ssd modification application to da 282-11-2004-i mod 4
Post on 20-Nov-2021
6 Views
Preview:
TRANSCRIPT
SSD Modification Application to DA 282-11-2004-i MOD 4
Submitted under Section 4.55(2) of the EP&A Act, 1979
Australian Bay Lobster Facility
Lot 1 DP1192506, 9484 Tweed Valley Way, Chinderah
Prepared on behalf of
Australian Bay Lobster Producers Ltd
by
June 2019
Page 2
Table of Contents
1.0 Executive Summary .......................................................................................................................................................... 3
2.0 Project Background .......................................................................................................................................................... 7
3.0 Existing Operations & Approved Staging .......................................................................................................................... 9
4.0 Subject Site and Surrounds ............................................................................................................................................ 10
5.0 Proposed Modification .................................................................................................................................................... 12
5.1 Modifications Sought ................................................................................................................................................. 12
5.2 Ancillary Use Considerations ............................................................................................................................................. 15
6.0 Statutory Assessment .................................................................................................................................................... 15
6.1 Tweed Local Environmental Plan 2014 ..................................................................................................................... 15
6.2 Environmental Planning and Assessment Act 1979 ................................................................................................... 16
6.3 Environmental Planning and Assessment Regulations 2000 ...................................................................................... 16
6.4 Environmental Protection Licences ............................................................................................................................ 16
6.5 Waste Management ....................................................................................................................................................... 16
Anticipated Volumes of Waste Streams ................................................................................................................................... 17
Sources of Waste Streams and Process Handling ................................................................................................................... 17
6.6 Water Considerations ..................................................................................................................................................... 18
6.7 Flood Impacts ............................................................................................................................................................ 19
6.8 Erosion and Sediment Control Considerations............................................................................................................ 19
6.9 Soil Considerations ......................................................................................................................................................... 19
6.10 Traffic and Access .......................................................................................................................................................... 21
6.11 Noise and Vibration ........................................................................................................................................................ 22
6.12 Odour ............................................................................................................................................................................ 23
6.13 Visual Quality ................................................................................................................................................................. 23
6.14 Consultation ................................................................................................................................................................... 24
7.0 Condition Amendments .................................................................................................................................................. 24
8.0 Conclusion ..................................................................................................................................................................... 26
Page 3
1.0 Executive Summary
Australian Bay Lobster Producers Limited (“ABLP”) request a modification of the Integrated Development Approval DA-282-11-
2004-i (“the Approval”). The Approval relates to the construction and operation of a commercial aquaculture facility and associated
seawater supply infrastructure (“the Development”) at 9484 Tweed Valley Way, Chinderah, New South Wales (the “ABLP site”).
Modifications to the Approval have been granted on two previous occasions, being the Project Approval 08_0083 dated
16/12/2008 which relates to the construction of a seawater intake pipeline (“the Pipeline Consent”) and Project Approval DA
282-11-2004-i MOD 2 (“MOD 2”) dated 23/09/2013, which updated the Approval in line with the operational requirements of
ABLP (refer to Appendix B for a copy of MOD 2). The modifications incorporated into the Approval by MOD 2 reflect ABLP’s
current consent and will be collectively referred to hereinafter as the “Consent”.
ABLP currently has a third modification (“MOD 3”) under assessment with the Department of Planning and Environment. The
modification seeks to amend condition 4.39 of the Approval to permit the importation of excavated natural material (ENM) and
potential acid sulfate soils (PASS) to the ABLP site. The modification also seeks to clarify the uncertainty in the Consent concerning
the flood mitigation plan. At present the Consent requires ABLP to construct a bund wall as a flood mitigation precaution. In
substitution of the bund wall ABLP intends to raise the site, by way of conventional fill, to approximately 4.0m AHD. The area of
land raised as part of this process is confined to the current footprint of the ABLP site and is intended to be undertaken as and
when the fill becomes available over time.
This modifications contained in this application consolidate the modifications sought in MOD 3 in addition to seeking approval for
further modifications that are intended to update the Consent to support the evolving operational requirements of ABLP and the
future development of the ABLP site. It is the fourth modification since the Approval an as such will be referred to hereinafter as
“MOD 4”. The modification is comprised of eight components which are detailed as follows:
• MODIFICATION COMPONENT NO.1
Component 1 is intended to formalise ABLP’s approval to conventionally fill and raise the area of land designated for
Stage 2 and Stage 3 of the Development. The proposed fill and raise flood mitigation method is preferred as opposed to
a bund wall, which is currently approved, as it ensures the ABLP site will be protected from a 100-year ARI flood event.
The current flood mitigation requirements for the Development are detailed in condition 4.39 of the Consent.
Condition 4.39 of the Consent relates to the importation of soils to the ABLP site for use in the construction of protective
mitigants to ensure a flood free environment for the operational pad. A bund wall was original proposed as the protective
mechanism against flooding, however, further investigations revealed that due to the presence of a high groundwater table at the
ABLP site and the impacts of same, a bund wall would not adequately protect the ABLP site from a 100-year ARI flood. On this
basis, the area comprising Stage 1 of the ABLP site has been protected using a fill and raise method whereby the site was raised
to a height of 4.0m AHD. MOD 4 seeks to modify the Consent to permit ABLP to continue to fill and raise the ABLP sites for
Stages 2 and 3 as the method of flood mitigation. Therefore component 1 of MOD 4 seeks to modify the Consent to the
extent that any references to the previously proposed ‘bunding’ of the ABLP site, or references to the use of ‘floodgates’
or the construction of a ‘borrow pit’ and/or ‘bunding – in the context of landscaping’ are removed as they are no longer
relevant in circumstances where ABLP adopts a raise and fill method of flood mitigation.
It is estimated that to fill and raise Stages 2 and 3 of the ABLP site, ABLP will be required to import approximately 2
million cubic meters of fill. To achieve this ABLP adopts an ‘as and when available’ approach to obtaining fill, whereby it
sources fill when it can be sourced in a commercially sustainable manner. On this basis ABLP requires permission to fill
the site over a timeline that accommodates the gradual filling of the site as and when fill resources become available. The
fill that is currently permitted under the Consent, is virgin excavated natural material (VENM), although due to the limited
resources of VENM in the region, ABLP seeks approval to include excavated natural material (ENM) and potential acid
sulfate soils (PASS) as approved soils for use in fill operations.
ABLP acknowledges the sensitivities surrounding use of PASS and therefore it is committed to developing and adhering
to a strict PASS treatment plan that will enable it to receive and treat the PASS on site in a safe and responsible manner.
ABLP estimates that the proportion of PASS to be used in the fill and raise of the site will not exceed 25% of the total fill
Page 4
material for Stages 2 and 3, or 500,000m3. The remainder of the fill material will consist of VENM and/or, subject to the
outcome of this application, ENM. Further detail about the intended treatment and use of PASS is included in the attached
documentation, including a basic treatment plan and Acid Sulfate Soils Management Plan (see Appendix E).
Of important note is that the importation of PASS is ancillary to the primary purpose of the ABLP site and is directly
related to ABLP’s compliance with the “Flood Impacts” conditions in the Consent, specifically the design and construction
of flood protection measures capable of excluding a 100-year ARI flood event. As such the importation and treatment of
PASS is related to the principle purpose of the ABLP site as it would form part of the construction of the Development in
the same manner approved under the Consent. On this basis component 1 of MOD 4 does not create a separate or
independent use for the ABLP site and accordingly is eligible to be undertaken pursuant to the Environmental Planning and Assessment Act 1979 (the Act).
In order to include PASS as an approved fill material, the Consent will require modification to remove, subject to other
regulatory approvals, any reference to PASS as a ‘waste’ material.
• MODIFICATION COMPONENT NO.2
Component 2 seeks to expand the permitted operations at the ABLP site to include aquaculture operations that are
complimentary to the cultivation of bay lobster. To achieve this ABLP proposes updates to the wording in Schedule 1 of
the Consent and the removal of restrictions imposed at paragraph 1.3, Schedule 2 of the Consent.
The purpose of the Consent was to enable ABLP to construct and operate a commercial aquaculture facility, however the
current Consent restricts the ABLP, per paragraph 1.3 of Schedule 2, to the “commercial cultivation of Thenus orientalis and T. indicus”. Although ABLP’s site is currently limited to the production of Thenus spp., it is envisaged that because of
the unique nature of the facility and the projected development of the fresh seawater pipeline, there will be commercial
and environmental opportunities that arise from emerging seafood markets. On this basis ABLP seeks to modify the
Consent to permit alternative aquaculture ventures, that are not associated with the construction and operation of a
commercial Australian Bay Lobster facility, to operate or be constructed on the ABLP site. Such ventures would not be
permitted at the site without specific approval, however by broadening ABLP’s current approval in this way, ABLP will be
able to capitalize on future opportunities of this nature.
The second part of this component pertains to the wording of paragraph 1.3, Schedule 2 of the Consent, specifically:
1.3 The development is restricted to the commercial cultivation of Thenus orientalis and T.
indicus at the site.
ABLP seeks to widen the species of Australian Bay Lobster referenced in the Consent to include a broader list of Thenus.
The basis for this is that as further research is conducted into bay lobsters within the industry, the naming conventions
are subject to change. As an example, Thenus orientalis is no longer recognised as a species of bay lobster. In order to
circumvent the progressive changes to bay lobster naming conventions, ABLP proposes to amend paragraph 1.3 to
include the commercial cultivation of “Thenus”.
• MODIFICATION COMPONENT NO.3
Component 3 seeks to permit ABLP to construct short term accommodation on the ABLP site for use in emergency
situations, whether caused by unavoidable natural events or otherwise, and to ensure the health and safety of personnel
on the ABLP site (“emergency and relief accommodation”).
During the flood event that occurred in March/April 2017ABLP staff were prevented from accessing the ABLP site, as a
result of which ABLP sustained near catastrophic losses to its production. In order to circumvent the losses that would
be sustained by a similar event, ABLP seeks permission to include short term accommodation as part of the building
Consent. It is believed that had short term accommodation been available on the ABLP site at the time of the flood event,
ABLP would not have incurred the significant losses that it did. In addition to this, as ABLP seeks permission to use short
Page 5
term accommodation to protect the safety and wellbeing of personnel who enter the ABLP site. In circumstances where
personnel are evidencing adverse health symptoms (e.g. such as exhaustion) ABLP utilise the short term accommodation
to allow personnel until they could be safely removed from the ABLP site.
o Component 3 seeks to amend the Consent to permit ABLP to install and utilise short term accommodation at
times of unavoidable natural and human risks.
• MODIFICATION COMPONENT NO.4
Component 4 seeks to eliminate any inconsistency between ABLP’s Environmental Protection Agency Licence No.
12947(“EPA license”) and the Consent with respect to the volume of water that is permitted for collection from the
Tugun Desalination Plant. The Consent currently limits ABLP from collecting more than 160,000 litres of seawater per
day from the Tugun Desalination Plant. This is in contrast with the EPA license which permits ABLP to discharge 5,497KL
per day.
The production of bay lobster is dependent on fresh seawater and in order to satisfy the operational demands of the
facility in the future, it is estimated that ABLP will require seawater in excess of 160,000 litres per day. At present, ABLP
relies on Tugun Desalination Plant as its primary source of seawater and will continue to do so until the seawater intake
pipeline from Dreamtime Beach is completed. Once completed ABLP will revert to the sweater intake pipeline as an
exclusive source of seawater. Notwithstanding, in order to protect ABLP’s production from a pipeline failure or unexpected
maintenance, ABLP requires ongoing access to the Tugun Desalination Plant in perpetuity. Although ABLP is currently
well within the permitted volume of water that can be collected under the Consent, in order to protect its future operations
from a pipeline failure or comparable event, it seeks to align seawater collection thresholds in the Consent with the EPA
discharge license.
• MODIFICATION COMPONENT NO.5
Component 5 seeks to amend the wording of paragraph 4.51, Schedule 2 of the Consent by removing the restrictions
on seawater and wastewater vehicles. Additionally, this component seeks to formalise ABLP’s consent to collect seawater
from the Tugun Desalination Plant without limitation. ABLP’s operations run 24 hours a day, seven days a week, and
require a continuous source of fresh seawater to sustain animal life. ABLP sources its seawater from the Tugun
Desalination Plant, therefore in order to satisfy its production demands it is imperative that ABLP has unrestricted approval
to collect seawater from the Tugun Desalination Plant.
The wording of paragraph 4.51, Schedule 2 of the Consent is ambiguous and as a result ABLP and related parties have
encountered confusion with its interpretation. Specifically, ABLP seeks to replace the word “development” with the phrase
“construction at the ABLP site” and to remove the wording “(i.e. the arrival and departure of vehicles delivering or removing seawater and wastewater)” altogether. This wording was erroneously included at paragraph 4.51 as part of MOD 2 and
should have been inserted into paragraph 4.53, Schedule 2 of the Consent. The purpose of these amendments are to
secure ABLP’s right to continue to collect seawater from the Tugun Desalination Plant and deliver it to the ABLP site over
a 24hour time period. In consideration of this modification, it is noted that the collection of seawater from the Tugun
Desalination Plant is not intended to persist upon completion of the seawater intake pipeline, except for in the event of a
pipeline failure or maintenance event preventing ABLP from using the pipeline. Considering this, ABLP will require access
to the Tugun Desalination Plant for the purpose of seawater collection in perpetuity.
Further and subject to the formal approval of the Tweed Shire Council (currently agreed ‘in principle’ – refer Appendix C),
ABLP seeks approval to include Jack Evans Boat Harbour as a primary seawater collection point until December 2021.
Currently the Consent permits the authorised extraction of seawater from the Tweed Heads River at the Jack Evans Boat
harbour as an alternative to the Tugun Desalination Plant. This alternative collection point was intended as a contingency
plan in the event that seawater could not be sourced from the Tugun Desalination Plant. ABLP seeks to include this
approval in the Stage 1B description, Schedule 2 of the Consent.
In summary this component is intended to modify the Consent as follows:
Page 6
o amend the paragraph 4.51, Schedule 2 to include the phrase “construction of the” and to remove the wording “(i.e. the arrival and departure of vehicles delivering or removing seawater and wastewater)”. The paragraph will read as
follows:
“Activities associated with the construction of the development, including activities associated with MOD 2 must only be carried out between the hours of:
a) 0700 and 1800, Monday to Friday; b) 0800 to 1300 on Saturdays; and c) at no time on Sundays or Public Holidays.”;
o amend the paragraph 4.53, Schedule 2 to read:
“Operation activities associated with the development, including the arrival and departure of vehicles delivering or removing products, seawater or wastewater from the site, may be undertaken twenty four (24) hours a day, seven (7) days a week provided the noise contribution limits comply with the EPA’s Industrial Noise Policy.”;
o amend the Stage 2 and Stage 3 works, Schedule 2 to include the Tugun Desalination Plant as a supply/collection
point for daily seawater pursuant to ABLP’s EPA license; and
o amend the Stage 1b works, Schedule 2 to include the Jack Evans Boat Harbour, Tweed River as a daily seawater
collection point until 31 December 2021. See the attached agreement (in principle) between ABLP and the Tweed
Shire Council, permitting the extraction of seawater from Jack Evans Boat Harbour until December 2021.
• MODIFICATION COMPONENT NO.6
Component 6 seeks to amend the note at paragraph 4.13, Schedule 2 of the Consent to update the “main aquaculture development site” to reflect the correct property allotments comprising the ABLP site. At present the Consent erroneously
includes property lots that are not owned or operated by ABLP. The reason for this erroneous description is because of
a land sale event that transpired subsequently to the approval of the Consent. The Consent currently lists the ABLP site
as all property that is attached to 355 Cudgen Road, Cudgen, NSW.
As part of formally transferring the land to be used as part of the development, ABLP purchased Lot 1 in DP 1192506
together with three small lots adjoining the highway, namely Lots 708, 709, 710 in DP 1000580. Accordingly, the note
at paragraph 4.13, Schedule 2 should read:
“Note: For the purposes of this condition, “main aquaculture development site” refers to the area of approximately 45 hectares on which Farms 1 to 3 will be located on part Lot 1 DP 1192506 and Lots 708, 709 and 710 in DP 1000580.”
Please refer to Figures 1 & 2 for an aerial photograph that outlines Lot 1 in DP 1192506 together with a copy of the
original concept.
In addition to the item above, the proposal seeks to modify the pipeline alignment (as approved) between Tweed Coast
Road and Elrond Avenue. In this regard, the proposed amendment is reflected in the plan attached at Appendix H. This
amendment is necessary so as to minimise impact on private access roads and to properly reflect the most efficient route
relative to on site obstacles.
• MODIFICATION COMPONENT NO.7
Component 7 seeks to include an updated conceptual site plan depicting future development at the ABLP site. The plan
is intended as a general guide as to the size and position of buildings and related developments on the site based on
Page 7
current and future operational demands. Given the fluid nature of the business the site plan cannot be relied upon as an
exact depiction of future development and is subject to change. Refer to Appendix G for a copy of the plan.
• MODIFICATION COMPONENT NO.8
Component 8 seeks to address a number of housekeeping matters that will bring the Consent in line with the present
operations at the ABLP site. These include modifications to:-
1. classify seawater collection from an external source, inclusive of the departure and arrival of trucks to the ABLP site
as part of this process, as an ‘operational activity’;
2. confirmation that seawater trucks are permitted to leave and enter the ABLP site over a 24 hour period for the
purpose of supplying seawater;
3. deletion of paragraph 6.6, Schedule 2 of the Consent, along with any other reference to the payment of road
contributions. The payments referred to in the Consent have been paid in full and final satisfaction of the obligation.
4. with the exception of the Tweed Shire Council Kingscliff Sewerage Treatment Plant (“Kingscliff STP”), remove any
reference to a wastewater location, including reference to the discharge point at Chinderah any connected or related
community consultation that is directly related to this discharge (inc. Appendix B of Mod 2 as it currently stands).
5. modify the contents of Schedule 1 of the Consent to properly reflect the modifications sought.
6. modify the contents of Schedule 2 of the Consent to properly reflect the modifications sought.
7. modify the Consent to include a paragraph that permits ABLP to alter, relocate, remove or expand the car parking at
the ABLP site in order to meet the growing demands of the Development, on the basis that such alteration, relocation,
removal or expansion is in accordance with Australian Standards AS2890.1 1993 Off-Street Car Parking and the
Tweed Shire Council’s code DCP2 Site Access and Parking Code.
The various components listed above are ancillary to the primary purpose of the Consent and do not create a ‘new use’ for the
ABLP site. As such there will be minimal to no impact on the environment or local community as a result of the modifications.
Overall it is intended that amendments proposed in MOD 4 will remain consistent with the existing Consent pertain to the ongoing
construction and operation of the Development in accordance with the approved use referenced in the Consent.
Please note, whilst the Consent refers to over ten (10) parcels of land that will be subject of MOD 4, the modifications primarily
pertain to the ABLP site at Lot 1 DP1192506 and 708, 709, 710 in DP 1000580, referred to hereinafter as 9484 Tweed Valley
Way, Chinderah. Otherwise the owner’s consent has been obtained for land that will be affected as a result of MOD 4 prior to the
modifications submissions with the Department of Planning and Environment.
2.0 Project Background
ABLP obtained the Consent in 2005 to commence construction on an aquaculture facility design to produce Thenus spp. commonly
referred to as Australian Bay Lobster and known locally as Moreton Bay Bugs. The facility is the first of its kind as bay lobsters are
not currently produced anywhere else in the world. Therefore, consumers rely on wild caught bay lobster to satisfy demand, which
is leading to the continued depletion of an Australian natural resource as the demand for the product outstrips natural supplies.
Fortunately, on the back of consecutive decades of research, ABLP has designed an onshore aquaculture facility using recirculation
aquaculture technology to produce bay lobsters in a sustainable and environmentally safe manner. The offshore aquaculture facility
is currently approved over three (3) stages. Upon completion of all three (3) stages, the operation is expected to occupy
approximately 45 hectares of land and produce an estimated 3228 tonnes of product annually with minimal environmental impact.
The project has been designed to produce two (2) products; a live, hard shell animal of a nominal 218g and a soft-shell animal
(frozen or fresh chilled) of a nominal 45g.
ABLP has constructed the first stage in the approved development, a greenhouse structure enclosing a series of recirculating
seawater raceways and filtration systems, and associated buildings to facilitate the operational demands of the facility. The first
stage of the facility is still within its research and development stage as ABLP adjust to the practicalities of scaling up its system to
a commercial level. As such the current animal production numbers are low and will remain so until such time that ABLP’s technology
has been adequately tested and proven at a commercial scale. Notwithstanding, ABLP continues to employ approximately 70
Page 8
people at the facility and generates stimulation to the local economy via its use of trades and services in the construction and
operation of the Development.
As part of scaling the facility to a commercial level the Development will ultimately incorporate pipeline infrastructure from the ABLP
site to Dreamtime Beach, Kingscliff, providing the facility with a clean and uninterrupted source of fresh seawater. The seawater
pipeline will be laid within public reserves and private land, housing a series of pipes that will draw water from an offshore point
located approximately 1km from the beach. To date, and pending the construction of the seawater pipeline, ABLP relies on bulk
truck transport of seawater from the Tugun Desalination Plant or Jack Evans Boat Harbour, Tweed Heads River to supply the
seawater required by the Development. As the Tugun Desalination Plant sources its seawater from its own dedicated offshore
pipeline, ABLP prefers to source its water from this location. The existing Consent categorises the Tugun Desalination Plant as a
public utility designed to supply the water grid. Therefore, collection of the seawater to the ABLP facility remains via licensed ISO
stainless steel lined transport tanks. Although because of the plant’s restricted operating days ABLP has been forced to source
water from the Jack Evans Boat Harbour on occasion to ensure it maintains adequate levels of fresh seawater.
Once the seawater has passed through the ABLP facility, it is treated and on forwarded to Tweed Shire Council’s Sewage Treatment
Plant at West Kingscliff where it forms part of the existing discharge from the plant. All seawater discharged from the ABLP site is
treated in accordance with the licensing requirements for Council’s Sewage Treatment Plant and ABLP’s Environmental Protection
Agency permits.
DA-282-11-2004-i & MOD 1
With respect to the approvals background, the Consent was originally issued in September 2005 before being contested in the
Land and Environment Court and a subsequent challenge to the Supreme Court. The Supreme Court made a ruling in favour of
ABLP and the application was referred back to the Land and Environment Court. Unfortunately due to the considerable costs of
this process, both in time and money, ABLP lost institutional funding commitments. In order to account for a reduction in its funding,
ABLP submitted a request to the NSW Department of Planning and Environment (“the Department”) seeking approval to stage
the development over three stages, thus limiting the initial outlay for the Development (MOD 1). The Department approved the
amended consent and the staging plan outlined within DA-282-11-2004-i was formed.
Pipeline Amendment 08_0083
In December 2008 the Pipeline Amendment 08_0083 was granted, providing ABLP with consent to amend the seawater intake
pipeline route without altering the approved development on the ABLP site.
DA-282-11-2004-i MOD2
MOD 2 (DA-282-11-2004-i MOD2) was granted in September 2013. This modification amended the staging plan to divide the
development activities listed in Stage 1 between two sub-stages, Stage 1a and Stage 1b. The purpose of this was to allow ABLP
set aside the wastewater discharge pipeline to Stage 1b in order to focus on the construction and operation of the greenhouse
structure, referred to as Farm No. 1. Additionally, due to high levels of rainfall at the time, the water table surrounding the ABLP
site had risen to a point that prevented the trenching and construction of the wastewater pipeline. Although the wastewater pipeline
was initially delayed to Stage 1b, a fortuitous turn in the environmental conditions at the site allowed ABLP to include the pipeline
as part of its commercial scope for Stage 1a.
DA-282-11-2004-I MOD 3
MOD 3 was submitted to the Department in ??, however at the request of the Department it has since been incorporated into this
document and will form part of MOD 4. MOD 3 related to the proposed amendments to condition 4.39 Soil Quality, Schedule 2
of the Consent. Specifically the modification sought to permit the importation of excavated natural material (ENM) and potential
acid sulphate soil (PASS) for use in the site filling operations associated with to Stages 2 and 3. This modification is now contained
in this application.
MOD 3 also sought to clarify the wording within the Consent concerning the flood mitigation protections that are required as part
of the Development. As an alternative to constructing a bund wall around the site, ABLP sought to a fill and raise the site to
approximately 4.0m AHD. The fill and raise method does not expand the approved 45 hectare footprint of the Development and
would be carried out using conventional fill methods as and when fill became available. This modification is now contained in this
application.
Page 9
3.0 Existing Operations & Approved Staging
The construction works associated with Stage 1a and 1b are predominantly complete and operations are currently in the latter
stages of Stage 1b.
Please refer to Table 1 (below) to identify the development timeline for the ABLP site. Also see Appendix E - Acid Sulphate Soils
Management Plan and Appendix G for a list of the current and proposed operations at the ABLP site.
Table 1: Staging, description and subsequent status
Stage Description Environment and
Monitoring Regime
Status
Stage 1a
Works
The construction and operation of Farm 1 located in the north-
west section, occupying an area of approximately 15 hectares and
including hatchery and growout facilities, car parking plus processing building, workshop facilities, seawater and freshwater
storage tanks, access road upgrade, and as described under DA-282-11-2004-I, and all additional information submitted in
support of the application and MOD 1 and MOD 2, including supply of up to 40,000 litres of seawater daily from the Tugun
Desalination Plan, and direct discharge of up to 40,000 litres of wastewater to the drainage channel/ Tweed River at Chinderah
until 21 October 2013.
• Discharge concentration
monitoring -in accordance with
Condition 5.1;
• Groundwater monitoring-
in accordance with
Condition 5.4;
• Independent
Environmental Auditing- as per condition 5.7, and
• Annual Environmental
Management Report –
as per condition 9.3.
Complete
Stage 1b
Works
The construction and operation of Farm 1 located in the north-
west section, occupying an area of approximately 15 hectares and including hatchery and growout facilities, car parking plus
processing building, workshop facilities, administration building, seawater and freshwater storage tanks, access road upgrade and
discharge of seawater to the pipeline as described under DA-282-11-2004-I, and all additional information submitted in support of
the application and MOD 1, including supply of up to 160,000
litres of sweater daily from the Tugun Desalination Plant.
• Discharge concentration
monitoring -in accordance with
Condition 5.1;
• Groundwater monitoring-
in accordance with Condition 5.4;
• Independent
Environmental Auditing-
as per condition 5.7, and
• Annual Environmental
Management Report – as per condition 9.3.
• Construction complete
• Operations partially
complete
Stage 2
Works
Construction and operation of Stage 2 located immediately east of
Stage 1, occupying an area of approximately 14 hectares and including hatchery and growout facilities, car parking plus
processing building, workshop facilities, administration building, seawater and freshwater storage tanks, as described under DA-
282-11-2004-1, and all additional information submitted in support of the application, as well as discharge of wastewater to
pipeline, and construction/ operation of the pipeline and pump house at Dreamtime Beach to supply all seawater needs.
• Noise monitoring to
confirm the noise emissions performance
of the pumping station at Duranbah Beach;
• Discharge concentration
monitoring -in accordance
with Condition 5.1;
• Groundwater monitoring-
in accordance with Condition 5.4;
• Independent
Environmental Auditing-
as per condition 5.7, and
• Annual Environmental
Management Report – as per condition 9.3.
• Preparatory works for
fill and raise of site commenced.
• Seawater pipeline
planned for
construction mid-2019.
• Wastewater pipeline
construction
complete.
• Site construction
forecasted to commence in 2019
contingent upon Stage 1 production
success.
Page 10
Stage 3
Works
Construction and operation of Farm 3 located immediately south of Farm 1 and occupying an area of approximately 15 hectares
and including hatchery and growout facilities, car parking plus processing building, workshop facilities, administration building,
seawater and freshwater storage tanks as described under DA-
282-11-2004-I, and all additional information submitted in support of the application.
• Discharge concentration
monitoring -in
accordance with Condition 5.1;
• Groundwater monitoring-
in accordance with
Condition 5.4;
• Independent
Environmental Auditing- as per condition 5.7, and
• Annual Environmental
Management Report –
as per condition 9.3.
• Stage 3 will
commence based on
demand place on Farm 2. Projected for
commencement beginning of 2020.
4.0 ABLP Site and Surrounds
The site is zoned as RU1 Primary Production pursuant to the Tweed Local Environmental Plan 2014 (TLEP2014) which replaced
1(b) Agriculture Protection of the Tweed Local Environmental Plan 2000 (TLEP2000) the in force Act at the time ABLP received
its initial consent. The site is surrounded by RU1 Primary Production zoned lands and neighbours a Hanson sand mine, a Caltex
Service Station and the Melaleuca Station Crematorium, with access provided by the M1 Pacific Motorway which runs along the
western boundary of the property. Please refer to Figure 1. (below) for a locality plan of the area.
The primary site access is from the M1 Pacific Motorway via the Tweed Valley Way interchange at Chinderah, NSW. Refer Figure
2 below.
Figure 1. Locality Plan Source: Nearmap 2019
Page 11
Figure 2. Aerial Photograph Source: Nearmap 2019
Page 12
5.0 Proposed Modification
5.1 Modifications Sought
Australian Bay Lobster Producers Limited have approval to construct and operate a commercial aquaculture facility and associated
seawater supply pipeline 9484 Tweed Valley Way, Cudgen, NSW under the jurisdiction of the Tweed Shire Council Local
Government Area. This MOD 4 to the Consent and is comprised of eight components, which are detailed as follows:
• MODIFICATION COMPONENT NO.1
The application to modify seeks to formalise the filling of the land (as opposed to bunding) and to also authorise /
formalise the method of filling the land to ensure the aquaculture development site is flood free including in a 1 in 100
year flood event. Flood requirements for the approved aquaculture development are provided in condition 4.39 of the
Project Approval DA 282-11-2004-i MOD 2.
Condition 4.39 of the consent relates to the importation of soil to the site for this purpose of achieving a flood free
environment. Whilst the bunding of a protected operational pad was originally proposed, the presence of a high groundwater
table and the impacts of same, precluded the use of a bund in this instance. Accordingly, the site has been filled to date and it is
proposed to modify the consent so as to make sure that the continued filling of the land is properly reflected in the consent.
To achieve the filling of the land, it is estimated that around 2 million cubic metres of fill will be required. Given the extent
of fill remaining, Australian Bay Lobster are seeking to obtain and utilise available filling resources when they are available
and in a manner that is commercially viable. It is for this reason, that Australian Bay Lobster are seeking the ability to
gradually fill the site by way of using available fill resources, when and as it becomes available, including virgin excavated
natural material (VENM), excavated natural material (ENM) and potential acid sulphate soils (PASS). The PASS would
be treated onsite before being used as a fill material.
With respect to the likely extent of potential Acid Sulphate Soils to be used in the filling of the land, it is estimated to be
in the order of 500,000m3 or 25% of the fill required to implement the ABLP consent. The remainder will be made up of
VENM (as used to date and when the resource is available) and or ENM, subject to the outcome of this application. Further
detail about the treatment and use of the soil is included in the attached documentation, including a basic treatment plan
and Acid Sulphate Soils Management Plan (see Appendix E).
The importation of the PASS is ancillary to the use of the site as an aquaculture facility and associated seawater supply
works. In particular the proposed modification has a relationship with the approved use to ensure flood protection
measures are sufficient and consistent with the consent. The importation and treatment of the PASS is a construction
requirement to support the existing consent and use. This element of the proposed modification is not a separate or
independent use on the site and is related to the principle purpose as approved. As such, the modification is eligible to be
undertaken pursuant to the Environmental Planning and Assessment Act 1979 (the Act).
The proposal seeks to modify the consent such that any references to the previously proposed ‘bunding’ of the site, the
use of ‘floodgates’, the construction of a ‘borrow pit’ and or ‘bunding – in the context of landscaping’ are removed as
they are no longer relevant in circumstances where filling is proposed.
As a result of the proposed filling of the land using VENM, ENM and PASS, there is also a requirement to modify the
consent to ensure that any applicable reference to the use of ‘waste’ materials (limited to PASS) for the purposes of
filling is permitted, subject to other regulatory approvals.
• MODIFICATION COMPONENT NO.2
Page 13
The current consent gives approved for the carrying out of aquaculture on the subject site. Given the broad scope of this
consent, an unnecessary and restrictive oversite has occurred resulting in a restriction on trade being only for the species
Thenus spp. As the site is approved for aquaculture and is rare for the locality, it is requested that this restriction be lifted
for as the emerging seafood market continues growth with imaginative use of sealife on restaurant plates, this site could
be capable of supporting such emerging markets should they eventuate.
o The modification seeks to ensure the site is utilised for aquaculture ventures as approved and not solely restricted
for one product type. Consent is to be modified to allow for additional species to be farmed with the prior
agreement of relevant authorities.
• MODIFICATION COMPONENT NO.3
Given recent flooding events in the Shire, the business venture has suffered catastrophic losses to its product. With recent
reviews for the site with regard to such natural risks, it has been determined that should emergency short-term
accommodation had been available, employees could continue to operate the site and ensure that any losses to product
is minimised.
o The modification seeks amendment to include emergency short term accommodation quarters to be utilised at
times of unavoidable natural and human risks.
• MODIFICATION COMPONENT NO.4
There is inconsistency between the EPA approved collection of seawater from the Tugun Desalination Plan and that of
the SSD consent. The use of and collection of this seawater is required on a daily basis and will continue until such time
as the pipeline to Dreamtime Beach is established for a permanent readily supply.
o The modification seeks to amend the amount of seawater collected from Tugun Desalination Plant to align with
the EPA approval with License No. 12947. The simplest method to address this matter is with the rewording of
those conditions to point to EPA approvals for quantity and quality.
• MODIFICATION COMPONENT NO.5
The consent is to be modified to formally allow an unlimited collection of seawater from the Tugun Desalination Plant. In
this regard, In this regard, ABLP’s operations are undertaken on a 24hour a day, seven days per week cycle, however the
current approval (as formalised in Mod 2) limits seawater extraction from the desalination plant to only 160,000 litres
per day.
In order to ensure clarity with the movement of vehicles to and from the site, modification of condition 4.53 is also sought.
In this regard, it is sought to rationalise the existing wording so as to ensure that this condition also includes vehicle
movements to and from the Tugun Desalination Plant and any other water source, at any time over a 24 hour period.
Previously, Mod 2 of the consent authorised the extraction of seawater from an agreed location at Jack Evans Boat
Harbour (Tweed Heads) as an alternative to the Tugun Desalination plant. The alternate site being a failsafe in the event
that water is unable to be sourced from the desalination plant at any point in time.
It is therefore proposed to amend the current wording so as to formalise the authorised extraction of water from the
Tweed River at Jack Evans Boat Harbour. This will be placed at the end of the Stage 1B description and for this new
extraction (agreed in principle with Tweed Shire Council – refer Appendix C) to be undertaken over a period of up to
December 2021.
Whilst the extraction of seawater from the desalination plant is unlikely to be required (on a permanent basis) once the
pipeline is constructed, it is proposed to retain the ability to use water from the desalination plant (within the approval),
Page 14
even when the pipeline is constructed in the event that the pipeline cannot be used due to maintenance / repair
requirements.
o The modification seeks to amend the Stage 1b works description allow for operational delivery hours to be
permitted at any time and for the collection and delivery of seawater from the Tugun Desalination Plant and
directly from the Tweed River with Tweed Shire Council agreement to be formally recognised and that the amount
of seawater permitted to be collected from the Tugun Desalination Plant be unlimited and subject to SEQ Water
approval.
o In accord with the attached agreement reached (in principle) with Tweed Shire Council, the extraction of
seawater (from the same location previously approved at the Tweed River at Jack Evans Boat Harbour, Tweed
Heads) is to be approved until December 2021.
• MODIFICATION COMPONENT NO.6
Modification of consent to properly include the accurate identification of allotments - Property site description change to
Lot 1 in DP 1192506 - Whilst the Consent includes all property site Lots then attached to the ownership of 355 Cudgen
Road, Cudgen, the property was not owned by ABLP.
As such and in order to enable ABLP to formally purchase the land approved for its development, it was decided that
rather than create new boundaries, the site was adjusted (boundary adjustment) and they proceeded with the purchase
of Lot 1 in DP 1192506, together with three small Lots adjoining the highway Lots 708, 709, 710 in DP 1000580.
Please also see Figures 1 & 2 demonstrating a recent aerial photograph that outlines Lot 1 in DP 1192506 together
with a copy of the original concept.
In addition to the item above, the proposal seeks to modify the pipeline alignment (as approved) between Tweed Coast
Road and Elrond Avenue. In this regard, the proposed amendment is reflected in the plan attached at Appendix H. This
amendment is necessary so as to minimise impact on private access roads and to properly reflect the most efficient route
relative to on site obstacles.
The modification seeks to amend the consent by way of referencing the correct property descriptions
• MODIFICATION COMPONENT NO.7
This proposed modification includes a conceptual site plan that depicts (generally and diagrammatically only) the future
stages of development as the site evolves.
As such, a reference to this site plan is proposed within the beginning of the consent. A copy of the plan is contained at
Appendix G.
• MODIFICATION COMPONENT NO.8
The proposal seeks to make a number of housekeeping changes to reflect current operations. These include:-
1. The modification of the consent to clearly reflect that the collection and delivery of seawater is an ‘operational’
requirement that is to be carried out any time.
2. The modification of the consent to remove reference to the payment of road contributions as this payment has
already been made.
3. The modification of the consent to remove any reference to the discharge of wastewater to any location other than
the approved and existing discharge point, being the Tweed Shire Council Kingscliff Sewerage Treatment Plant. Any
reference to the discharge at Chinderah is to be removed, along with any connected or related community
consultation that is directly related to this discharge (inc. Appendix B of Mod 2 as it currently stands).
Page 15
4. Modify the contents of Schedule 1 of the consent so as to properly reflect the modifications sought
5. Modify the contents of Schedule 2 of the consent to properly reflect the modifications sought
This modification request is considered to involve minimal Environmental Impact and therefore the consent as amended will remain
consistent with the existing approval given that the use fundamentally remains the same and all modifications herein relate to the
ongoing success of the site for such purposes.
Whilst the consent references over ten (10) parcels of land the subject of this modification relates to a single parcel being Lot 1
DP1192506, known as 9484 Tweed Valley Way, Chinderah. Owners consent has been provided at time of lodgement of the
modification to the Department of Planning and Environment.
5.2 Ancillary Use Considerations
MOD 4 does not propose a separate or independent use of the ABLP site and maintains the principle site purpose as approved in
the Consent. To support this, the modification is consistent with the ‘ancillary use’ considerations presented in Planning Circular PS13-001, including the provisions regarding the emergency and overnight accommodation for staff. The criteria for determining
an ‘ancillary use’ are detailed as follows (“Ancillary Use Considerations”:
• If the component is going to serve the dominant purpose of the development, it is more likely to be an ancillary use.
• If the amount of land used for the ancillary use is relatively small, it is more likely to be an ancillary use of the princip le
purpose.
• If the component is temporary, it is more likely to be ancillary, but if it is ongoing it is likely to be independent.
• Related components of a development are likely to have an ancillary relationship.
The overnight and emergency accommodation is intended to support the ongoing operations of the facility in specific circumstances
(providing emergency and relief onsite accommodation to staff). It is imperative to the successful operation of the ABLP site
during emergency events (e.g. flooding) and will offer a means of ensuring the safety of ABLP staff when relief is required. The
accommodation is not intended to facilitate new operations and/or operations that are not approved under the Consent and
satisfies all Ancillary Use Considerations within the Planning Circular PS13-001. On the basis of the above, the accommodation
proposal is a suitable modification pursuant to s4.55(1A) of the Act.
Further to the above, the importation of PASS, ENM and VENM is a construction component of the Development. The modification
is ancillary to the approved land use in the Consent as it is direct support of implmenting flood protection measures that are adequate
to protect the Development from 1 in 100 year ARI flood event. The importation of such soils will form part of the fill and raise
method of flood protection(as opposed to site bunding which is unviable) and will only comprise a small and temporary part of the
overall construction of the site. To clarify, the treatment of importation, treatment and use of PASS is intended to as part of the
raise and fill operations only and will not extend beyond this.
6.0 Statutory Assessment
The following section addresses the strategic context and statutory assessment of MOD 4.
6.1 Tweed Local Environmental Plan 2014
MOD 4 remains consistent with the requirements of the Tweed Local Environmental Plan 2014 (“TLEP2014”) as they apply to
the current Consent. The subject site being Lot 1 of DP1192509 together with Lots 708, 709 and 710 in DP 1000580 is zoned
RU1 pursuant to TLEP2014 and complies with the definition of an approved development for Animal Establishment . MOD 4 does
not seek consent for a new land use on the ABLP site and as such the proposed modification to the approved Animal Establishment
remains permissible and any modifications are subject to s4.55(1A) of the Act. The modifications in MOD 4, as detailed in Section
5 of this report are an ancillary component to the approved Animal Establishment consent provided in the 2005 approval by the
Minister for Infrastructure and Planning, under DA-282-11-2004-i.
Page 16
Furthermore, as MOD 4 seeks to update the current Consent to account for the operational needs of ABLP as the business
develops, specifically the need to install suitable onsite emergency and relief accommodation and to update the seawater supply
levels for consistency with the EPA license, MOD 4 does not deviate from the purpose of the Consent and is therefore consistent
with TLEP2014.
6.2 Environmental Planning and Assessment Act 1979 (“EPAA”)
The modifications the subject of MOD 4 are sought in accordance with section 4.55(2) of the EPAA.
Section 4.55(2) of the EPAA, states:-
(2) Other modifications A consent authority may, on application being made by the applicant or any other person entitled to act on a consent granted by the consent authority and subject to and in accordance with the regulations, modify the consent if:
(a) it is satisfied that the development to which the consent as modified relates is substantially the same development as the development for which consent was originally granted and before that consent as originally granted was modified (if at all), and
(b) it has consulted with the relevant Minister, public authority or approval body (within the meaning of Division 4.8) in respect of a condition imposed as a requirement of a concurrence to the consent or in accordance with the general terms of an approval proposed to be granted by the approval body and that Minister, authority or body has not, within 21 days after being consulted, objected to the modification of that consent, and
(c) it has notified the application in accordance with: (i) the regulations, if the regulations so require, or (ii) a development control plan, if the consent authority is a council that has made a development control plan that requires the
notification or advertising of applications for modification of a development consent, and (d) it has considered any submissions made concerning the proposed modification within the period prescribed by the regulations or
provided by the development control plan, as the case may be.
Subsections (1) and (1A) do not apply to such a modification.
This application has been made in accordance with the above provisions.
6.3 Environmental Planning and Assessment Regulations 2000
The MOD 4 modifications remain consistent with the requirements of the Environmental Planning and Assessment Regulations 2000 as they apply to the Development. The Development will be carried out as previously approved.
6.4 Environmental Protection Licences
Both Australian Bay Lobster Producers (EPA License No. 12947) and the Kingscliff STP (EPA License No. 12684) hold
Environmental Protection Agency licenses for wastewater discharge. As noted in Stage 1a of the Consent, ABLP’s wastewater is
discharged to the Kingscliff STP where it joins the wastewater of the Kingscliff STP before being discharged at the nominated
Tweed River location.
The proposed modification will not require any variation to the existing Environment Protection Agency licences for wastewater
discharge or other monitoring for ground water or noise. However, MOD 4 does seek to update the existing conditions concerning
the fresh seawater collected from the Tugun Desalination Plant and the Tweed River to the site to align the Consent with ABLP’s
EPA licences. This will require the amendment to the definitions for Stage 1a and Stage 1b, Schedule 1 of the Consent as outlined
in this application.
6.5 Waste Management
Page 17
Anticipated Volumes of Waste Streams
Subject to approval, the filling of the site will involve sourcing, treating and depositing PASS, VENM and ENM. However, approval to
use PASS to fill the site is sought on a temporary basis only, as it will be limited to a maximum of 500,000m3 or 25% of the fill
required to raise the site over a four year period. The remainder of the fill will be made up of VENM (estimated 300,000m3 being
15%) and ENM (estimated 1,200,000m3 being 60%).
The maximum daily, weekly and annual material anticipated for the filling of the site is identified in Table 2 below.
Table 2: Anticipated Filling Schedule Volumes Material Source Maximum Daily Expected Weekly Expected Annually
Potentially Acid Sulphate Soils
(Periodically subject to availability.) 481m3
2,403m3
125,000m3
Excavated Natural Material 1,153m3 5,769m3 300,000m3
Virgin Excavated Natural Material 288m3 1,442m3 75,000m3
Sources of Waste Streams and Process Handling
The waste streams will be sourced locally from the southern Gold Coast and northern NSW regions, with a particular focus on the
Tweed Coast region depending on the availability and usability of materials. As the location of the ABLP site is adjacent to a major
transport route (M1 Pacific Motorway) and as the surrounding land is zoned 1(b) Agricultural Protection pursuant to TLEP2000, the site is well positioned to take advantage of the opportunity to utilise local PASS, particularly given that ABLP will be equipped
to treat and stabilise the material on site free of adverse environmental impacts on adjoining neighbours.
All processes involved with the excavation, transport, handling, storage, treatment and stabilisation of PASS will be consistent with
NSW EPA Waste Classification Guidelines. Immediately after excavation, PASS will be kept wet at all times during the subsequent
handling, transport and storage of the material, up until it can be disposed of safely. After excavation all PASS will be transported
to the site within 16 hours of being excavated which will minimise its transport through the region where it will be deposited into
a PASS treatment pad for handling at the ABLP site. ABLP does not intend to stockpile PASS before treatment, however should
this occur (in exceptional circumstances) the soils are to be stored in an environment that ensures minimal to no environmental
impacts from the acid leachate produced. As part this process consideration will be given to the setbacks to adjoining neighbouring
properties and environmental other features such as topography. Moreover, the following safety measures will be incorporated as
part of protocol for PASS that is stockpiled on site before treatment, which are consistent with ASSMAC’s Acid Sulphate Soil Manual
(1998):
• incorporating an impervious pad on which to place PASS;
• implement an artificial form of capping the PASS if storage is for longer than a few weeks to minimise the surface area
exposed to oxidation;
• construct diversion banks upslope to prevent run-on water; and
• consider sediment control structures to ensure sulfidic material is not eroded.
Treatment of PASS is to occur on site via a treatment pad, leachate drain and leachate dam (see Appendix E - Acid Sulphate Soil
Management Plan). Once the PASS material has been placed in the treatment areas it will be allowed to drain (with leachate directed
into the leachate collection pond) and then dosed with a neutralizing agent (e.g. aglime). This treatment process involves adding
enough lime (calcium carbonate) to balance the final pH of the post oxidised soil to approximately 5.5pH and in accordance with
ASSMAC’s Acid Sulphate Soil Manual (1998). A key parameter is the liming rate or the rate at which the lime needs to be applied
to neutralise potential net acidity. Calculating the quantity of lime in addition to the application methods to be applied wi ll be
Page 18
detailed prior to PASS works commencing and will be consistent with ASSMAC’s Acid Sulphate Soil Manual (1998) section 6.1.
Following treatment the PASS will be sampled and tested in accordance with Step 5 in Part 1 of the Waste Classification Guideline
(2014)to determine whether any other contaminants are present in the material. As part of this testing, quality control measures
will be implemented in accordance with EPA Waste Classification Guidelines (2014) and the ASSMAC’s Acid Sulphate Soil Manual
(1998), inclusive of recording the time of the soil excavation, quantity of soil treated, the pH of the soil and the EPA
superintendent’s quality review and comments. Any excess or unwanted PASS will be disposed of at an EPA licensed waste facility
under the direction of the EPA superintendent. The disposal will be carried out in accordance with the EPA’s Waste Classification
Guidelines (2014) and will be undertaken within 8 hours of receiving the PASS, having been stored wet at all times up until burial
at least two (2) metres below the lowest historical level of the water table. Additionally, documentation will be provided to landfill
of each truckload of potential ASS received, detailing that the soil’s excavation, transport and handling have been in accordance
with the ASSMAC’s Acid Sulphate Soil Manual (1998). Furthermore, the treated PASS will be tested to ensure the material is
sufficiently neutralised before it is incorporated into the fill as part of the fill and raise flood mitigation strategy and in compliance
with condition 4.39 of the Consent.
As the treated PASS will not be removed from the site following neutralisation and is intended for use in the construction of the
ABLP site, the receipt and treatment of PASS is not a separate or new use of the ABLP site, but is an ancillary process to facilitate
the Consent. The proposed use of PASS as part of the fill and raise flood mitigation strategy is consistent with the aims, objectives and guidance
in the NSW Waste Avoidance and Resource Recovery Strategy 2014-2021 (“WARRR”). Specifically, the objective of the WARRR is
to reduce the environmental impact of waste by utilizing resources more efficiently, in part by recycling materials through the
productive economy to help create jobs and grow the NSW economy base. ABLP intends to support the WARRR by recycling PASS
for use in its fill operations with negligible risks posed to the environment or neighbouring community. The inclusion of PASS in
the site fill is also a more commercially viable option to achieve a flood free site and generates numerous employment opportunities
within community, which in turn stimulates the local economy.
6.6 Water Considerations
The water considerations covered in the Consent concern three (3) broad categories; stormwater management, the protection of
natural water resources surrounding the site and water involved with the cultivation of bay lobster (i.e. seawater and wastewater
quality). The flooding impacts and sediment, and erosion controls associated MOD 4 are discussed separately in the sections
below.
Stormwater Stormwater management encompasses two main components, namely, the collection of rainwater runoff from the roofs of the
structures at the ABLP site and the implementation of a flood mitigation strategy to protect the ABLP site from a 100-year ARI flood
event. MOD 4 does not propose to alter, in any way, the impervious area at the ABLP site, the total catchment area for the
Development, nor any existing external stormwater assets that are assessed and approved under the Consent. Additionally the
proposed modification will not have any impact on flood liability. Please refer to section 8.1 below for further information on this
point.
Surrounding Natural Water Resources
The protection of natural water resources, including categorised water streams, courses or bodies surrounding the site, will not be
affected by the proposed modification. MOD 4 relates to the inclusion of additional fill materials for use in the flood mitigation strategies
implemented at the site and as such it will not alter the discharge levels of untreated water over and beyond that already approved
in the Consent. Therefore the modification will not in any way diminish the quality of water in the surrounding water streams,
courses or bodies.
Production Water Water considerations relating to the cultivation of bay lobster concern seawater intake quality, seawater treatment, seawater
storage/economy and the outflow wastewater quality that is to be conveyed back to the Kingscliff STP. MOD 4 does not propose to
alter any conveyance of water through pipelines, the greenhouse structures themselves or the treatment of water within the
structures or operational arrangements of the Development. As a result the proposed modification will not alter the quality of
Page 19
wastewater associated with the cultivation of bay lobsters over and beyond what is provided for in the Consent.
6.7 Flood Impacts
Perhaps the most significant issue associated with the Development is the effects of flooding on the operational activities at the
site and the corresponding impacts of ABLP’s flood mitigation measures on the local floodplain. As present, the Consent incorporates
the use of a combination of borrow pit construction (to source bunding soil) and bunding to raise the perimeter of the ABLP site to
a height of 4.0 metres AHD to protect against a 100-year ARI flood event.
MOD 4 does not seek to change the requirement to protect the ABLP site from a 100-year ARI flood event, instead it is aimed at
incorporating an additional flood protection method, specifically the conventional filling of the site to raise it to 4.0 metres AHD. As
part of this method ABLP seeks to modify condition 4.39 of the Consent to allow the importation of VENM, ENM and PASS to the
site for use in the fill and raise operations. To confirm, the fill and raise method is in line with the currently approved bunding
method and as such it will only be conducted within the ABLP site (the 45 hectares on which Farms 1 to 3 will be located on Lot
1 DP1192506) and not beyond this area. Therefore from a flood perspective, the loss of floodplain storage and obstruction to
flood flow remains unchanged. Further, as this application maintains the spatial extent of earthworks for the approved fill being
undertaken for stages 1-3, a revised flood impact assessment is not required and would be redundant.
6.8 Erosion and Sediment Control Considerations
As MOD 4 relates to the type of fill material permitted for use in the fill of the ABLP site, including the importation and treatment
of VENM, ENM and PASS, the modification will not have any implications to erosion and siltation at the site over and above those
considered and approved under the Consent.
In keeping with the Consent, the construction works relating to the fill and raise of the ABLP site will continue in accordance with
the best practice measures for the prevention of erosion and degradation of sediment. As part adhering to these best practices the
following sediment and erosion mitigation measures will be undertaken:
• where necessary, runoff will be directed to sediment fences, hay bales and/ or gully grate control devices to capture mobilised sediment;
• where necessary sediment traps will be installed along overland flow paths within disturbed areas;
• stockpiles will be sited away from drainage lines;
• vegetation clearing and site disturbance will be minimised;
• fuels and chemicals will be stored away from drainage lines and within bunded areas, and
• following completion of the works, the site will be cleared of all debris, spoil and foreign matter.
The conditions of the Consent concerning the the implementation of an Erosion and Sedimentation Control Management Plan as
part of the Construction Environmental Management Plan (CEMP), inclusive of conditions 4.5-4.8, and specifically 8.3, are to be
retained. Accordingly, by executing the measures referenced above in combination with the existing sediment and erosion controls
in the Consent, there will be no additional erosion and siltation implications over and above those considered and approved under
the Consent.
6.9 Soil Considerations
Soil testing for PASS was carried out at the ABLP site by Douglas Partners in 2004 and indicated Acid Sulphate Soils are present
at the site. The tests indicated a variation in net acidity from <0.02% to 0.27% Sulphur and accordingly it was recommended that
an Acid Sulphate Soil Management Plan be required for works that would result in the disturbance of soils on the site.
In connection with this, it was originally proposed to excavate soils from within the ABLP site, by way of a borrow pit, for use in the
fill works. MOD 4 seeks to amend the Consent in this regard to reflect the terms of the current arrangement to fill and raise the
site, and to amend condition 4.39 to permit the importation and use of VENM, ENM and PASS to fill the site.
Page 20
In particular, ABLP acknowledges the concerns with using PASS as part of the site fill due to the environmental and human safety
considerations associated with the material. Notwithstanding, ABLP guarantees that all PASS introduced to the ABLP site will be
treated on-site in a designated location using an EPA approved treatment pad, leachate drain and retention dam(refer to Appendix
E - Acid Sulphate Soil Management Plan). Once the PASS material has been placed on the treatment pad it will be allowed to drain
(with leachate directed into the leachate collection pond) and then dosed with a neutralizing agent (e.g. aglime). This treatment
process involves adding fine ag-lime with a neutralizing value (NV) of at least 95% (calcium carbonate) to balance the final pH of
the post oxidised soil to approximately 5.5pH in accordance with ASSMAC’s Acid Sulphate Soil Manual (1998). The application
rate for applying the neutralizing agent (liming rate) to the soil will depend on the agent used, however, the calculation of the
quantity of lime in addition to the application methods to be applied will be detailed prior to commencing any works involving the use
of PASS material and will be consistent with ASSMAC’s Acid Sulphate Soil Manual (1998) section 6.1.
All leachate generated during the treatment operations will be directed to collection ponds and properly treated to achieve the target
levels detailed in in table 3 below.
Table 3: Proposed Monitoring Frequencies and Target Levels Material Test Frequency Target Level
Leachate Water
Ponded leachate water (from ASS
treatment)
pH Field measurement: -immediately following rain
events and non-work periods
pH 6.5-8.5
Leachate for disposal into collection pond pH Field measurement:
-immediately prior to disposal
-checks during discharge period
pH 6.5-8.5
Treated Potential Acid Sulphate Soils
Soil during treatment/ prior to reuse Visual assessment Prior to reuse/ backfilling of
the pit
-no effervescence
-no release of sulphurous odour
Field pH Field or laboratory
measurement:
-during treatment
-if required laboratory testing
of SPOCAS will be undertaken
pH >6.5 ASMAC (1998)
Oxidised pH Field or laboratory measurement: -during treatment
-if required laboratory testing of SPOCAS will be undertaken
pH >6.5 ASMAC (1998)
Following ag-lime treatment, the soil will be sampled and tested in accordance with Step 5 in Part 1 of the Waste Classification
Guideline (see Appendix ??). Samples will be collected at a rate of one (1) sample per 25 m and tested (pHF – pHFOX) by a
suitably qualified environmental consultant experienced in the management and monitoring of acid sulphate soils, before being
used in the fill operations at the ABLP site or transported for offsite disposal. The rate of sample per m³ may increase if it is shown
that the liming rate is successfully neutralising the PASS. All personnel are responsible for reporting all incidents to their supervisor
and project environment team. A short term and long-term controls or remediation plan will be prepared and, if required, implemented
immediately by an environmental consultant to control the adverse impacts of acid sulphate soils.
In addition to the above, visual inspections of work areas will be undertaken by a qualified and experienced person to identify signs
Page 21
of PASS or oxidation. Such inspections will include checking for the following:
• unexpected scalding, degradation or death of vegetation;
• unexplained death or disease in aquatic organisms;
• formation of the material jarosite or other acidic salts in exposed or excavated soils;
• areas of green-blue water or unnaturally clear water indicating high concentration of aluminium and/or low pH;
• rust coloured deposits on plants and on the banks of water bodies and watercourses indicating iron precipitates;
• black to very coloured waters indicating de-oxygenation; and
• any sulphurous smells.
Quality control measures will be implemented in accordance with EPA’s Waste Classification Guidelines (2014) and the ASSMAC’s
Acid Sulphate Soil Manual (1998), inclusive of recording the time of the soil excavation, quantity of soil treated, the pH of the soil
and the EPA superintendent’s quality review and comments.
Based on the advice of external consultants, ABLP understands that the monitoring, testing and control protocols referenced above,
are sufficient for the safe use of PASS in the filling of the ABLP site. It is ABLP’s primary concern to ensure the material will not
cause environmental harm to the drainage lines, watercourses, and riparian lands on nearby properties.
6.10 Traffic and Access
MOD 4 will not increase the quantity of fill required to fill the ABLP site and does not propose a new land use. Therefore the existing
conditions of the Consent pertaining to truck and traffic movement will remain unchanged and as such a traffic impact assessment
is not considered necessary for this modification.
A detailed traffic impact assessment was previously carried out by Traffic Planning Services to assess the traffic impacts associated
with ABLP’s proposed aquaculture development. The report investigated the contemporary traffic conditions at the Pacific Highway/
Tweed Valley Way interchange and estimated the future traffic conditions in the area. This was assessed in contrast with the traffic generated by
the proposed development and the impacts of increased volumes of traffic on the Melaleuca Station access intersection at Tweed
Valley Way and the access road junction encompassing the on and off-ramps at the eastern side of the interchange.
The report found:
• traffic generated by the proposal would have minimal impact on the adjacent road network;
• the Tweed Valley Way/ Melaleuca Station access intersection would cater for the traffic generated by the development in the absence of any upgrades to the intersection layout; and
• the southbound on and off-ramp loop intersection with the local road on the eastern side of the interchange would need
to be upgraded to provide a separate left turn deceleration land and taper approximately 100m in length (with left turn
island) to cater for development traffic..
In order to account for the increased traffic from the development, conditions 4.26-4.38 of the Consent detailed traffic and transport
requirements prior to commencement of Stage 1 works. All such conditions have been addressed by widening and sealing Lot 51
DP1056966 (Melaleuca Road), completing the deed of agreement with RMS and preparing a revised Traffic Management Plan
(dated February 2009) nominating the following access points for the development:
• a variable message sign to be installed at a location agreed to by the RMS to advise southbound motorists that trucks will be turning into Melaleuca Road;
• heavy vehicles travelling north from the site will need to first travel west on Tweed Valley Way to the intersection of Cudgen Road and Tweed Valley Way. Utilising the existing RMS stockpiles on the eastern side of Cudgen Road, trucks will perform a right hand turn out of Cudgen Road and travel east to merge onto Pacific Highway; and
• under no circumstances are trucks leaving the ABLP site to use the existing U-turn facility opposite Melaleuca Station or to use any cross-overs located on any route that is reserved from RMS or emergency vehicles.
All the above traffic management arrangements have been completed in coordination with DOP, RMS and the Tweed Shire Council.
MOD 4 will adhere to the traffic management arrangements above in addition to conditions 4.26-4.38 of the Consent upon carrying
out the filling for future stages. A further traffic assessment was carried out recently by Rytenskild Traffic. This report recommended
Page 22
that the existing arrangements (subject to minor works) were sufficient for the importation of fill to the site. Refer to Appendix ??
for a copy of the report.
6.11 Noise and Vibration
Richard Heggie Associates Pty Ltd (“RHA Pty Ltd”) were commissioned as part of the original Consent to assess operational and
construction noise emissions from the proposed development on the nearby residential receivers. The assessment was conducted
in general accordance with the guidelines presented by the EPA’s Industrial Noise Policy and Environmental Noise Control Manual.
In summary, RHA Pty Ltd found that the level of noise emission from the ABLP site did not require specific noise control measures
to offset the operational noise generated by the facility. Further, ABLP was not required to implement specific controls during the
construction of Stages 1, 2 or 3 of the Development. Both advices maintain relevance to MOD 4 in relation to fill material
transported to the ABLP site for Stages 2 and 3.
MOD 4 will require all PASS introduced to the ABLP site to be treated on-site using an EPA approved treatment pad, leachate drain
and retention dam(refer to Appendix E - Acid Sulphate Soil Management Plan). The PASS treatment works will be undertaken on
site in accordance with the EPA’s Environmental Noise Control Manual and will not give rise to an ‘offensive noise’ as defined under
the Protection of the Environment Operations Act 1997 and accompanying Regulations. All measures will be put in place to
minimise noise emissions from plant and equipment operated on the site in connection with the Development by installing and
maintaining, wherever practicable, efficient silencers and low-noise mufflers (residential standard), and by replacing the reversing
alarms on vehicles with silent hazard warning alternatives (flashing lights). Otherwise the future operational activities of the
proposed development remain consistent with the Consent and as such conditions 4.51, 4.53, 4.55 and 4.56 of the Consent
remain relevant and applicable to the Development moving forward.
6.12 Air Quality & Dust
The ABLP site is located at 9484 Tweed Valley Way, Cudgen on the eastern side of the M1 Pacific Motorway. The surrounding
land is primarily designated for rural use, with the exception of a number of other non-rural commercial operations located on
neighbouring land, including Melaleuca Station Crematorium, Caltex Chinderah, Kingscliff STP and a sand mining operation
located on the neighbouring property to the east of the site. While no site- specific air quality data is available, the existing air
quality in the vicinity of the site is expected to be good given the largely rural nature of surrounding land use and the lack of other
nearby significant industrial activities.
Per the Consent, the ABLP site is to be protected from a 100-year ARI flood event. This has been completed for Stage 1 of the
site, however the remaining area allocated for the Stages 2 and 3 remains at approximately 1.0m AHD, forming part of the broader
Tweed River flood plain. The volume of fill material and its transport to the ABLP site for Stages 2 and 3 will remain unchanged,
under MOD 4, however the material itself and the treatment of selected material (PASS) forms part of the proposed modification.
Notwithstanding, as the nature of the works filling works for Stages 2 and 3 will remain unchanged from the Stage 1 filling works,
the former air quality management techniques can be applied, including:
• sealing of the bund wall and fill material after stabilisation;
• the short-term dust management, in particular dust created by sealing operations, via scheduled water spraying activities;
• long term dust management by establishing new vegetation growth to cover on bare areas;
• all trafficable areas and vehicles manoeuvring on the site must be maintained in a condition that will minimise the generation or emission of wind blown or traffic generated dust from the site at all times.
Management techniques to minimise and prevent airborne pollutants (such as dust) will be applied across the transportation,
onsite storage and filling operations involving the material, including:
• all fill materials will be either treated or used in the fill operations upon delivery to the ALBP site. As such there will be no stockpiling of VENM, ENM or PASS in order to reduce airborne dust; and
• PASS will be kept wet at all times during excavation and subsequent handling, transport and storage, until the material is treated or disposed of safely.
Page 23
At the completion of the Development all outdoor spaces will be landscaped with native vegetation or pavement inserted to protect
ground soil from wind or erosion and to prevent airborne dust deteriorating air quality. Internally, all areas of the facility are paved
or gravel lined to preserve air quality and avoid erosion.
6.12 Odour
Animal Feed The ABLP Development is regarded as an intensive animal husbandry facility due to the large biomass of animals. The potential for
odours in connection with the ABLP operations arise from leftover feed that is not consumed by the animals, disposal of waste
associated from food processing and food preparation. To note, as the animals are aquatic their food remains submerged
underwater and does not create odours until it is removed from the water.
Fill Material MOD 4 includes the importation of VENM, ENM and PASS to the site for use in the fill operations. PASS are soils that contain iron
sulphides or sulfidic materials that have not been exposed to air and thus are not oxidised. The main characteristics of PASS are
its silty texture, black or grey coloration and marsh like odour, comparable to a mangrove mud. Once treated the odour dissipates
which is in part the reason that ABLP intends to avoid stockpiling of PASS onsite in favour of immediate treatment upon delivery. This will
negate the odour emissions from any PASS that is delivered onsite.
The Protection of the Environment Operations Act 1997 (POEOA 1997) defines an offensive odour as follows:
(a) That, by reason of its strength, nature, duration, character or quality, or the time at which it is emitted, or any other circumstance:
i. is harmful to (or is likely to be harmful to) a person who is outside the premises from which it is emitted, or ii. interferes unreasonably with (or is likely to interfere unreasonably with) the comfort or repose of a person
who is outside the premises from which it is emitted, or (b) That is of a strength, nature, duration, character or quality prescribed by the regulations or that is emitted at a time, or in other circumstances, prescribed by the regulations.
Consistent with Assessment and Management of Odour from Stationary Sources in NSW 2006, the character of a particular odour
can only be judged by the receiver’s reaction to it, and preferably only compared to another odour under similar social and regional
conditions. The level at which an odour is perceived to be of nuisance can range from 2 OU to 10 OU for less offensive odours .
Experience gained through odour assessment from proposed and existing facilities in NSW indicates that an odour performance
criterion of 7 OU is likely to represent the level below which ‘offensive’ odours should not occur (for an individual with a ‘standard
sensitivity’ (2) to odours). Therefore, the policy recommends that, as a design criterion, no individual is to be exposed to ambient
odour levels of greater than 7 OU.
The nearest residence to the ABLP facility is located approximately 500m away (Melaleuca Station (owners’ residence) to the
east, with the next closest house over a kilometre away. For dispersion modelling purposes, the odour performance criteria are
applied at the nearest existing off-site sensitive receptor. For a single residence the odour performance criteria remain at 7OU as
previously approved and with a major transport route intersecting.
If permitted, upon arrival at the ABLP site PASS will be treated immediately in order to limit their exposure to the local environment.
The treatment process will remove the odour associated with PASS before it is deposited in the general fill works and compacted,
eliminating any odour whatsoever. Therefore potential harm or interference to a person from the odour emitted by PASS will be
eliminated at the ABLP site due to the treatment protocol in force. The management and minimisation of odour generation at the
site per condition 4.47 of the Consent is to be considered in preparing the protocol for the importation and treatment of PASS at
the ABLP site. Considering this, MOD 4 does not limit ABLP’s ability to comply with conditions 4.44- 4.47 of the Consent.
6.13 Visual Quality
As MOD 4 predominantly relates to the type of soil material imported to the ABLP site, the visual amenity of the site will not be
Page 24
diminished in any way over and above that already assessed and approved. The production buildings are to remain at the height of
5800mm and the processing building is also to remain at 11000mm from ground level, (considering the site is raised to 4.0m
AHD) consistent with flood protection measures.
From the south, small sections of the ABLP site can be viewed from balconies of selected properties located on the Cudgen Plateau,
otherwise the majority of houses on the plateau are unable to view the site due to a land spur located to the west of Cudgen. A
small number of rural properties on the northern side of Cudgen Road have clear views of the site, however, the closest residence
is approximately 1.7 kilometres away. Other nearby residences are located approximately 500m to the west of the site (Melaleuca
Station and 9480 Tweed Valley Way, Chinderah) although are at or below the proposed level of the ABLP facility.
In order to minimise the visual impacts from the construction and operational activities associated with the development, the measures
approved in the current Consent will be retained for Stages 2 and 3. These include but are not limited to:
• The ABLP facility is partially screened from vehicles travelling on the new Pacific Highway by an existing stand of trees on the western boundary of the site and this stand has been increased in density by new plantings;
• A 10m landscaping vegetation buffer surrounding the perimeter of Stage 1 has been constructed and will continue
around the stages 2 and 3 as they are constructed. The buffer is to aid in reducing the visual bulk of the development and is sufficient in width to visually buffer the project from the Pacific Highway and surrounding properties.
• The ABLP site has been designed and constructed to be sympathetic with the local landscape.
• The future fill and raise of the site will be in accordance with the approved height in the Consent which will partly obscure the project.
• External lighting associated with the development is to be screened and directed in such a manner so as not to cause a nuisance to surrounding properties and roadway. The lighting proposed for the development is a minimum level of illumination necessary and is to comply with AS 4282(INT) 1995 – Control of Obtrusive Effects of Outdoor Lighting.
MOD 4 will not to diminish the visual amenity of the ABLP site in anyway over and above what is currently approved. To ensure
this, a number of visual reduction initiatives have been retained to minimise the visual impacts for the Development. Such initiatives
include vegetation buffers, spatial separation from residential uses in the surrounding area, the selection of congruent cladding
material with the surrounding natural environment and the screening of external lighting.
6.14 Consultation
The Tweed Shire Council, Environment Protection Authority, the Office of Environment and Heritage and Roads and Maritime
Services had all been consulted at the time of preparing this report. See Appendix C - Authority Consultation.
ABLP has endeavoured to satisfy those items requested by external authorities, however some of those items that do not relate to
MOD 4 have not been provided. As continuously mentioned throughout this report, MOD 4 is predominantly focused with obtaining
consent to allow the importation of additional fill materials to the ABLP site. This permission has a nexus to the approved Consent
(flood mitigation measures) and as such the modification is not proposing a new land use. Therefore all environmental impacts of
the MOD 4 have been assessed by way of the previous modifications and the Consent. ABLP confirms that the safety and protective
measures recommended by third party consultants or otherwise, will be maintained and strictly adhered to in the undertake the
further works associated with Stages 2 and 3 of the Development.
7.0 Condition Amendments
The following conditions of the Consent require amendment as a result of this modification request. The modified conditions are
to act as suggested wording pending the Department’s review. For ease of reference the modified conditions cite the existing
wording in the current Consent with amendments evidenced by underlined text (for additions) or struck out text (deletion). Any
new conditions proposed to address by MOD 4 are provided as new conditions and cited in the relevant sections of the approval.
Condition
Number Title
Potential Change Justification
Page 25
- Schedule 1 – Land
description
Update Update to reflect property amalgamations/boundary
adjustments and to reflect the intent of modifications
outlined earlier in this report.
- Definitions Update Update definitions for ‘Stage 1a works’ and ‘Stage 1b
works’ to reference updated supply/source of seawater
and to reflect the intent of modifications outlined earlier
in this report.
1.1 Application documentation Update Update to reference MOD 4 documentation and any
subsequent response to submissions.
1.2 Inconsistency between
application documentation
and development consent
Update Update to reference changes to Condition 1.1.
1.3
Amend species restrictions
Update
Update to allow for the commercial cultivation of other
aquatic species, subject to the approval of the
Department of Primary Industries and the Planning
Secretary.
4.1a Temporary wastewater
disposal for Stage 1a
Removal Remove any reference to temporary wastewater
discharge at Chinderah or any other location as all
wastewater discharge is now to the Kingscliff STP
under the control of Tweed Shire Council.
4.1b
Temporary seawater supply
Update
Update to reflect potential changes to the
development’s staging and to accommodate delays
experienced during detailed design of the seawater
pipeline. This will include the use of a fail-safe seawater
supply option at Jack Evans Boatharbour over Council
land.
4.3
Effluent discharge limits
Removal
Propose to remove this condition so as to rely on the
effluent limits referenced in Condition L2.4 of the
development’s Environment Protection Licence (EPL).
4.4 Daily volume of effluent
discharge
Update Propose to update the conditions to more accurately
align with the discharge volumes referenced in the EPL.
4.10 Stormwater infrastructure Update Propose to update conditions to remove any reference
to a borrow pit as it was never constructed.
4.13 Flood impacts – Bund wall Removal Propose to update conditions to remove any reference
to a bunding so as to reflect the proposed filling of the
land.
4.15 Flood impacts – Floodgates Removal Remove and or amend conditions where references are
made to floodgates as they are not necessary in the
circumstance where filling is proposed.
4.16
Perimeter bund wall -
Landscaping
Update
Propose to amend the conditions to more accurately
align with ongoing filling of the site and the
construction of the northern landscaping mound,
particularly in the context of the previously proposed
perimeter bund wall.
4.28
to
4.37
Carparking and traffic
management
Update
Potential updates to reflect current operations, remove
conditions which are no longer relevant, and reflect
parking arrangements as the site gradually expands.
Page 26
8.0 Conclusion
MOD 4 will not alter the approved use of the land or deviate from the approved construction or operational activities referenced in
the Consent. As such there will be no additional environmental or public risk to the local environment or neighbouring communities,
above and beyond that considered in the Consent. Rather, the proposal seeks to address the evolving administrative and
management requirements of the company and is designed to update the Consent in line with the ongoing operational requirements
of the facility (as approved). The proposed modification will enable Australia Bay Lobster Producers to continue to develop the site
and facility in a commercially viable manner for the benefit of its employees and the local community, with minimal impact to the
social or environmental surroundings in the area. Accordingly, MOD 4 outlined herein is considered to be of minimal environmental
impact.
Having regard to the information presented, the proposed modification is considered to warrant the Departments support. The
Department of Planning and Infrastructure’s support for the proposed modification to DA-282-11-2004-i is respectfully requested.
Should the Department have any questions regarding the modification please do not hesitate to contact the undersigned.
Regards,
Adam Smith
Director
Page 27
Appendices
Page 28
APPENDIX A
RECENT AERIAL PLAN
Page 29
APPENDIX B
EXISTING CONSENT CONDITIONS
Page 30
APPENDIX C
TWEED SHIRE COUNCIL TEMPORARY SEAWATER EXTRACTION
CORRESPONDENCE & OTHER AUTHORITY CONSULTATION
Page 31
APPENDIX D
EMERGENCY RELOCATABLE STAFF ACCOMODATION PLANS
Page 32
APPENDIX E
ACID SULFATE SOIL ASSESSMENTS AND TREATMENT PLAN
Page 33
APPENDIX F
TRAFFIC IMPACT ASSESSMENT
Page 34
APPENDIX G
CONCEPT DEVELOPMENT PLAN
Page 35
APPENDIX H
PIPELINE ROUTE AMENDMENT
top related