To the General Manager, Tweed Shire Council.
Submission Re: DA 19-0346.
The Caldera Environment Centre opposes any further expansion of water mining and extraction facilities in the Tweed Shire. Last year (May 2020) the Tweed Council passed a moratorium on new water mining facilities and we ask that this policy continue to be acknowledged. During the drought of 2019 there were serious stream flow issues in areas adjacent to water mining operations. The impacts of this industry on the water table are poorly quantified, and the cumulative impact of farms and residential lots as well as the mining industry have not been adequately considered. The bottled water industry also increases plastic pollution, and with the Tweed Zero Waste Target, it would be appropriate to consider the impacts of the businesses that the Council supports.
The CEC requests that
- The cumulative impact on the water table be considered
- All extraction bores be monitored and metered to ensure compliance with the permitted extraction volumes.
- Truck movements be maintained at existing levels.
The sections below are from the Tweed Water Alliance and we support their comments of the reports:
1. Comments on Hydrogeological Report – Eco-logical Australia
The Water Source
The Report suggests there is only minimal potential for connection between the surface water systems and the aquifer, because the water source is a deep, fractured rock aquifer that does not intersect with the shallower Tweed River sandstone aquifer.
Flow rates and salinity amounts were recorded from two bores – one with high-flow and low salinity, and the other with low-flow and high salinity. Could this indicate the presence of two different aquifers occurring at this site?
Does the low flow rate of one bore suggest that this bore has intersected a fractured rock aquifer? If so, does this suggest that the Production bore, with a higher flow rate, has intersected some other aquifer, or has some connection to surface water?
Rainfall Recharge
The Report states Long-term Rainfall records indicate a cyclical wetting and drying series, with shorter, more intense wetting periods and protracted drier periods. Significant drying trends can be seen between 1976 and 1987 and between 1990 and 2008. Wetter than average conditions prevailed between 1972 and 1976; 1987 and 1990 and between 2008 and 2013. Given the cyclical wet/dry rainfall periods, can the water source support an increased extraction rate?
2. Comments on the Noise Impact Report – CRG Acoustics
Noise levels during glass bottling, recorded outside, adjacent to the western roller door, were recorded as between 54 and 58 decibels. This exceeds the recommended Amenity Noise Levels for rural areas, which have a maximum of 50 decibels.
Early morning sleep disturbance and predicted outdoor noise levels were recorded at two nearby residences at levels of 45 and 43 respectively, for non-typical adverse weather conditions, which exceed the stated noise criterion.
The Report states “…..the increase in road traffic noise is expected to be less through Uki Village and Murwillumbah compared to at the receivers near the subject site (predicted to be less than 0.5 decibels with 1,638 vehicles per day) given the higher traffic volumes.”
How can the Report conclude that less noise would be experienced along the route because the traffic volume is higher?
Current approved truck movements are 12 movements per week-day, with 8 movements each on Saturday, Sunday and Public Holidays. DA19/0346 seeks to increase truck movements to 32 movements each day, although the breakdown of bulk versus bottled water is not provided.
How, if significant noise disturbance limits current allowed truck movements on Saturday, Sunday and Public Holidays, can a four-fold increase in truck movements every day be justified?
Daily traffic volume measurements were taken (in 2017) at two sites on Kyogle Road at Nos. 8 and 1529. Both are located in 50 kph speed limited areas. No 1529 also has 40 kph limits during school terms. Therefore, laden tanker/truck movements are slowed at these two sites compared to other sites on Kyogle Road, rendering noise levels less intrusive.
Why were no noise recordings taken of laden 19m bulk water semi-trailer tankers and rigid or semi-trailer trucks, travelling up to 100 kph, past other residential areas on the transport route? Why were no predicted noise levels provided for laden trucks in transit to the site before and after the operational hours requested?
In summary, does the information in these reports adequately establish that an increase in extraction is a sustainable use of this resource, providing only minimal harm to groundwater dependent ecosystems? How can an increase in operational and transport noise be justified at nearby and further residences? Further, why should this applicant be allowed exemption from the standard industry operational hours, in rural areas, of 7am – 7pm?
Sincerely,
Caldera Environment Centre, 4 Queen St., Murwillumbah, NSW 2484.
21/04/2021
