SUSANNAH VALLEY - Beautiful but Oh So Badly Abused

- from WalkGPS.com  Nov.- Dec. 2012

 

The Issue?    |   Links to info.    |    The Impacts?    |   The Way Forward 

 

 THE ISSUE?

The much-loved but long-abused Susannah Valley is to be further degraded by the proposed expansion of quarrying operations. Many of those who know and love the area were among the 241 who recently registered to City of Swan (CoS) their objections to the expansion. Despite the strong community concerns, CoS voted at a Council meeting on 12 December 2012 to approve the expansion. Council attempted to paper over its decision with a 'Claytons' reduction of the proposed 20-year Licence term to a renewable 5-year term with soft conditions. Their recommendation to approve the Licence now goes for final rubber-stamping to the WA Planning Commission (WAPC; currently chaired by an ex-City of Swan CEO).

Many local bushwalkers will know Susannah Valley as a beautiful valley that opens across the Darling Scarp north of Red Hill, 23 kms northeast of Perth city. The area has great value for its high aesthetic appeal, including a fascinating landscape with aspects that are becoming quite rare along the Darling Scarp, including flowing streams and an amazing diversity of wildflowers and vegetation types.

The 'Darling Range Regional Park' in Susannah Valley is now a Class A Reserve, the most protected type of Crown (public) land in Western Australia. That supposedly protects a portion of the lower valley across the Scarp, but upstream Susannah Brook and its many feeder stream courses flow through an 8 sq km area of 'Rural'-zoned freehold land owned by Hanson Construction Materials (*Hanson) who operate the major Red Hill Quarry Pit immediately north of Toodyay Road.

In view of its high conservation values and many other very special features, most visitors to the area are shocked to learn that the Valley area directly upstream of the Class A Reserve has no 'reserve' status and remains unprotected under Hanson ownership for potential future mining expansions.

In mid-2008 Hanson released its original proposal to substantially expand the area of its current quarrying operations to the north and northwest including an area now known as 'Area A' on the above image and map below). The original proposed expansion area also extended due northward deep into the Valley. That latter portion was rejected; however the Minister for Environment; Water (The Hon Bill Marmion) on 9 October 2012 approved the quarry extension across Area A.  The Minister's approval disregarded the Environmental Protection Authority's (EPA) strong recommendation that the whole expansion proposal should be rejected.

The EPA's rejection of the original application was summarised as follows in their media statement of 31 January 2011:

 

‘Implementation of the proposal would lead to the destruction of six Aboriginal heritage sites that are of high significance to the Nyungah people of the Perth region,’  Dr Vogel said.

This would not meet the EPA’s objective to ensure that changes to the biophysical environment do not adversely affect historical and cultural associations,’  he said.

‘Another impediment to recommending approval is that visual impacts cannot be reduced sufficiently for this proposal.

‘Also, the EPA’s objective for landscape and landforms, to maintain their integrity, ecological functions and environmental values, cannot be met.

‘Finally, the impact to faunal assemblages and the loss of connectivity between habitats and the adjoining conservation reserves, especially in the western section of the proposal site, does not meet EPA objectives.’

‘The proponent has not fully implemented an existing approval for the Red Hill quarry [i.e. the ‘East Pit’ area on the above image] and there is still opportunity to expand the quarry in an easterly direction in accordance with that approval.’

 

In addition to the EPA's concerns, there had previously been 79 objections from local residents, including a 2009 petition to the Legislative Council of the Parliament of W.A. 

It is very disturbing that in a supposedly  environmentally enlightened age Hanson through its quarrying has already been allowed to have such a huge negative impact on the aesthetic value of the whole valley.

Walkers within Reserve below Area A ridge-line on south side of Susannah Valley.

Unfortunately, apart from bushwalkers, other nature-lovers, and local City of Swan ratepayers, there is low public awareness of the extent to which the public amenity and conservation values of the Susannah Valley have already been compromised and degraded. Driven by other shorter-term priorities, successive Governments, local authorities, and vested interests have become adept at keeping such compromises beneath the public's radar until it is too late to undo what's already done.

Given that processes to date have failed to properly protect this special area, City of Swan had a unique opportunity and responsibility to the community to retrieve the situation before further irreparable damage was done to the Valley. Sadly, Councillors at the Council meeting on 12 December 2012 opted to largely ignore the 241 public objections, and failed to take the only correct decision to reject the Licence application.

 LINKS TO INFORMATION

The following links and information below will help you to understand the history, issues and impacts in more depth:

 
  1. Red Hill Quarry Development - Hanson Construction Material Pty Ltd - Report & Recommendations of the Environmental Protection Authority -  EPA Report #1381, Jan. 2011

  2. Hanson Red Hill Quarry Response to Public Environmental Review  - Stratagen consultant report (for Hanson), Nov. 2008

  3. Statement that a Project may be Implemented  - Signed 9 Oct. 2012 by W.A. State Minister for Environment; Water (Hon Bill Marmion MLA)

  4. Nyungah website - 2008 information  - Highlights how Hanson managed to proceed with quarry operations beyond the initial approved West Quarry footprint.

  5. Respiratory Health & Silica Dust Levels in the Extractive Industry - Occupational Health Report Series #9: 2003, N.Z.

  6. Report on Aboriginal Consultation & Site Investigation of the "Owl Stone" at Hanson's Red Hill Quarry, Lot 11 Toodyay Road, City of Swan - Macintyre & Dobson, Mar. 2009

  7. State Planning Policy 2.4 - Basic Raw Materials - Western Australian Planning Commission (gazetted July 2000). This requires (in part) that in considering Hanson's application the local government  ensures  that the quarrying operations will not adversely affect the environment or amenity in the locality of the operation during or after extraction.

  8. Statement to Parliament on Hanson Red Hill Quarry (1) - Hon. Alison Xamon, MLC (Greens MP for East Metro); 29 Mar. 2012.

  9. Statement to Parliament on Hanson Red Hill Quarry (2) - Hon. Alison Xamon, MLC; 8 Nov. 2012.  Also Media Summary.

  10. Perth Scarp further quarrying process under question - 'West Australia 2013 Vote' editorial comment, 10 Dec. 2012

  11. Local anthropologist Ken Macintyre raises number of concerns with Perth Scarp mining expansion process at Red Hill - Quoted on 'West Australia 2013 Vote', 11 Dec. 2012

  12. Proposed Extension to Hanson's Red Hill Quarry: Lot 11 (No. 585) Toodyay Road, Red Hill - City of Swan; agenda item for General Council meeting held 12 Dec. 2012.

  13. Deputation to City of Swan on Red Hill Quarry extension, 12 Dec. - D.Osborne

 

View across Susannah Valley from north side to Hanson Red Hill Quarry & extension Area A along skyline.

 THE IMPACTS?

There are many real and potential negative impacts of the quarry extension that concern the public. In addition to the above links to information, the following summarises some of the impacts:

 Public amenity - The 'Darling Range Regional Park' is a wonderful public amenity within the City of Swan.

The public has the right to the 'quiet enjoyment' of the Class A Reserve in Susannah Valley and to know that  the values of the Reserve will not be further compromised and degraded in any way by activities in the freehold land held by Hanson.  Known negative impacts that would reduce the recreational value and pleasure of visiting the Reserve and/or increase the risk of passive activities such as walking, include:

  • Visual impact of removing natural, vegetated ridgelines and altering the skyline above the Valley, extending the major visual damage already done by the adjacent operations to the east. The expanding ridge-line scars will be clearly visible from the northern side of the Class A Reserve.

  • A buffer width of only 100m around the SE corner of the Class A Reserve cannot effectively protect against serious negative impacts for visitors to the Reserve.

  • Greatly increased proximity of potentially dangerous flying rock 'missiles' from explosives detonation.

  • Clouds of crushed rock dust with health risk implications (e.g. See link #5 above and note below).

  • Constant intrusive noise from adjacent mining operations.

View approx. SE across existing Hanson Red Hill Quarry across former ridge-line. Susannah Valley in background on left .

 Flora & fauna & other environmental protection (including water quality)  

Walkers are especially aware of the high conservation value of the Reserve and the adjacent freehold areas. The condition of Susannah Brook through the freehold land indicates that Hanson has no interest in protecting conservation values along the Brook through their own land. Without improvement and protection of conservation values upstream, the values of the Class A Reserve downstream will continue to degrade. Known impacts include:

  • Hansons Area A extension extends across the headwater area of stream courses that feed northward into Susannah Brook through the Reserve. Almost the whole of Area A drains steeply into stream courses which feed directly into the Brook. (See detail from topographic contour map below.)

  • Increased stream water turbidity and sedimentation along Susannah Brook which is apparently not now being monitored by Hanson. (See picture below of steep overburden dump.)

  • Weed infestations (dominated by Watsonia and Ink Weed) are spreading uncontrolled and vigorously within Hanson's freehold land, especially along the banks of Susannah Brook.

  • Wandoo woodland - The NE area of the Area A  extension includes mature wandoo woodland which will be removed by the quarrying. Apart from creating a visible scar along the skyline in this area, loss of the wandoo woodland removes increasingly scarce feeding habitat for Black Cockatoos at a time when there is growing community concern to protect such habitat.

Topography across extension Area A

 showing steep drainage slope from ridge-line into Darling Regional Park

 

 

      Steep quarry overburden dump on skyline, leaching fines into Valley.

 

 Protection of unique landscape features of aboriginal significance

The Owl Stone site (see above link #6 report) was added to the Register of Aboriginal Heritage in 2009. Aside from its undoubted nyungah significance it is in any event a feature of great aesthetic value that should be carefully protected. The registered site is supposed to have a 250m buffer zone radius around it to help protect the giant balancing stones from vibrations during blasting and other quarry operations. The approved West Quarry Pit area and 'Disturbance area' are shown as extending northward to within about 150m of the Owl Stone i.e. About 100m into the 250m buffer zone. That is because a previous 5.4 ha extension of the quarry was granted by the Minister in 2006 with the result that it intrudes into the buffer zone. That northernmost area has not yet been quarried but it would be an offence under the Aboriginal Heritage Act if it does intrude into the 250m zone.

The Area A extension will add to the risk to the Owl Stone and will also destroy an ancient aboriginal campsite identified in the northeast area of Area A.

 Health risks from Crushed Rock Dust emissions

Hanson has no effective dust controls in place or proposed. Rock dust from quarrying operations may have very serious negative health impacts on workers and visitors to the nearby area (such as walkers). Employers such as Hanson have a duty of care to provide safe systems of work, but workers (and visitors to the nearby Reserve) should be concerned that Occupational Safety & Health regulations do not impose any particular measures and monitoring regimes in relation to crystalline silica emissions. The fact that the EPA has advised only that dust emissions can "potentially be managed" indicates a lack of certainty. Given i) the lessons from James Hardie Industries' long denial of asbestos dust impacts; and ii) the known negative health impacts of quartz dust from rock crushers, there should be no excuse nor tolerance for complacency, assumptions, or misleading public assurances. Whether a buffer of only 100m between the Class A Reserve and the quarry operations is sufficient to eliminate the health risk to walkers in the area is simply an unacceptable unknown.  

 Precautionary Principle

In some circumstances Governments place much emphasis on the application of the Precautionary Principle ('PP') such as in Water Catchment management in this State. In other circumstances they take a much more 'pragmatic' approach and have little regard for the PP (such as in Bauxite Mining in this State).  Many aspects of the proposed quarry extension raise concerns and risks to environment and health, with substantial uncertainty on whether they can be effectively managed (see above). Under any reasonable application of the Precautionary Principle ('PP') the extension would not proceed. As the PP is one of the key principles under which the EPA considers such proposals, it is not surprising that the EPA would not recommend approval of the proposal. A decision to proceed would ignore risks that are insufficiently understood. 

 Inappropriate Licence Term

The Extractive Licence application was for a 20-year tenure which was clearly unacceptable. As one small concession to public objections City of Swan reduced this in their recommendation for approval to a renewable 5-year term. The reality is that the Licence conditions and compliance standards are weak and a 5-year term will not ensure greater protection for Susannah Valley. The Valley will inevitably be further degraded beyond remediation due to the expanded quarrying activities.

 THE WAY FORWARD

 

 

The only proper course of action NOW, to ensure the badly neglected Susannah Valley and adjacent Class A Reserve receive the protection they require, requires the following three key steps:

 
  1. Minister for Planning/WAPC must disallow Hanson's application for a quarry extension;

  2. or Minister for Planning/WAPC must place a freeze on consideration of any further Red Hill quarrying proposals and applications from Hanson; and

  3. Minister for Planning must initiate an immediate comprehensive inquiry into the planning implications surrounding the Red Hill Quarry. The Inquiry must consider the following (in part):

    1. the history of the Red Hill Quarry operation and its impacts, including an environmental audit of Hanson's operations to date;

    2. the processes involved in the past extension proposals;

    3. the suitability of the current zoning of the remaining undisturbed freehold land (Lot 11, Toodyay Road) in light of the existing and potential values and best uses of that land in the public interest.

 
 

 

     

Map view of lower Susannah Valley

 showing 'Darling Range Regional Park'/Reserve and the Hanson quarry areas

 

(*Hanson) Note: Hanson Construction Materials Pty Ltd is a subsidiary of German-based multinational company Heidelberg Cement.

 

 

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