15 December 2017 Moorabool Shire Council PO Box 18 Ballan VIC 3342
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15 December 2017 Moorabool Shire Council PO Box 18 Ballan VIC 3342 Submitted via [email protected] SUBJECT: BACCHUS MARSH URBAN GROWTH FRAMEWORK Cement Concrete & Aggregates Australia (CCAA) welcomes the opportunity to provide a submission to the Moorabool Shire Council on Planning Scheme Amendment C81 - Bacchus Marsh Urban Growth Framework. CCAA is the peak industry body for the heavy construction materials industry in Australia including the cement, pre-mixed concrete and extractive industries. For your information, a list of CCAA Victoria’s members is provided in Appendix 1. CCAA members nationally account for 85% of total industry output, which contributes nearly $12 billion to Gross Domestic Product, employ 18,000 Australians directly and supporting the employment of a further 89,000 people. CCAA members produce and supply the heavy construction materials that are used to construct Victoria’s infrastructure. Providing both the raw material and finished product, heavy construction materials contribute to the construction of our roads, railways, bridges, ports, airports, hospitals and schools. CCAA’s members service local, regional and national building, construction and infrastructure markets. The reliable and cost-effective supply to these markets is fundamental to sustainable growth and it is CCAA’s aim to promote policies that recognise the importance of these materials to Australia’s sustainable future. Appropriate land use planning that recognises and protects state significant extractive resources while managing local communities and the environment is a key industry priority. Resources must be protected from incompatible land use as their location is determined by geological conditions, which cannot be changed. Resources must also be located close to their market as transportation is a significant cost of operations. CCAA welcomes the recognition within the Framework document that the Darley sand quarries are a significant sand resource for Melbourne’s western growth front and construction industry. CCAA also welcomes the Framework’s Employment Objectives and Strategies to protect the valuable sand resource and to provide adequate separation distances to adjacent sensitive land uses. CCAA supports industry to engage with the community and the Department of Economic Development, Jobs, Transport & Resources (DEDJTR) to develop innovative end land uses for the quarries after the sand resources have been fully exhausted. CCAA provides the following additional comments in support of the state significant Darley sand resources: Darley Sand Quarry Investigation Area The DEDJTR Demand & Supply report 1 identifies the Inner West, comprising Macedon Ranges & Moorabool as the only major area to supply sand to Melbourne's west. In fact, the vast majority of the Inner West sand is sourced from the Darley Sand Quarry Investigation Area, comprising some 20 per cent of Melbourne's sand supply. The Demand & Supply report2 also indicates that sand production from the Inner West is identified as a critical area with potential production shortfalls of 21 million tonnes from 2015 - 2050. CCAA’s primary area of concern is the potential sterilization of the significant Darley Sand Quarry Investigation Area before the resource is fully utilized by encroachment of incompatible land uses. From the east, the proposed Merrimu residential growth precinct poses a risk, with the outlined buffer interface subject to further investigation and is potentially inadequate to protect the resource from encroachment. From the west, there is no identified buffer to the rural residential development and hence, no protection from encroachment, despite a buffer being identified in the Bacchus Marsh Buffer Assessment 3. There are recent examples such as the Mt Atkinson PSP where encroachment of incompatible land uses has sterilized existing resources in the ground and shortened the life of a proven, established state significant quarry. This situation should not be repeated at Bacchus Marsh. Transport links both north and south from the Darley Sand Quarry Investigation Area need to allow ready access to heavy vehicles to transport the sand to market. The area should not be impacted by increased congestion from increased light vehicles or be subject to potential heavy vehicle bans. Appropriate transport planning now could help separate the expected increased light vehicle traffic from the expanded residential development from the heavy vehicles. Note that the Darley Sand Quarry Investigation Area should be extended north to cover the granted Work Authority 342 that extends 2 kilometres north of Russells Road, Coimadai. Additional costs due to supply from nearest alternative source If sand production from the Darley Sand Quarry Investigation Area was prematurely stopped before the resource was fully utilised due to encroachment of incompatible land uses, the nearest alternative source of sand of suitable quality for the west of Melbourne is uncertain. Significant quantities of sand occur near the You Yangs in Greater Geelong LGA, but of insufficient volume to totally meet the forecast demand. The next closest potential sources in the west are in Surf Coast and Colac - Otway LGAs, some 100 km from the main west of Melbourne market, involving an additional 70 km transport compared to the Darley sand resource. The next closest alternative proven sand resources occur at Seymour (an additional 75 km, but this resource is also under pressure of sterilisation due to a 'no quarries in flood plain' attitude of the local Catchment Management Authorities), Cranbourne/ Langwarrin (an additional 35 km), Lang Lang (an additional 90 km) or Grantville (an additional 100 km). All of these alternatives involve transporting millions of tonnes of material across Melbourne, increasing traffic congestion, reducing productivity and increasing the costs of material, leading to an increased cost of infrastructure. The Demand Supply report also states that there is an extra $2 billion in additional transport costs incurred for every extra 25 kilometres that quarry resources must be transported from quarry gate to where the materials are used, over the period 2015-50. As heavy construction materials make on average 32% of the cost of infrastructure projects, the huge increase in the cost of transporting sand from these more distant alternative sources will contribute to an increase in the cost of infrastructure. Such increases, for example could add an extra $1.3 billion to the cost of the $11 billion Metro Tunnel. 1 Extractive Resources in Victoria: Demand and Supply Study 2015-50. DEDJTR May 2016. 2 p58, Extractive Resources in Victoria: Demand and Supply Study 2015-50. DEDJTR May 2016 3 Growth Areas Framework Plan. Background Investigation. Moorabool Shire Council & VPA, Aug 2017 CCAA Submission to Bacchus Marsh UGF Dec 2017 Page 2 of 4 The Extractive Industry Interest Areas (EIIAs), as identified via the DEDJTR online mapping tool GeoVic (http://er-info.dpi.vic.gov.au/sd_weave/registered.htm ), overlap the proposed Parwan Station, Hopetoun Park North and the south part of Merrimu. They contain potential resources rather than proven resources capable of supplying proven product to established markets. CCAA does not object to these potential resource areas being sterilised so long as the sand resource in the Darley Sand Quarry Investigation Area is allowed to be fully utilised. These EIIAs include: • Extractive Industry Interest Area 884017 - includes the Maddingley Brown Coal Mine and landfill (http://www.maddingleybrowncoal.com.au/ ). Area included as an EIIA to include the potential of basalt overburden that could be extracted to access the coal underneath. This opportunity is also dependent on the demand for coal. Additional basalt resources are currently available elsewhere. • Extractive Industry Interest Area 884021 - includes potential sand deposits. No existing Work Authorities. Limited potential for significant sand operations. • Extractive Industry Interest Area 884022 - includes potential sand deposits. No existing Work Authorities. Limited potential for significant sand operations. • Extractive Industry Interest Area 884023 - includes potential sand deposits. No existing Work Authorities. Limited potential for significant sand operations. Victoria’s planning environment needs to be internationally competitive to continue to attract capital to invest into Victoria to ensure a sustainable and competitive heavy construction materials industry. This in turn facilitates Victoria’s improved productivity, housing affordability and lower infrastructure costs. Please do not hesitate to contact me to discuss any of these issues in more detail. Yours sincerely Brian Hauser State Director Vic/Tas CCAA Submission to Bacchus Marsh UGF Dec 2017 Page 3 of 4 APPENDIX 1 CEMENT CONCRETE & AGGREGATES AUSTRALIA MEMBERSHIP FOUNDATION MEMBERS Boral Construction Materials Boral Cement Limited Cement Australia Pty Ltd Hanson Australia Pty Ltd Holcim (Australia) Pty Ltd VICTORIA ORDINARY MEMBERS Alsafe Pre-Mix Concrete Pty Ltd Fulton Hogan Industries Mentone Pre Mix Barossa Quarries Pty Ltd Hillview Quarries Pty Ltd Metro Quarry Group Pty Ltd Barro Group Pty Ltd Hymix Australia Pty Ltd Premier Resources T/A Hy-Tec Baxters Concrete Pty Ltd Independent Cement & Lime Pty Ltd Industries Pty Ltd Broadway & Frame Premix Concrete Kennedy Haulage Pty Ltd Volumetric Concrete Australia Pty Ltd Pty Ltd ASSOCIATE MEMBERS Agi-Kleen Pty Ltd Concrete Waterproofing Sika Australia Pty Ltd BASF Australia Pty Ltd Manufacturing Pty Ltd T/a WAM Australia Xypex Australia Concrete Colour Systems GCP Applied Technologies CCAA Submission to Bacchus Marsh UGF Dec 2017 Page 4 of 4 .