receivers are located a substantial distance from the proposed internal haulage
areas (approximately 300 m) and extraction pit (approximately 550 m). The house located closest to the
Brickworks factory at Lot 1 RP127728 is owned by CSR. Therefore, it is expected that the proposed
development can comply with the relevant environmental standards without the need for mitigation measures.
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(c) Staff numbers:
The permanent full-time Site workforce for the proposed operations will be approximately three (3)persons. It
is estimated that five (5)drivers will be required in addition to the three (3)permanent full-time staff.
CSR have advised that the number of staff associated with the past mining operations and brickworks
conducted under the existing approved Environmental Authority for the mining lease is well above the three (3)
persons and five (5)drivers for the proposed operations.
As such, the reduction in staff numbers for the proposed operation in comparison to the previous operations is
anticipated to reduce impacts on the surrounding area.
(d) Machinery I equipment required:
All extraction activities included as part of the proposed operations will be undertaken in a manner consistent
with the past operations over the land and will comprise the following equipment and facilities:
bulldozer or similar earthmoving equipment (stripping topsoil and overburden material, land forming and
rehabilitation);
hydraulic excavator (for material extraction);
. front end loader (for stripping, product haulage to stockpiling areas and out-loading);
. other equipment may be required on an occasional basis (e.g. grader, water truck, 4wd for site
maintenance, etc.)
As such, the machinery and equipment included as part of the proposed operations will not cause additional or
different impacts to the machinery and equipment previously utilised in the mining operations.
2 Where there is found to be a change or increase in the intensity of the operations, provide the following
details to demonstrate that the site can be designed and operated in such a way that will avoid causing
significant adverse impacts to the surrounding area in terms of changing air, acoustic, visual, and
stormwater qualities:
(a) A Stormwater Quality Management Plan that demonstrates compliance with the following codes and
release limits:
(i) Water sensitive design code (Noosa Pian);
() Erosion and sediment control code (Noosa Pian);
(i) Water quality release limits as published in the current mining permit issued by DNRM.
The submitted storm water management report should address the following points:
(i) Diversion of clean water catchments at the site to minimise cross contamination of
storm water;
() Demonstrate that the proposal can satisfactorily incorporate suitably acceptable and viable
stormwater quality treatment measures at the site to achieve the required water quality
discharge requirements (i.e. water quality release limits);
() Appropriate storm water management controls at the site to cater for all proposed stages of
quarry operations, which includes:
a. Nomination on plan of Erosion and sediment control structures (including sediment
basin sizing and location).
b. Sediment basin management and maintenance plan, which outlines flocculation
methodology and timing.
(iv) A water quality monitoring program for the site including event based and receiving water
quality monitoring;
(v) An operation and maintenance plan for all water quality treatment measures proposed at
the site and including an inspection and maintenance program; and
(vi) The separation of uncontaminated and potentially contaminated areas of the site.
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(b) An acoustic impact assessment which demonstrates that proposed use will not adversely impact on
the existing ambient acoustic environment and surrounding sensitive land uses. In particular, the
assessment is to include, but is not limited to:
(i) All mechanical plant and equipment used for extractive and screening purposes capable of
emitting noise beyond the site boundary; and
(ii) Trucks and service vehicles entering and leaving the site and any associated road traffic
noise impacts.
Where the assessment identifies impacts that require mitigation, the assessment report must provide
recommendations for noise amelioration accordingly.
(c) An air quality impact assessment which demonstrates that proposed use will not adversely impact on
the existing air quality and surrounding sensitive land uses. Where the assessment identifies impacts
that require mitigation, the assessment report must provide recommendations for amelioration
accordingly.
RESPONSE:
Although the proposed operations will result in increased annual extraction volumes in comparison to the past
operations that have been conducted under the existing approved Environmental Authority for CSR’s mining lease
operations, the proposed operations on-site will be undertaken in a manner consistent with the disturbed areas
(from the previous mining activities) over the land. Impacts on the environment will be limited as all proposed
activities will be within existing disturbed areas with no extension outside of the existing mining lease operational
area. In addition, the proposed operations will not result in an increase in vehicle movements (on the extemal road
network and within the Brickworks precinct), staff numbers or number of machinery and equipment on-site.
The proposed operations will be guided by the SBMP prepared for the Site, which was included as Attachment 8 of
the Planning Assessment Report submitted to Council. The SBMP provides a framework for environmental
management on the Site and is a practical guide at the operational level. The SBMP has been prepared to assist in
the management and protection of surrounding environmental values and describes how the operator proposes to
manage potential environmental impacts which may be caused as a result of the proposed activities.
The SBMP prepared for the Site includes:
. a Stormwater, Erosion and Sediment Control Plan ("SESC Pian") to effectively manage changes to the
hydrological regime, treatment of stormwater from disturbed areas of the Site and management of water
quality on the Site. The SESC Plan includes calculations on the required storage capacity of sediment basins
to achieve relevant water quality objectives. The Department of Environment and Heritage Protection ("EHP")
has issued conditions of approval which outline appropriate water quality objectives for the quarry. The SBMP
includes strict monitoring and reporting requirements to ensure that CSR comply with the relevant standards.
Detailed Stormwater Quality Modelling (such as MUSIC modelling) is inappropriate for assessing development
applications for extractive industry in rural areas (refer to the MUSIC modelling application requirements). The
State Planning Policy for Healthy Waterways only applies to urban areas. Given that the Site is located in a
rural environment, the requirement to undertake a detailed Stormwater Quality Management Plan is
inconsistent with the State Planning Policy. Therefore, the SCEC Plan has been prepared in accordance with
the relevant sections of the Water Sensitive Design Code and Erosion and Sediment Control Code of the
Planning Scheme. The conditions of approval and Site Based Management Plans provide appropriate
controls for managing water quality at the Site; and
. Noise and Dust I Air Quality management procedures that will be employed to maintain environmental values
and standards in accordance with relevant regulations, policies and conditions. In addition, buffers between
operations and adjacent residents / residential areas will be maintained. The Site is located in a rural setting
adjacent to other primary industry activities and the nearest sensitive receivers are located a substantial
distance from the proposed internal haulage areas (approximately 300 m) and extraction pit (approximately
550 m). The house located closest to the Brickworks factory at Lot 1 RP127728 is owned by CSR. EHP has
issued conditions of approval which outline appropriate air quality and acoustic objectives for the quarry. The
SBMP includes strict monitoring and reporting requirements to ensure that CSR comply with the relevant
1271_da1_320_001_130402_ltro_council_response to info request.doc 4
Page 5
standards. Therefore, the conditions of approval and Site Based Management Plans provide appropriate
controls for managing air quality and acoustic impacts at the Site.
Issue -
Rehabilitation
It is understood that the extraction activity would be completed in 2 years and that the clay resource would be
exhausted at such time.
Information Required
3 Provide a detailed rehabilitation plan that is coordinated with the site ecological assessment.
4 The rehabilitation plan must also include the following:
(a) revegetation layout on A3 plans at a scale of no greater than 1:500, including a scale on the plan;
(b) A species palette incorporating the species selection of only native indigenous species;
(c) Near to equal numbers of each species to be used within the relevant re-vegetation areas of the
buffer so that one species ofplant is not over or under represented on the site;
(d) Measurable and achievable criteria on which the performance of the floristic component of the re-
vegetation strategy can be assessed annually over three years;
(e) Measurable and achievable criteria on which the performance of the structural component of the re-
vegetation strategy can be assessed annually over three years;
m The re-vegetation plan must nominate a total bond amount of 1.5 times the schedule of works
estimate of costs (plus GST) for the re-vegetation works, including maintenance for at least three
years of growth;
(g) Details and treatment of any water body.
RESPONSE:
In accordance with the Ecological Assessment Report and Plan of Operations for the Site, rehabilitation works will
be required prior to the surrender of the mining lease over the Site. Disturbed areas will be rehabilitated to a stable
landform with appropriate vegetation establishment. The final landform will comprise shallow excavations with
gentle sloping batters vegetated with native grass cover for grazing purposes. Pasture grasses already located
within the area shall be the preferred species for initial stabilisation of rehabilitated landform areas. Refer to
FIGURE 10 -
CONCEPTUAL REHABILITATION PLAN attached.
It should be noted that:
1. final batters will be no greater than 1:3 slope;
2. batters and the floor of post extraction area are to be grassed with a suitable native pasture species (i.e.
Setaria sphacelata);
3. pasture grass species selected will be subject to availability (it is anticipated that pasture grasses already
located within the area shall be the preferred species); and
4. all water storages on-site will be retained for beneficial reuse as farm dams (i.e. stock watering), not as
treatment devices. No ongoing maintenance for treatment of water bodies will be required.
In addition, re-vegetation I rehabilitation of the Site will be managed by:
1. monitoring of th vegetation establishment will be carried out on a periodic basis as follows:
i. 1 month after seeding;
ii. 3 months after seeding;
iii. 6 months after seeding; and
iv. 12 months after seeding;
2. monitoring will investigate the following and data will be recorded in a logbook or on field sheets:
i. occurrence of woody weeds (approximate coverage in %,common name or species if known); and
ii. broad assessment of soil stability; and
1271_da1_320_OOl_130402_llro_council_response 10 info request.doc 5
Page 6
3. photographs of the Site should be taken and records kept for performance assessment over the monitoring
period.
The EHP conditions of approval outline appropriate requirements for the rehabilitation of the Site which are
generally consistent with the mining lease rehabilitation requirements. The Rehabilitation Management Plan has
been prepared in accordance with these conditions. It is unreasonable to require a higher standard of rehabilitation
for extractive industry compared with the requirements of rehabilitation for the mining activities (e.g. extensive
planting schemes) because the two activities have an identical land disturbance footprint and impacts.
Information Required
5 Please provide written confirmation that the material quarried on-site is only to be used for works on the
receiving site (Neales Quarry).
RESPONSE:
As mentioned in the Planning Assessment Report (reference: 1271_DA1_310_001) submitted to Council as part of
the Development Application, CSR confirm that the material quarried on-site will be utilised as clean fill in the
rehabilitation of CSR mining leases to the south of the Site in order to establish an appropriate landform to facilitate
post extraction land uses. The CSR owned mining leases to the south of the Site, to be rehabilitated, are described
as:
. Neales Quarry: 125 Lake Macdonald Drive, Lake Macdonald QLD (described as Lot 8 on RP160703 and Lot 2
on RP852009); and
. White Pit Quarry: 93 Lake Macdonald Drive, Lake Macdonald QLD (described as Lot 101 on SP142407, Lot
140 on MCH978 and Lot 3 on RP137375).
Pursuant to Section 278 of the Sustainable Planning Act 2009, please accept this correspondence as a response
to all of the information requested.
Should you have any questions in relation to this matter, please do not hesitate to contact Mr Andrew Lyndon as
referenced below.
Yours faithfully
7j;;fUS
Clayton Hill
General Manager
Contact: Andrew Lyndon, Manager of Planning and Environment
Email: [email protected]
Enc/s:
. Figure 10 Conceptual Rehabilitation Plan (Drawing No. 1271.049)
_
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Page 7
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Legend: Notes:
Monitoring of performance:
Site Boundary 1. Final batters to be no greater than 1:3 slope. 1. Monitoring of the vegetation establishment will be carried
Cadastral Boundary 2. Batters and floor of post extraction area to be grassed with a suitable out on a periodic basis as follows:
native pasture species (e.g Setaria sphacelata). 1.1. 1 month following seeding
Cadastral Boundary (Watercourse)
3. Pasture grass species selected will be subject to availability. 1.2. 3 months following seeding
_ Grass seeded rehabilitation 4. All site water storages will be retained for beneficial re-use as farm 1.3. 6 months following seeding
dams (ie for stock watering), not as treatment devices. No ongoing
_ Water Storage retained farm dam as
maintenance for treatment of water bodies will be required.
1.4. 12 months following seeding
2. Monitoring will investigate the following and data will be
recorded in a logbook or on field sheets:
2.1. occurrence of woody weeds (approximate coverage in
%,common name or species if known)
2.2. broad assessment of soil stability.
3. Photographs of the site should be taken and records kept
for performance assessment over the monitoring period
West Ridge Quarry Figure 10 Conceptual Rehabilitation Plan
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Nearmap 2012. Image dat-= 20t’.11.()8
~ CSR Building Products Limited
Page 8
GROUNDWORK PLUS
PO Box 1779
Milton Be QLD.cGS4 Austraffa POSTAGE
Ph: 07 3871 ,"t
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GROUNDWORK PLUS ae POSTAGE |
PO Box 1779 Prepaid Labe'
Milton BC QLD 4064 Australia a PAID
Ph: 07 3874 0844 \ AUSTRALIA
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