--REMOVE-- Thanks for downloading this template, it’s intended to help get you writing right

away with guidance on various points to address, feel free to expand upon. Federally they’re

assessing the environmental impacts only as the scope for this letter. If stuck, make sure to

read a lot of the information on www.StopBanksiaMines.com --REMOVE--

[Date]

[Name(s)]

[Address line 1]

[Address line 2]

The Hon Melissa Price MPMinister for the EnvironmentParliament House CANBERRA ACT 2600

By email Melissa.Price.MP@aph.gov.au

Dear Minister Price

RE: SAND MINING, HANSON CONSTRUCTION PTY LTD (PROPONENT)LOTS 53 AND 1320 BANKSIA ROAD (MINING LEASE 70/915, EPBC REF: 2015/7438)

I must state that I strongly oppose the proposals to mine sand in Wellard and Oldbury. I

am also concerned that due process and consideration to the environmental, ecological, health

and safety impacts has not occurred and that the approvals have not been adequately

scrutinised. These concerns are shared by surrounding residents impacted by this mess.

[ADD YOUR OWN PARAGRAPH HERE]

Below are several key areas, which address the seriousness of sand minding and recognise

why others in the community and I strongly oppose the proposal for Sand Mining on Banksia

Road in Wellard.

Surrounding Wetlands:The proposal for Sand Mining of the Conservation Reserves on Banksia Road in Wellard and

Boomerang Road in Oldbury is located amongst four “Wetland” sites as illustrated in

Figure 1: Surrounding Wetlands and Rehabilitated Areas, with specific mention to lots 28 and

29 Boomerang Road (circled region 1) that were rehabilitated with Federal Government funding

under Landcare initiatives between 1994 and 2006, referred to as Boomerang Creek.

Figure 1: Surrounding Wetlands and Rehabilitated Areas

The aim of the rehabilitation project was to repair and enhance the natural ecology of the

Wellard district. The strategy was to connect the highly fragmented areas of good quality

natural bushland including the proposed site. Residents created corridors of natural vegetation

and rehabilitated the existing wetland on lot 28, next door to the proposed mine. Between 1994

and 2006 over 50,000 trees, bushes, rushes and reeds have been planted on the land. The

wetland, as planned, has become a crucial component of the local ecology.

Figure 2: Rehabilitation Beginnings of Boomerang Creek, circled region 1, improving a vital ecological corridor

There was originally extensive wetland areas in this district but most were cleared for

agriculture, therefore the restoration activities that have occurred around the proposed mine

have increased the importance of this area encompassing both sites. The proposed clearing of

the Endangered Conservation Reserve is now in direct contravention to previous planning and

remediation activities to connect these fragmented areas. This mine will interfere with the

groundwater flows crucial to the survival of the wetlands, current modelling does not consider

these surrounding wetlands and is flawed. The approval of this proposal and operation of both

sand mines would directly affect the wetlands and possibly destroy the site negating all the

government funding, and other residents money, hard work and the community’s time that has

been invested. Their investments wasted by Hansons greed to mine highly contentious areas in

close proximity to suburbia.

Figure 3: Todays Thriving Boomerang Creek, circled region 1

West of the proposed sand mines (circled region 4) is home to grandfather Melaleuca Paperbark trees and a thriving ecology, a natural wetland that has also not been considered in the assessment of the Banksia Road and Boomerang Road mine sites.

Figure 4: Nearby wetland (circled region 4) as photographed 4th August 2018

Previous Rejections of this Proposal:Firstly, it must be noted that both the City of Kwinana is strongly against this proposal. It is

incomprehensible that a State or Federal Government department would override the wishes of

the local Councils and ratepayers in this regard. The City has consistently opposed the

proposal to mine sand from Lots 53 and 1320 Banksia Road. A motion was carried at the

Ordinary Council Meeting Minutes from 14 February 2007 and as recent as the 8 August 2018

stated that the proposed sand mine was not supported by the City of Kwinana, for the following

environmental reasons:

i. The proposal will require removal of a significant area of remnant native vegetation

which is in excellent condition, and a significant landscape feature ridgeline.

ii. The proposal does not comply with the Environmental Protection Authority Guidance

Statement No. 3 Separation Distances between Industrial and Sensitive Land Uses,

which, for a Screening Works is a minimum of 500m, noting that there are about 40

residential lots located within 500m of the proposed sand mine premises.

Unfortunately many examples of process non-compliances exist related to this proposal.

An earlier proposal was referred to the Environment Protection Authority (EPA) in March 2009.

The EPA determination, released on 19 May 2009, was ‘Not Assessed’.

PGV Environmental Report:It must be noted a that PGV Environmental, through their own error or pressure by others,

publish a number of false, misleading and contrary statements used to justify the proposed

Banksia Road sand mine.

Acceptance of the proposal with this number of contradictions exacerbates the community’s

concerns and lack of faith in the proponent and Department of Mines and Petroleum to do the

right thing. Upon further scrutiny and comparison to other proposals, it is increasingly evident

that inconsistent assessments and approval outcomes exist and that these mine sites should

not have been approved.

Of particular concern, the Additional Information report commissioned by PGV Environmental

states “The proponent is currently mining a site closer to the wetland to the south-east known

as the Boomerang Road Site.” As of the 7th August 2018 no mining work has been undertaken,

In fact no preparation to commence mining is visible. The environmental and social effects of

mining Boomerang Road have not yet been realised and therefore justifying a new site based

on an existing site is a misleading and deceiving tactic. Detailed satellite aerial imagery is

provided to illustrate the growth (not decline) of the area over a 10 year period, it is evident no

mining activities are occurring.

Figure 5: Aerial Photography of the Banksia Rd and Boomerang Road Sites 26/05/2008

Figure 6: Aerial Photography of the Banksia Rd and Boomerang Road Sites 30/06/2012

Figure 7: Aerial Photography of the Banksia Rd and Boomerang Road Sites 28/06/2018

Banksia Woodlands of the Swan Coastal Plain Listed as Endangered:In September 2016 the Department of Environment and Energy, Threatened Species Scientific

Committee, listed the Banksia Woodlands of the Swan Coastal Plain as “Endangered”. The

area that this sand mining proposal is located on is noted in the surveys provided and by local

knowledge as Banksia Woodland in “Excellent to Very Good Condition”. Most of the surviving

Banksia woodland on the Swan Coastal Plain is degraded. In particular there are few areas

that retain a healthy diverse understorey as currently exists today. The Banksia Woodland is

unique as it has never been cleared, it is dense and rich and includes hollow tree trunks which

aid the nesting of black cockatoos or other fauna.

The Conservation Objective is to mitigate the risk of extinction of the Banksia Woodlands of the

Swan Coastal Plain ecological community, and maintain its biodiversity and function, through

the protections provided under the Environment Protection and Biodiversity Conservation Act

1999 and through the implementation of priority conservation actions. The proposed sand mine

is in direct contravention with the Conservation Objective to which this land is listed.

Under the EP Act, clearing is not permitted where the biodiversity values, land conservation

and water protection roles of native vegetation would be significantly or adversely impacted.

The Banksia Woodlands will be significantly or adversely impacted. The Clearing Permit for the

Banksia Road site was approved in October 2016, one month after the Banksia Woodlands

were listed as endangered. A Review of Section 3 “Assessment of application against Clearing

Principles” defined within the Clearing Permit Decision Report highlights the proposals are

seriously at variance with the clearing principles.

The following impact levels have been assigned to best align to Clearing Principle descriptors in the Clearing Permit Decision Report:

Impact Level Clearing Principle Description Very High Proposal is at variance to this Principle

High Proposal may be at variance to this PrincipleMedium Proposal is not likely to be at variance to this Principle

Low Proposal is not at variance to this Principle

Clearing Permit #6492/1, Issued 27th October 2016 to Hanson’s for the Banksia Road site:

Ref Clearing Principle V.High High Medium Low(a) Native vegetation should not be cleared if it

comprises a high level of biological diversity. x

(b) Native vegetation should not be cleared if it comprises the whole or a part of, or is necessary for the maintenance of, a significant habitat for fauna indigenous to Western Australia.

x

(c) Native vegetation should not be cleared if it includes, or is necessary for the continued existence of, rare flora.

x

(d) Native vegetation should not be cleared if it comprises the whole or a part of, or is necessary for the maintenance of a threatened ecological community.

x

(e) Native vegetation should not be cleared if it is significant as a remnant of native vegetation in an area that has been extensively cleared.

x

(f) Native vegetation should not be cleared if it is growing in, or in association with, an environment associated with a watercourse or wetland.

x

(g) Native vegetation should not be cleared if the clearing of the vegetation is likely to cause appreciable land degradation.

x

(h) Native vegetation should not be cleared if the clearing of the vegetation is likely to have an impact on the environmental values of any adjacent or nearby conservation area.

x

(i) Native vegetation should not be cleared if the clearing of the vegetation is likely to cause deterioration in the quality of surface or underground water.

x

(j) Native vegetation should not be cleared if clearing the vegetation is likely to cause, or exacerbate, the incidence or intensity of flooding.

x

A proposal not at variance to a Principle does not negate any form of environmental impact.

Endangered and Threatened Species:The land that this proposal refers to is an integral part of current wildlife corridors in this area. It

is home to a number of significant species of both Flora and Fauna in particular the

Endangered Carnaby’s Black Cockatoo and the Vulnerable Red Tailed Black Cockatoo. The reports submitted to back this proposal noted the impact on these species to be low as

there were other reserves surrounding this site. This ignores the fact that the species are

endangered and vulnerable because there are insufficient areas of feeding and breeding

habitat remaining. When the area of habitat is so critically low then all areas are highly

significant. We all know that any bushfire can deplete food and breeding sites for a number of

years – which increases the need to conserve adequate areas of bushland to repopulate these

sites.

The surveys listed in the proposal document were carried out in 2007 and 2013 and could well

be out of date. Local residents have noted a very large increase in numbers of both Carnaby’s

and Red Tail Black Cockatoos using this area in the last 4 years. Increased clearing for

housing projects has reduced the area of natural bushland in the Southern Metropolitan Area

and is likely the reason that the populations in this area have increased. We believe it should

be standard practice to take these factors into account.

The report commissioned by PGV Environmental states “The habitat assessment concluded

that Black Cockatoos could use the site however there was no evidence of foraging, roosting or

breeding (Attachment 10).” This sentence should trigger further alarm bells as all local

residents know this to be contrary to the fauna they experience on a daily basis. Evidence of

foraging is pictured below, and where there is foraging amongst undisturbed Banksia

Woodland the likelihood of roosting and breeding is extremely high. The City of Kwinana placed

camouflaged cameras to provided documented evidence of ground foraging:

Figure 8: Carnaby’s Black Cockatoo – Ground Foraging 03/08/2017 (sequence 1 of 3)

Figure 9: Carnaby’s Black Cockatoo – Ground Foraging 03/08/2017 (sequence 2 of 3)

Figure 10: Carnaby’s Black Cockatoo – Ground Foraging 03/08/2017 (sequence 3 of 3)

GPS Tracking of a single Black Cockatoo by a Research Group showed that this bird and its

flock visited the proposed mine site on at least 14 different dates between 11 June and 15

August 2016. This makes the proposed site a ‘Key Foraging Area’ (an area observed to have

been visited for foraging by a flock five or more times; as defined by Birdlife Australia). The

image below clearly indicates both dense movement and active, repeated foraging events at

the proposed sand mine site. It is important to reinforce that the point locations in the figure

below represent a single bird which is both moving and foraging as part of a flock (of, in this

case, 50-150 birds based on direct observations of the flock); so the activity displayed in the

figure below are a large underestimate of actual use of the site by black cockatoos as

transmitters are programmed to switch on at certain times and show a snap shot of activity.

Additionally, given the number of known roosts in the area it is likely there would be more than

one flock using the area, or flocks of more than one species (given the tracking is only one

Carnaby’s cockatoo flock, to which the transmitter-attached bird belonged). The source of the

data is currently protected and can be provided upon further discussions occurring.

Figure 11: 2016 research of an adult female Carnaby Cockatoo

Remember, the report commissioned by PGV Environmental states “The habitat assessment concluded that Black Cockatoos could use the site however there was no evidence of foraging, roosting or breeding (Attachment 10).”

Furthermore, the following images are from video footage recorded by a local resident whose

property shares a common boundary with the proposed mine site. Video footage can be

provided on request which illustrates the Black Cockatoos foraging amongst the Banksia

Woodland proposed to be cleared. Large flocks of Black Cockatoos have been a near daily

occurrence in July and August 2018. Pictured below is a relatively small flock compared to

most other encounters.

Figure 12: Carnaby Black Cockatoo’s - Above Ground Foraging 06/08/2018 (sequence 1 of 2)

Figure 13: Carnaby Black Cockatoo’s - Above Ground Foraging 06/08/2018 (sequence 2 of 2)

Die Back:The City of Kwinana states that the site has two areas of dieback, one being within the area

proposed to be mined. The management plans included are insufficient to guarantee that

dieback won’t be further dispersed by the mining activities or dispersed through transport of

material from the site to other sites. The risk of spreading dieback within and beyond the site

posed by this activity is considerable and contrary to the Threat. The approved Mine Proposal

and Closure Plan has no reference to dieback within the document and only broadly references

dieback in a draft document attached which the proponent states as being adequate to address

the dieback risks on site. The proposed methods are insufficient to mitigate the risk of spread of

dieback.

Impact on Residents:The proposal benefits are so small and benefit so few that it is incomprehensible that the

community would be burdened with such impacts. The hours of operation are 6 days a week,

7am to 5pm. The hours of operation combined with the reduced buffers are going to impact

negatively on the amenity and well-being of adjacent property owners. There is likely to be

significant increase in noise and thus complaints upon implementation of the proposal. They

will argue that “sand is a much-needed resource” but in reality, there are sand mines nearby

that are not operating or occur in areas with more appropriate zoning and adherence to buffer

zones.

Buffer Zone:The proposal has been approved with considerable reduction in buffers recommended by the

EPA in the Guidance for Assessment of Environmental Factors. This guidance document

states that a buffer of 300-500 metres is appropriate for the type of extractive industry

proposed. The Mining Proposal and Remedial Action and Management Plan confirm the use of

screening and sieving machinery. This states the buffer between this industrial activity and

sensitive land uses is 500 metres. The buffers proposed by this activity are reduced by

unacceptable levels up to 80%. This is a considerable reduction that will have significant

impacts on adjacent residents. This will increase health, safety and environmental impacts,

considering typical emissions that may affect the amenity of nearby sensitive land uses

(gaseous and particulate emissions, noise, dust, odour). The buffer zone is inadequate

considering minute dust particles can travel for kilometres and particle density will vary

significantly dependent upon weather conditions and distance from the mine.

Even if a 40% reduction in the buffer zone was approved, reducing the effective no-residential

exclusion zone from 500 metres to 300 metres (the minimum range stipulated for the extractive

industry proposed), there is no land available to be mined as it would not be possible to mine

the narrow corridor due to boundary requirements and safe operating distances.

Figure 14: 300 metre radial exclusion plots around nearby residents

Silica Dust:The Cancer Council of Australia states that silica dust (crystalline silica) is found in some stone,

rock, gravel and clay. When Silica sand is mined it is realised into the air as fine dust known as

respirable crystalline silica or silica dust. What we’re learning today about Silicosis is following

a similar path to Asbestosis, Silicosis is the new Asbestosis.

Today, all States and Territories in Australia have work Health and Safety laws that explain

duty of care for employers and workers responsibilities. Local residents will be repeatedly

exposed to this toxic dust, according to Hanson’s own Safety Datasheet: Repeated exposure to

the dust, as to be experienced by surrounding residents, can result in increased nasal and

respiratory secretions and coughing. Inflammation of lining tissue of the respiratory system may

follow, carrying risk of causing serious and irreversible lung disease, including bronchitis, and

silicosis (scaring of the lung) plus many more. The Cancer Council of Australia also states that

Silica dust is harmful when inhaled into your lungs. As is it 100 times smaller than a grain of

sand, you can be breathing it in without knowing. Furthermore, exposure to silica dust can lead

to the development of lung cancer, silicosis, kidney disease and chronic obstructive pulmonary

disease. It is estimated that 230 people develop lung cancer every year because of past

exposure to silica dust at work. Not all exposed workers will develop cancer, cancer risk

increases with long term or repeated high-level exposure. Therefore, the residents that

surround the proposed sand mining operation are at a high risk of developing cancer due to

long term exposure of silica dust.

Hanson Safety Procedures require the use of Personal Protective Equipment (PPE) as part of

their Duty of Care to material handlers of quarry products including those extracting sand

(mining), this Duty of Care includes the use of breathing apparatus and hermetically sealed

machinery cabins with dust and toxin filtering air condition systems. It therefore cannot be

comprehended how the stringent use of PPE and safety precautions is required for Hanson

employees or contractors, yet the neighbouring properties exposed to the exact same risk are

not required to have any protective equipment. Dust suppression controls can only ever

suppress at best, there is no guaranteed containment in an open environment, therefore

unacceptable risk exists to residents included in the EPA buffer zone and outer estate residents

depending on the weather conditions and wind direction. The location of the proposed sand

mine is simply not suitable for the operating environment and operating context.

It is mentioned the use of chemical additives where appropriate will also be used, the chemical

composition is unknown and therefore its solubility and impacts to the water table and

surrounding flora and fauna are unknown and present risk associated with this activity.

Water: All residents in this area rely on rainwater. Approval of this proposal would see residents having

to buy clean drinking water and incur additional costs to ensure the stored water is not at risk of

contamination, or risk drinking contaminated water. As rural residents are not on town supplied

water, we are reliant on our roofs as the primary catchment for our water supply. The

settlement of crystalline silica and lead-oxide dust on to our roofs will cause the contamination

of our collected water, a vital source used for fresh drinking water and general use. There is no

proposal to reimburse residents for costs incurred in having to purchase water from alternative

sources, modify existing water storage systems to prevent contamination from airborne, or

expenditure on ongoing water quality monitoring and filtration systems required to ensure clean

drinking water is available.

Many of the local bores depend on the surface aquifer which the excavation of this sand mine

will affect. 60 Million Litres of annual draw from the Banksia Road sand mine alone will certainly

impact the water table of surrounding Banksia Bushland and local bores, the annual draw from

the Boomerang Road sand mine is not listed therefore the cumulative impacts are not known.

There is nothing to prevent both the Banksia Road and Boomerang Road mines extracting vast

quantities of water at the same time, depleting the natural available resources. There is no

proposal to reimburse residents for costs incurred in having to re-drill or relocate local bores

used to sustain the local ecology.

Wetlands exist in the opposite quadrants to the proposed Banksia Road and Boomerang Road

sand mines, significant quantities of water drawn from the water table (as proposed) will have

devastating affects to surrounding wetlands. In the reports provided by PGV Environmental

there is inadequate recognition or assessment of the areas circled in Figure 1: Surrounding

Wetlands and Rehabilitated Areas.

Acid Sulphate Soils:The wetland zone is a high risk area for acid sulphate soils. The project is guaranteed to lower

the groundwater table, potentially exposing acid sulphate soils and resulting in heavy metal

pollution of the groundwater table.

Lead-Oxide:The methods proposed in the remediation plan are ignorant of the chemistry relevant to lead

contamination in organic sands and the ameliorating ability of soil pH to significantly reduce

mobilisation of heavy metal contamination. The mobility of lead contamination at the site is

being rendered negligible by the soil pH as demonstrated by the City of Kwinana’s ongoing

groundwater monitoring program which indicates that lead has not impacted groundwater at the

site.

The proposed remediation methods will introduce considerable abrasive forces which will likely

break the weak bonds that will increase lead mobility. The lead oxides are highly soluble at this

point and the remediation plan introduces and exacerbates the potential exposure pathways to

environmental and human receptors, being inhalation of dust created at the site and increased

mobility of lead to groundwater resulting from site dust control measures.

The stated benefits relating to the remediation of the lead contamination are over emphasised

in the associated reports as is the risks posed by the site and the area requiring remediation.

The site does not have to be mined if remediation is required. A more detailed, scientifically

based and Western Australian Accredited Auditor approved rehabilitation plan would be more

successful and have less risks than the plan included in the public notice documentation.

Closing:

Significant new or additional information justifies the reassessment of the issues raised by the

proposal:

1. Subsequent to the EPA decision to not assess the proposal, the affected bushland has

been listed as a Threatened Ecological Community under the Environmental Protection

and Biodiversity Conservation Act 1999 (EPBC Act);

2. The City of Kwinana commissioned a report by GHD, which found the reserve to have

excellent biodiversity values both for its size and its particularly high habitat value for

fauna species due to the variety of microhabitats and various resource niches available

(i.e. fallen logs, hollow logs, leaf litter, sandy soil);

3. The Conservation Reserve is now of sufficient size, shape and condition to be

considered Regionally Significant;

4. The City of Kwinana has determined that the Reserve contains areas of ‘pristine’

vegetation so environmentally significant that there is now no minimum area threshold

for referral of proposals to clear such areas to the Department of Environment and

Energy;

5. The City of Kwinana has determined that the proposed clearing would be at variance to

at least eight (8) of the ten (10) clearing principles; and,

6. Banksia Woodlands were listed prior to the approval of the Clearing Permit and should

have been considered by the Department of Mines.

7. The cumulative impacts of both Banksia Road and Boomerang Road mine sites

operating has not been assessed, as only a road divides the two mine sites they should

be assessed as one single larger site with consideration to four (4) nearby wetlands.

The Department of Mines and Petroleum has made a decision on a significant proposal of a

prescribed class without referring the matter to the EPA as required by the EP Act. Both sites

have been reviewed in isolation without full assessment by the EPA of cumulative impacts.

I am concerned that due process and consideration to the issues mentioned has not occurred,

at best reeking of incompetence by those involved and at worst, corruption. Acknowledging this

was a decision by the previous Government, who passed all consequences to the current

Government, I ask the current Government to make amends and revoke Mining Lease 70/915

(Lots 53 and 1320 Banksia Road) and revoke approvals for an adjacent proposed sand mine

on Lot 6 Banksia Road and Lots 300 and 301 Boomerang Road.

Please note my request for action and my strong objection and prevent this unwanted, low

benefit, high environmental impact and massive community cost project from proceeding.

Yours Faithfully,

[Name(s)]

Email:

Phone:

CC: Rod Whyte rod.whyte@environment.gov.au

(Director, Projects Assessments West Section Department of Environment)

CC: Mallory Owen mallory.owen@environment.gov.au

(Projects Assessments West Section Department of Environment)

CC: Stephen Dawson minister.dawson@dpc.wa.gov.au

(WA Minister for Environment)