The RTA Intends to Expose Human Lives to these Hazards at Bulahdelah

Do you use the Pacific Highway? The following established hazards are just some of those the RTA intends to expose you and countless others to with the use of Option E for the Bulahdelah section of the Pacific Highway Upgrade:-

Boulders are Already Falling from the Cliffs of the Alum Mountain

Boulders have been falling from the Alum Mountain's cliffs since around the time of commencement of blasting for the NSW Roads and Traffic Authority's (RTA) Pacific Highway Upgrade at Nerong. (Some ten kilometres south of Bulahdelah.)

When the boulders hit the ground they shatter into fragments. The following photographs are of just some of the boulder fragments and trees which have been struck by falling boulders/fragments.

All bar the last of these photo's were taken in the tourism area at the mountain's summit. The last photograph is of a boulder-fragment damaged tree about a quarter of the way down the road from the top carpark.

And the RTA, knowing that boulders from the Alum Mountain's cliffs can reach the their planned Option E roadway area (ref. the RTA document Geotechnical Issues for Community Information - which was not issued to the community) and having been notified that there have been ongoing boulder falls from the mountain's cliffs since the commencement of blasting some ten kilometres south of Bulahdelah, continues to pursue this insanely dangerous route for the Bulahdelah section of the Pacific Highway Upgrade.

The above tree is about a quarter of the way down the road from the Alum Mountain's summit. Fragments of boulders can travel for that distance and more. Prior to recommending the Option E route to (now former) N.S.W. Minister for Roads, Carl Scully, the RTA had documented 'boulders up to six metres in diameter' in the area of the planned roadway (ref. the abovementioned RTA geotechnical document).

The RTA's Deceptions Regarding the Health Hazards of Alum Stone Dust

As is confirmed by Roads and Traffic Authority (RTA) documentation, RTA authoritarianism has been prioritised throughout the processing of the (Bulahdelah Pacific Highway Upgrade) Option E scheme and has been bolstered via the disregarding/distorting of facts related to human rights issues.

The RTA is well aware of the fact that there are multiple concerns – not just ‘one concern’ [1] – regarding the dust which would be produced during construction of Option E.

Alunit is Latin for alum. It is from this that the word alunite – meaning: alum – is derived. Alum, aluminilite, alum stone and alunite are synonyms.

Those who are not neophytes to alum stone and aren’t attempting to impress/deceive with newly gained and inadequate knowledge commonly refer to it as alum. This is the case with the nickname of the mountain in Bulahdelah’s eastern sector, ‘the Alum Mountain’. It is not and has never been: ‘the Alum Stone Mountain’; ‘the Aluminilite Mountain’; ‘the Alunite Mountain’; or, according to RTA terminology, ‘The Potassium Aluminium Sulfate [sic] Hydroxide [2] Mountain’; it is called the Alum Mountain due to the fact that alum is a name for its massive quantities of rock-forming sulphate mineral [3].

Concerns regarding alum dust were not only expressed by those who were closeted with the RTA during their closed Focus Group meetings [4]: in response to other citizens who raised concerns about alum dust (and heritage issues), the RTA’s former Project Manager for the Bulahdelah section of the upgrade declared (long before the addition of Part 3A to the Environmental Planning and Assessment Act), “The RTA can build a highway anywhere.”

In the case of alum-bearing dust, the RTA’s first step in their ‘we can build it anywhere’ approach to their Option E scheme was to attempt a put-down with the claim:

· ‘Alum does not occur naturally’.

Although alum – as in the product extracted from alum stone – can and does occur naturally, [5] it is not the processed product which is of concern to informed community members.

Next, the RTA announced:

· “We’ll wet down the dust.” (This was followed up in the EIS with ‘Wet down construction areas to minimise dust emissions’ [6].)

Commercial processing of alum stone can entail calcination (roasting – as occurs during bushfires on the Alum Mountain) followed by lixiviation (separation of soluble from insoluble substances through percolation in water) or the even simpler method of lengthy exposure to the elements. Lixiviation can also take place when alum stone is simply soaked in water. In other words, ‘wetting down’ alum-bearing dust would produce alum. (The RTA has acknowledged that ‘the chemical alum … is hazardous when mixed with water’ [7]. Also: ‘When alum is mixed with water, it forms sulphuric acid which is hazardous’ [8].)

Although arrogance and ignorance could be said to be responsible for the above two (bulleted) RTA pronouncements, nothing but a blatant attempt to deliberately endanger the health of citizens, including children incarcerated in schools near the proposal, could be responsible for the following RTA statement:-

· ‘… the raw mineral which would be exposed during construction is alunite, which is not toxic and poses no risk to the community’. [9]

The RTA has admitted that there are ‘high concentrations of acid sulphate rock’ in the Alum Mountain section of Option E. [10]

The ‘acid sulphate rock’ to which the RTA refers is alunite (alum stone). The acid it produces is sulphuric acid. The RTA has acknowledged that sulphuric acid is ‘hazardous’.

Sulphuric acid is corrosive and, as the RTA is aware, so much so that it can corrode roads.

Aluminosis – which is a Schedule 1 Prescribed Dust Disease under the Dust Diseases Tribunal Act 1989 No. 63 – and cancer are just two of the hazards posed by inhalation and ingestion of alum-bearing dust (alum stone dust).

Adele Carrall.

References:-

1. Bulahdelah Upgrading the Pacific Highway Environmental Impact Statement (Bulahdelah EIS) Technical Paper 9 3. Potential Hazards and Risks.

2. Bulahdelah EIS Summary (S35) – Air Quality.

3. Encyclopædia Britannica: http://www.britannica.com/eb/topic-18100/alunite

4. As per 1.

5. Chambers’s Encyclopædia. (Internet search results concur with this.)

6. Bulahdelah EIS Vol. 6 Technical Paper 9 Hazard and Risk Table 3.1 Page 3-8.

7. As per 1.

8. As per 2.

9. As per 1.

10. Bulahdelah EIS Vol. 6 Technical Paper 11 4.9 Acid Sulphate Rock Page 4-33.

Part 3A of the Environmental Planning and Assessment Act Enabling Devastation

The township of Bulahdelah, N.S.W., is situated on the northern bank of the Myall River about an hour's drive north of Newcastle and fifty minutes or so south of Taree.

Southern Bulahdelah

© M., A. & E. Carrall

Bulahdelah's most outstanding feature and the source of its name is the mountain in its eastern sector. Originally called Bulla Della - meaning: 'the Great Rock' - by the Worimi, the Aboriginal people who once inhabited the area, the mountain, a volcanic extrusion, was nicknamed the Alum Mountain in the late 1800s when it was discovered that much of its rock is alum stone (synonyms: alunite, aluminilite, alum) and mining for its alum content commenced.

The Alum Mountain, Bulahdelah

© M. & A. Carrall

The Alum Mountain has long been renowned for: its geology relationships; its mining history; being the site of discovery of an orchid which flowers underground (Rhizanthella slateri); and for its exceptional quantity of native orchid species.

It has also long been highly valued by many people:-

On 16th May, 1866, Rachel Henning, whose letters to her sister in England were later published in book form, wrote of the mountain: … backing up our house and the village, is “Bulladilla”, a great rocky mountain with steep sides clothed with forest and a range of perpendicular cliffs at the top which always catch the last rays of the sun long after they have left us, and very beautiful old Bulladilla looks then. Rev. Herman Montague Rucker Rupp, a renowned naturalist who lived in Bulahdelah in 1923-1924, wrote (page 123 The Orchid Man – The Life, Work and Memoirs of the Rev. H.M.R. Rupp 1872 – 1956 by Lionel Gilbert):-

“After three months of uneventful relief work, I accepted charge of Bulahdelah on the Myall River, about seventy miles north of Newcastle. The village is scattered along the western base of one of the most remarkable rocky hills in Australia, known as the Alum Mountain. Barely 1,000 feet high, its bold cliffs and rock-masses make it the dominant feature of the landscape for miles along the Myall Valley. I know of few more striking scenes than that which greets the traveller’s eye when, climbing to the summit of the range that walls in this valley on the west, the road suddenly curves, and he finds himself looking over a sea of undulating tree-tops to the strangely tinted Bulah Delah – ‘the Great Rock’ – on the far side of the valley. The colour scheme of the Alum Mountain is unique. …”

“If you approach Bulahdelah in the late afternoon and are lucky enough to see a passing shower sweep across the Great Rock, you will never forget the opalescent sheen that suddenly gleams as the rays from the western sun strike the wet cliffs.”

“The Alum Mountain is the pride of Bulahdelah.”

The mountain is a long-established part of local culture and is Bulahdelah’s principal tourism asset. One of its unique features is that the public open spaces and recreation areas on its foot provide for a wide variety of cost free activities in a natural environment which is within easy walking distance from the village shopping centre. These include a large park - the Alum Mountain Park - which was established on the foot of the mountain almost twenty three years ago and tranquil, easily accessed walking trails from which a wealth of native flora and fauna species can be viewed.

The Alum Mountain Park, Bulahdelah - A Section of the Picnic and Rest Area © M. & A. Carrall

The park, which delineates and conserves a former mine processing plant site of National significance, has two sections: a picnic and rest area and a sports recreation area, both of which are used for respite and social gatherings. It is also an education facility and is a popular stop-off point for road users.

With: State Forests 'managing, caring and sustaining'; a State Government whose slogan is: NSW Labor Securing NSW's Future; and a Federal Government which claims to have 'mainstream values', this unique ecological, geological, heritage, cultural and educational site should, it may seem, be well protectected. Not so! Largely due to an amendment - Part 3A - to the N.S.W. Environmental Planning and Assessment Act 1979 (EP and A Act), the N.S.W. Minister for Planning, Hon. Frank Sartor (email: office@sartor.minister.nsw.gov.au) has recently approved its proposed destruction by the N.S.W. Roads and Traffic Authority (RTA).

With the inclusion of Part 3A, the EP and A Act serves as a licence for the RTA and their ilk to destroy the major geographical and social infrastructure of townships and to exterminate state and nationally significant species and heritage.

In this case, Part 3A of said Act, in addition to permitting the destruction of the Alum Mountain with a massive new section of highway, six-lanes-plus in width and up to 24 metres below current ground level, also serves as a licence for the RTA to:

• exacerbate air and noise pollution within the township, sandwiching residents, children at two schools and others between two sources of ever-increasing pollution, including potentially deadly ultrafine diesel exhaust particles;

• locate part of the roadway in (13 metres below the surface of) a colluvial landslide and under 40 metre high scarps of a mountain which is prone to mass movement (landslides) and rock (and boulder) falls; and to thereby

• jeopardise the lives of construction workers, residents, visitors to the area and road users.

  With (but not necessarily limited to) Part 3A specifically stating: "environment" includes all aspects of the surroundings of humans, whether affecting any human as an individual or in his or her social groupings, it can now be said that an intent of the EP and A Act is to enable the killing of humans.

Part 3A of the Environmental Planning and Assessment Act 1979 Caters for Dysfunctional Personalities

In incorporating Part 3A into the Environmental Planning and Assessment Act 1979 (the Act) the N.S.W. State Labor Government has invalidated: all threatened species listings; all heritage listings; all Aboriginal cultural heritage listings; and all N.S.W. environmental protection agencies. (In the case of the latter, jobs and at least one department – the N.S.W. Scientific Committee – which were made pointless with the enactment of Part 3A are being maintained; yet one of the motives behind the introduction of this amendment to the Act is the notion that Part 3A projects contribute to economic growth.) Even Commonwealth listings of N.S.W. Rare and Threatened Species and Heritage are rendered ineffective by Part 3A.

Cryptostylis hunteriana – a saprophytic State and Commonwealth listed native orchid species growing on the foot of the Alum Mountain. Attempts at relocation (transplantation, translocation) will kill this species. Photograph © M. Carrall.

The power to sign off on Part 3A project proposals is in the hands of just two people from the one department: the Director General, Department of Planning (currently Robyn Kruk), and the Minister for Planning (currently Frank Sartor – email: office@sartor.minister.nsw.gov.au).

In the case of those projects where an Environmental Impact Statement (EIS) has been produced, there is no prerequisite for the Minister to even peruse it, let alone investigate its accuracy.

On the whim of the Director General and the Minister for Planning, albeit with advice from ‘experts’, immeasurable and unwarranted environmental destruction is taking place in New South Wales and United Nations Treaties which have been ratified by Australia are being contravened.

(U.N. complaint procedure: http://www.ohchr.org/english/bodies/chr/complaints.htm.)

In the case of the Pacific Highway Upgrade, Bulahdelah, although several alternatives are available, not limited to but in particular Option A – a perfectly viable, cheaper route and the safest one for road users – to the west of the township, the Director General and the Minister for Planning have given their consent for the N.S.W. Roads and Traffic Authority (RTA) to use Option E, an internal deviation, and (but not limited to) to:-

• destroy Australian heritage which is of National heritage value (ref.1);
• eliminate two non-relocatable relics of the above: a boiler wall (which, contrary to the RTA’s propaganda, is directly in the path of the proposal) and a brick crucible;

• eradicate most – if not all – of the Alum Mountain Park – a public recreation area which delineates and conserves the site of a former mine processing plant of National heritage value (and which the RTA publicly stated in Newsletters 3 and 4 would not be affected by the proposal);
• mutilate the principal and historically recognised (ref. 2) aesthetics of a small country township;
• decimate a small country township’s principal tourism attraction;
• obliterate most of and scar and pollute the remainder of the highest usage section of said tourism attraction;
• cut off public vehicular access to the summit of the Alum Mountain;
• rob Australian citizens of their culture and their natural wealth;
• increase flood levels (ref. 3) and, despite the RTA’s denial of same, have the potential to adversely impact a wetland classified as significant under State Environmental Planning Policy No. 14 (SEPP 14) – Coastal Wetlands (ref. 4);
• sandwich residents, including children in two schools, between two sources of air and noise pollution;
• turn a residential street where a hospital and a nursing home are located into a highway access road (with an estimated initial usage of some 2,000 vehicles per day);
• put humans and their lives at risk from boulder and rock fall hazards which do not exist with any other route options (ref. 5);
• put humans and their lives at risk from the hazards of land slides and land slips which do not exist with any other route options (ref.5);
• decimate terrestrial flora and fauna habitat (both actual and potential) of a National level of conservation significance (ref.6);
• destroy plants which are listed on threatened species registers, including orchid species which cannot be successfully transplanted or propagated and annihilate the Type Site of Rhizanthella slateri;
• eradicate a geological seepage-zone habitat area which is inhabited and frequented by an unusually wide variety of fauna, including: Microbats; the Blue-bellied black snake; Glossy black-cockatoos; the Red-tailed black-cockatoo; White-headed pigeons; the Green and golden bell frog and many others; the Brush-tailed Phascogale and the Powerful owl; and to
• put the Alum Mountain’s population of squirrel gliders at risk of extinction (ref. 7).

  And the RTA’s internet publicised major ‘reason’ for wanting to use the only route which would incorporate all of the above and more? It’s a blatant and ludicrous falsehood: that a power transmission easement (which is vegetated, not as the RTA falsely claims, ‘cleared’) discourages animals from moving to the area on its western side (ref.8).

This King Parrot from the Alum Mountain was photographed in the residential area on the mountain’s lower foot (west of the power line easement). Photograph © E. Carrall.

With Part 3A, the Act no longer serves as a preventative to the realisation of projects which are founded on unintelligence/negligence/corruption. And with a killer Act which itself displays contempt for the environment and for human life, it is to be expected that working on Part 3A projects will be particularly attractive to those with dysfunctional (e.g. authoritarian) or depraved (e.g. sadistic) personalities.

This year, during RTA surveying on the foot of the Alum Mountain, Bulahdelah residents found a Vietcong-style spiked trap. Its sharpened spikes, which were firmly embedded into the ground, were made of small branches from saplings hacked by the surveyors:-

A Vietcong-style spiked trap with sharpened branches from saplings slashed by RTA surveyors. Found by Bulahdelah community members during RTA surveying.

References:- 1. The RTA document: Bulahdelah (Alum Mountain) Alunite Site-Complex, A Cultural Heritage Assessment with Reference to the Proposed Bulahdelah Pacific Highway Upgrade Route. 2. Rachel Henning (19th century) and H.M.R. Rupp (early 20th century). 3. Page 7.25 of EIS Technical Paper 8 – Water. 4. EIS Technical Paper 8 – Water. 5. Soil Landscapes of the Dungog 1:100 000 Sheet – Department of Land and Water Conservation, Sydney. L.E. Henderson, 2000: page 9: ‘Mass movement occurs on steep slopes, particularly the Alum Mountain Volcanics, which are also prone to rockfall’. 6. EIS Volume 4: 3.5 Overall Conservation Values of the Study Area – 3.5.1 Terrestrial Conservation Values. 7. EIS Volume 10: Conclusions. 8. The Parsons Brinkerhoff Upgrading the Pacific Highway website: http://www.pb.com.au/bulahdelah/index.html where it was previously stated, “…The significant advantage of Option E over other options to the west of the town is that the cleared power transmission easement is immediately to the east of the alignment. This cleared easement already discourages animal movement to the west of the easement.”

The RTA's Flawed Process - Pacific Highway Upgrade, Bulahdelah

The route the N.S.W. Roads and Traffic Authority (RTA) intends to use for the Pacific Highway Upgrade, Bulahdelah – Option E – is an internal deviation; it is not a bypass in any sense of the word. The through-Bulahdelah section would be adjacent to the residential area and schools on the lower foot of the Alum Mountain, destroying the Alum Mountain Park and surrounds in Bulahdelah’s eastern sector, the cultural heart of Bulahdelah. The new section of highway, although initially catering for only four lanes of traffic, would be six-lanes-plus in width and would connect with the existing highway in northern Bulahdelah. With this route, a massive northern interchange would also be within Bulahdelah.

Yet the ‘Project’ clause of the N.S.W. Minister for Planning’s Schedule 1 Project Approval, which was given under Section 75J of the Environmental Planning and Assessment Act 1979 (the Act), is for (bold typeface added for emphasis):-

A dual carriageway highway bypass to be constructed to the east of Bulahdelah, starting approximately 4.5 kilometres south of Bulahdelah and connecting to the existing highway approximately 4 kilometres to the north of the town. The project includes interchanges to the south and north of the town, allowing access to Bulahdelah.

With the exception of the southern (pre Bulahdelah) section, in approving the Project criteria in Application No: 05_0044 (approval File No: N99/00157) the Minister for Planning, Frank Sartor, has not approved what the RTA actually proposes for the Bulahdelah section of the Pacific Highway Upgrade; he has approved RTA propaganda.

And the processing of the Option E route has entailed the use of dishonesty from its inception, resulting in an oppressive situation which should not occur in any democratic country.

The following is an abbreviated account of the RTA’s route location history and selection procedure at Bulahdelah:-

In the second half of the 1980s I was shown – and held in my hands – a large map which had been published and distributed by the Roads and Traffic Authority (at that time probably called the Department of Main Roads). The map was of the Bulahdelah Bypass and displayed one route only. It was to the west of Bulahdelah in the approximate location of Option A, with the alignment of its northern end being through the “pine forest” at the O’Sullivan’s Retreat restaurant.

Additionally, purchasers and owners of property affected by said bypass were personally contacted by the RTA.

In 1990, the Pacific Highway (State Highway No. 10) Bulahdelah – Coolongolook Deviation Environmental Impact Statement (EIS) strongly indicated that the existing highway alignment at Bulahdelah would be used for the upgrade.

When the RTA and the then PPK Environment and Infrastructure – PPK (now – and henceforth in this post – Parsons Brinkerhoff) arrived in Bulahdelah in the year 2000, previous RTA activities had caused many residents to believe that the upgrade would be to the west of Bulahdelah (and the alignment of the southern end of the Bulahdelah to Coolongolook section of the upgrade was consistent with this). Some others may have deduced from the Bulahdelah to Coolongolook EIS that the current section of highway would be used. Moreover, most Bulahdelah residents were aware of at least some of the Alum Mountain’s values and did not expect that area to be even seriously considered, let alone advocated.

In March, 2000, the local community received a brochure (Newsletter 1) titled: Bulahdelah Upgrade of the pacific [sic] highway [sic]. Inside was a blurred orange blob over a hotchpotch of crude lines purported to be a map of Bulahdelah. On the same page, the RTA stated:-

· Study Area – To commence investigations a broad study area is being examined (refer map). This area will be refined as more information is gathered. … [Note: no route options were presented in this newsletter and the study area was – Bulahdelah.]

· Upgrading Options – There is currently no preferred route for the proposal, and the RTA will consider potential routes both east and west of Bulahdelah, as well as the possibility of upgrading the existing Pacific Highway through the town. The selection of a preferred route will be based on community issues, and environmental, engineering and economic considerations. [Note: to knowledgeable community members, this, with its ‘east of Bulahdelah’ and ‘environmental, engineering and economic considerations’, excluded the Alum Mountain.]

· Environmental Assessment Process – … Throughout all stages of the project there will be extensive consultation with the Bulahdelah community and Government agencies.

Studies to assist in the development of route options include a range of biological, traffic, geotechnical and social considerations, with several field studies commencing shortly. … The EIS will then document all potential impacts of the project, in terms of traffic, the community and the environment.

The planning process for the study is shown over page, with important opportunities for community involvement highlighted. [Note: with ‘extensive consultation with the Bulahdelah community’ and ‘biological, …, geotechnical and social considerations’, to knowledgeable citizens this too meant that the Alum Mountain would not be seriously considered as highway location.]

There were no ‘opportunities for community involvement highlighted’ over the page. Said ‘opportunities’ were listed under the heading ‘Have Your Say and Get Involved’. They were: ‘being placed on the study mailing list to receive newsletters’; ‘Contacting [sic] the study team’ on a toll free telephone number; attending public displays; and the ungrammatical, unintelligible and unenlightening phrase ‘nominating for the community focus group’.

Most Bulahdelah residents were, at that time (most still are), unfamiliar with the term ‘focus group’ and the extremely uneducated ‘nominating for the community focus group’ phraseology failed to inform. There was not ‘extensive consultation with the Bulahdelah community’ during this – or any other – stage of the project.

With ‘nominating for the community focus group’ being the only clue that there was to be an integrated group of community members and, although a toll free telephone number was provided, no stated means of participating in this nominating mystery, Newsletter 1 of March, 2000, failed to notify the community as to how to participate in the consultation process. (Community consultation was, at that time, a requirement of the Act.)

The first focus group meeting was held on 10th April, 2000. Community members who had not joined the focus group were barred from entering focus group meetings. While the community had been shown only a blurred orange blob indicating that Bulahdelah would be the study area for the Bulahdelah upgrade, focus group members, some of a character which fitted very with the RTA’s loutish ‘Have Your Say and Get Involved’ (Mouth Off and Interfere) caption and some others with – or with relations with – a pecuniary interest in the location of the upgrade, were secretively involved in selecting and eliminating potential route options.

It was not until the delivery of Newsletter 2, in late July, 2000, that the community, mostly unaware of the existence of the focus group, let alone that its members were representing them, was shown any route options at all. They were: Option A, a western route with an estimated cost of $145 million; Option B, also to the west but with its northern and southern ends close to the township – estimated cost $161 million; Option C, following the alignment of the existing highway – $165 million; Option D, its southern section following the alignment of the existing highway but then deviating in an easterly direction to the foot of the Alum Mountain – cost estimation $150 million; and Option E, through the foot of the Alum Mountain and the Alum Mountain Park in Bulahdelah’s only area of cultural and heritage value – estimated cost $149 million.

On the front page of Newsletter 2, under the heading What must the upgrade achieve? the RTA had stated:-

The upgrade of the highway must provide a safer environment for everyone, reduce travel costs for users, incorporate community issues and minimise impacts on the environment. This option must:

· [1] achieve safe driving conditions for travel speeds of 110 kilometres per hour in rural areas, 80 kilometres per hour in urban areas; · [2] connect the new highway to the town; · [3] have roadway for capacity for traffic volumes 20 years after opening; · [4] maintain access to all properties; · [5] maintain operations during flood conditions; · [6] provide safe local traffic, pedestrian and cyclist facilities; · [7] complement the existing community and landscape features; · [8] examine ways to ensure noise levels meet Environment Protection Authority guidelines; and · [9] achieve community satisfaction with the development of the route.

Although the community was totally unprepared for Options D and E, with the Alum Mountain’s history and its cultural (including environmental) values plus (but not necessarily limited to) bulleted statements 7, 8 and 9, most residents did not believe that the mountain would be seriously considered as suitable for a highway location. And according to Newsletter 2, Option E was the cheapest option by $4 million. That the Alum Mountain is also known to be prone to mass movement and boulder and rock falls was yet another reason for the community to believe that the RTA would not proceed with either Option D or E.

Not much over a month after the delivery of Newsletter 2, while the community (still barred from entering focus group meetings) was stunned/disbelieved that the Alum Mountain could actually be under threat, the RTA conducted the Value Management Workshop (VMW). At that time the community did not know what the VMW was – many residents still don’t – or that it was taking place.

Apart from a (much later) cavalier re-examination of Option C, which was not for altruistic purposes and was solely due to acquaintanceship between the then Minister for Roads, Carl Scully, and a Bulahdelah member of the Labor Party, the RTA refused to consider using any route other than Option E after the VMW. Yet continued to keep the community in the dark as to the VMW and its outcome: ‘that Option E should go forward for further consideration and refinement’. Furthermore, when community members who had found out that Option E was the option preferred by all VMW attendees attempted to alert the community as to that fact, the RTA, fallaciously ascribing a sole meaning to the words ‘preferred option’ – that of the RTA’s ‘Preferred Option’ jargon in which the ‘Preferred Option’ is that chosen (on advice from the RTA) by the N.S.W. Minister for Roads as the route which will be used, accused them of, “Rumour mongering.”

The VMW outcome was not officially announced until December, 2000. This was at a public meeting organised by Focus Group members, not, despite their presence at said meeting, the RTA or Parsons Brinkerhoff. The meeting was horrific, with:

o shock/bewilderment/outrage/fury displayed by community members;

o one of the Focus Group members who had attended the VMW (where all groups present, according to the RTA, ‘signed off’ on Option E) hysterically imploring that the highway be ‘left where it is’;

o another VMW Focus Group representative (whose home is not within the residential area) telling Bulahdelah residents that Option E would be better than Option A because, with Option A, “Traffic noise would be reduced to a dull roar,” and Bulahdelah would revert to being, “A quiet little village,” or ‘backwater’; and

o an Aboriginal citizen being abused by a furious Bulahdelah resident who, in front of all present, and while the Focus Group, the RTA and PPK did nothing to stop his attack, pointed his index finger at her as a Kadaicha would point the bone, all the time shouting and shaking with rage as he told her that he knew of Aboriginal sites on the Alum Mountain.

On top of the above, one VMW Focus Group representative introduced his account of the VMW and its outcome with, “I’m not here to tell you what went on at the VMW.” As relating what occurred at the VMW was what he was meant to be doing, presumably he meant that he was not going to say what really went on at the VMW:-

At the VMW, participants from Bulahdelah were placed with sub-groups of participants who were not from the area. Bulahdelah participants were four members of the focus group (one being the nephew-in-law of a property owner with a pecuniary interest in Option E) and the NSW Police representative (son-in-law of said property owner). (An employee of Parsons Brinkerhoff later claimed that when the western options were displayed none of the Bulahdelah attendees would even look at them.)

Only sixteen VMW participants were not officially with the RTA, Parsons Brinkerhoff or ACVM (the Australian Centre for Value Management). Of those sixteen:

§ four were the abovementioned biased and grossly irresponsible Bulahdelah residents;

§ three were mere councillors (laypersons) from Great Lakes Council, which, with the RTA’s promise to deal with council’s long-term neglect of drainage in the south-eastern section of Bulahdelah’s residential area, had – and still has – a pecuniary interest in Option E;

§ one, the National Parks and Wildlife Service (NPWS) representative, was in an RTA created and funded position with NPWS; and

§ another was representing the Aboriginal Lands Council from Karuah which had – and still has – a pecuniary interest in Option E.

Of the remaining seven of the said sixteen participants, one, the State Forests’ representative, was only in part-time attendance. (State Forests’ responses to the EIS show that State Forests now considers that a western route would be preferable to Option E.)

Note: For the past six years or so Bulahdelah residents who have been involved in battling against the use of Option E believed that that left only six disinterested parties in full-time attendance at the VMW. However, earlier this year it was found that the Environment Protection Authority’s representative at the VMW has the same – very distinctive – name as that of a current RTA employee.

The VMW Report clearly shows that the RTA had a prior determination to use Option E and that suppression and reversals of the truth regarding Options A and E also contributed to its outcome:-

In the Risk Assessment for Option E (page 37 VMW Report), the ‘probability or likelihood’ of occurrence of ‘Identified Hazards’ received ‘high, medium or low’ categorisations. ‘Identified Hazard’ no. 6 was: ‘[if] Aboriginal sites are located within the footprint’. The ‘probability’ rating for this was ‘low – medium’. Yet the RTA was already aware of at least one Aboriginal site within the footprint and had documentation as to the fact that there could be more:-

· Aboriginal artefact scatters in the path of Option E were recorded in the Indigenous Cultural Heritage Component – A Report to PPK Environment & Infrastructure Pty Ltd for the NSW RTA, which was published in May, 2000, two months before the VMW.

· The Bulahdelah to Coolongolook EIS states that artefacts which may have come from the Alum Mountain were found during said EIS.

In the Initial Option Assessment the options were not allocated identical assessment criteria and were treated in an inequitable manner.

In the Option Evaluation five Option A and E Evaluation Criteria were given extremely inaccurate assessments, resulting in false Assessed Criteria Rankings for those options i.e.:-

1. Assessed Criteria B was: ‘Minimising adverse social and amenity impacts (including noise, loss of local connectivity and area segregation)’.

There are no community facilities in the Option A locality. Option A, which: would have no social or amenity impacts; would reduce noise levels in Bulahdelah; and would not cause so-called ‘loss of local connectivity or area segregation’ was rated F (fair) and allocated 30 points. Option E, which would have major acoustic impacts on Bulahdelah and would obliterate, mutilate and pollute public open spaces of long-established social usage, would maximise adverse social and amenity impacts etc. was rated VG (very good) and given 60 points.

2. Assessed Criteria C was: ‘Minimising both natural and cultural environmental impacts’.

Option A, which would be in an environmentally insignificant area with more than ample corridor width to allow for impact avoidance (and with no non-indigenous heritage whatsoever) was rated P (poor) – 20 points. The Alum Mountain is a hydro-geological seepage zone and has long been renowned for its unusual quantity of Australian native orchid and wildflower species and for being the type site of Rhizanthella slateri. Its unique mining history is also long-renowned. Option E was rated F (fair) – 40 points.

3. Assessed Criteria D was: ‘Incorporating easy access to Bulahdelah services.’

Option A, which, with appropriate interchange design, would enable road users to access Bulahdelah services via travelling in the direction of their destination and to re-enter the highway at a point closer to their destination was rated P (poor) and allocated 17 points. Option E, which (at the time of the VMW) would have entailed an increase in travelling distance – away from and back to the highway via a central interchange, was rated VG (very good) – 68 points.

4. Assessed Criteria G was: ‘Minimising adverse visual impacts and aesthetics’.

Option A, with minimal cuttings and away from the village in an area of little aesthetic significance, received a VG (very good) rating and 12 points. Option E, with a gargantuan cutting through Bulahdelah’s principal and only historically recognised aesthetic feature, the Alum Mountain, was rated E (excellent) and given 15 points.

5. Assessed Criteria H was: ‘Maximising the improvement potential for Bulahdelah’.

Option A, which would bring about improvement merely by removing traffic noise and air pollution from the village and, with appropriate interchange design and location, would also maximise potential for any further improvements to Bulahdelah, was given 9 points – which would have been either F (fair) or P (poor). Option E would destroy existent public amenities and would transfer, not reduce, traffic noise and air pollution within the village. Acoustic impacts of Option E would be exacerbated by: batters; increased traffic speed; and reverberation from the Alum Mountain. Option E would also have massive construction impacts on Bulahdelah, including high likelihood of vibration damages to buildings (especially, but not limited to, those on stumps in clay soil). Option E was rated E (excellent) and received 45 points.

Further evidence that the VMW was defective can be found in some of the erroneous claims made by the four Sub Groups when recommending that Option E be pursued and further developed.

More recently, the then DIPNR (now the Department of Planning), in a response to the EIS, questioned ‘Why Option E’ instead of another route, especially Option A. Part of the RTA’s reply was:-

‘It is also important to note that some of the key stakeholders such as the Karuah Local Land Council and DEC indicated a preference against the development of the western route options (including Option A) during the route evaluation phase. This preference was related to ecological and heritage issues identified in those areas during the earlier phase of the project or would potentially be identified in the detailed assessment phase if a western route was [sic] chosen as the preferred route option’.

This is indeed important:-

As aforementioned, the Indigenous Cultural Heritage Component – A Report to PPK Environment & Infrastructure Pty Ltd for the NSW RTA, was published in May, 2000. On page 2 of said report (which incorporated the study area encompassed by the blurred orange blob of Newsletter 1) it is stated:-

It is concluded and recommended that:

Based on the surface evidence and the present level of assessment, there are no known Aboriginal sites within the study area which would pose a permanent constraint on the proposed development.

There are no known places of special or historical Aboriginal cultural significance within the study area.

A comprehensive surface archaeological survey, followed by a program of selective subsurface testing within sensitive landforms, should be conducted along the preferred alignment(s) of the upgrade easement and depot areas.

Where possible, the preferred upgrade easement should be located in such a way that impact to landforms of predicted high and moderate archaeological sensitivity should be avoided or minimised.

Also as aforementioned, the Aboriginal Land Council at Karuah has a pecuniary interest in Option E. It was at the extremely flawed VMW that Karuah Land Council ‘indicated a preference against the development of the western route options (including Option A)’ by ‘signing off’ on Option E.

In 2003 the NPWS was amalgamated into the DEC (now the DECC). It was at the extremely flawed VMW that the DEC, via its (then NPWS) representative who was in a position created and funded by the RTA, ‘indicated a preference against the development of the western route options (including Option A)’ by ‘signing off’ on Option E.

Aboriginal Issues (in brief)

On Wednesday, 10th October (2007) the RTA placed notification of a consultation period for ‘Aboriginal groups and/or [sic] Aboriginal people’ in the Great Lakes Advocate (page 22). Titled Aboriginal heritage assessment, the notification says:-

The NSW Roads and Traffic Authority (RTA) is continuing with investigations to upgrade the Pacific Highway at Bulahdelah.

The RTA seeks the registration of Aboriginal groups and/or Aboriginal people who wish to be consulted on Aboriginal cultural heritage matters relating to the Bulahdelah upgrade.

The cultural heritage assessment may result in the RTA applying for a section 87 permit and/or a section 90 consent under Part 6 of the National Parks and Wildlife Act 1974, and may also be used in the assessment of the impact of the project under the Environmental Planning & Assessment Act 1979.

Registrations from Aboriginal groups and/or Aboriginal people wishing to be consulted must be received by phone or in writing by Friday 26 October 2007.

(The above is followed by the name of the RTA Project Engineer, postal address, email address and telephone number.)

Aside from the fact that Aboriginal groups are of Aboriginal people and the RTA’s wording, ‘Aboriginal groups and/or Aboriginal people’, which implies that they are not, is abusive, the State and the Australian Government logos are included in this notification.

The State Government and the Australian Government, as well as the RTA, have advertised that Aboriginal heritage is currently being assessed. As they have invited input from individuals, Aboriginal sites, whether or not agreed on by Karuah ‘Local’ Aboriginal Land Council, should not be tampered with in any way whatsoever until such time as said assessment period has concluded.

On 10th October, 2007, it was found that a drilling machine involved in the RTA’s BH series of drilling operations had been being used on the lower slops of the Alum Mountain near ochre-strewn ground which is, in turn, adjacent to two stone circles which may possibly be dancing rings.

Drilling machine at the RTA's BH:235 site. This has damaged an area near a possible Aboriginal site.

The peg at the abovementioned drilling site.

BH:236 ready for drilling - at the B8 Aboriginal artifact scatter site.