Mod 2

The Dunloe Sand Park Quarry Mod 2 should not be permitted to proceed.

I believe that the proposed increased vehicle movements will have
significant unacceptable impact on the endangered Tweed Coast Koala
Population and that the proposal will also impose unacceptable impacts
on the local traffic network and amenity of residents along the
trucking route.

Their Environmental Assessment for flora and fauna is limited to the
following statement:

"The proposed modification will not involve any construction or
demolition works, therefore there will be no impacts to flora and
fauna as a result of the proposed modification. Existing flora and
fauna measures will continue to be employed to mitigate any potential
impacts. No additional assessment or mitigation is required."

Where is their evidence for thier implied claim that only construction
and demolition works impact endangered koalas? I believe that
increased noise and traffic will adversely affect them.

The dwindling koala population in this area should not be exposed to
this additional noise, general commotion, stress, and danger of being
hit by a truck on the road.

This proposal does not enjoy community support.

The proposed increased vehicle movements will have significant
unacceptable impacts on the endangered Tweed Coast Koala Population.

The proposal will have an unacceptable impact on the local traffic
network and the amenity of residents living along the trucking route.

TO: The NSW Department of Planning and Environment
(Attention: Director - Resource Assessments)

MODIFICATION REQUEST: Holcim Dunloe Sands Modification 2 to Project
Approval 06/-0030, Application No MP 06_0030 MOD 2, Proponent: Holcim
( Australia ) Pty Ltd, Location: Pottsville-Moobal Road, Pottsville.

DESCRIPTION OF PROPOSED MODIFICATION: The modification seeks to amend
consent conditions to allow an increase in the number of daily vehicle
movements in and out of the site, from 80 to 240 Monday to Friday and
40 to 120 on Saturdays.


I OBJECT to the above proposal for the following reasons:-

The proposal has not adequately addressed overall amenity impacts
associated with such an increase in peak truck movements from a
general road user and local residential amenity perspective for
dwellings adjacent to the quarry and along the haul route.

There has been no consideration of the effects of the increase in
truck movements in the context of future traffic conditions over a 10
year horizon.

The Traffic Impact Assessment should have considered background
traffic growth along the identified transport route and the cumulative
impact of planned developments in the area, including the
master-planned Dunloe Urban Development which is proposed to house
6000 people.

There has been no consideration of interaction with the traffic
generated by the Splendour in the Grass and Falls festivals.

There has been no assessment of the likely impacts on the natural
environment.

There has been no consideration of impacts on the Tweed-Brunswick
endangered koala population status.

The proposal is inconsistent with the development provisions of the
Tweed Coast Comprehensive Koala Plan of Management.

There has been no consideration of potential impacts of additional
truck movements (koala mortality) both within the site and on
Pottsville-Moobal Road.

It is unacceptable that the Tweed Shire Council and Tweed Shire rate
payers will have to pay for road maintenance resulting from the extra
use of Council roads by the proposed increase in truck movements.

I believe that the proposed increased vehicle movements will have
significant unacceptable impact on the endangered Tweed Coast Koala
Population and that the proposal will also impose unacceptable impacts
on the local traffic network and amenity of residents along the
trucking route.

Team Koala Inc is a registered charitable organisation established in
2009, with a current membership of 1200 and growing, is based in
Murwillumbah. Since inception, Team Koala's objective has been the
protection and preservation of a viable Tweed Coast koala population.
Team Koala has a continuing commitment to increasing public awareness
of the endangered status of the Tweed Coast koalas. The main threats
to koalas are habitat destruction for urbanisation and farming and in
this matter, permitting the three fold increase in vehicle movements
(TRUCKS UP TO THE SIZE OF 19 METRES) which will inevitably interrupt
the life cycle and breeding habits of the Pottsville Wetland's koala
population.

The proponent has alluded to the fact that the Tweed Coast
Comprehensive Koala Plan of Management has not been endorsed by the
State Government, and consequently has made no detailed assessment
against the KPOM. Team Koala is extremely disappointed with this point
of view as it seeks to devalue an important local government
initiative, to implement a recovery strategy, for the endangered Tweed
Coast koala population. Team Koala supports the Tweed Shire Council
assertion that are compelling reasons for the proponent make a proper
assessment of the development, and to consider in depth its impact on
the endangered koalas. In this process the proponent should be obliged
to consider the Tweed Shire Council's KPOM and not be permitted to
resort to legalese to avoid this responsibility.
This huge increase in vehicle movements poses a significant challenge
to the survival of the Tweed Coast koalas. It is an indisputable fact
that vehicle strike is one of the leading causes of koala fatality.
The proponent appears to be of the opinion that koalas are not on the
move during the trucking hours of operation, namely Monday to Friday
7am to 5pm and Saturdays 7am to 12noon. However it is the personal
experience of the Team Koala membership, by way of actual sightings,
that koalas move in daytime hours for various reasons, such as mating
and males seeking new territory.
The proponent seeks these increases vehicle movements to 2035. Not
only will the noise and dust in the present be an issue for koalas and
residents, but the increasing local population and consequent increase
in light traffic, will give rise to a dangerous scenario on our local
roads for residents and koalas alike. All of this on the
Pottsville-Mooball Road which bisects an area of the landscape that is
specifically identified by the Tweed Coast Comprehensive Koala Plan of
Management. This is critical to koala connectivity due to its location
between areas of existing habitat identified by the Tweed Coast Koala
Habitat Study (2011) as a koala blackspot.
In conclusion Team Koala requests that the Department advise the
proponent that the development consider the endangered Tweed Coast
koala population as of paramount importance. Also that the proponent
be obliged to consider the Tweed Shire Council KPOM to address the
obvious shortcomings in their present proposal. The Tweed Coast is
primarily a residential area and high level extractive industries do
not really have a place here if the unique flora and fauna is to be
preserved. The opinion of Team Koala is that the proponent is
fortunate to have the current permission for extraction already in
place. To go beyond this level of quarrying is not in the interests of
the survival of the koalas, but also poses a real threat to the social
and environmental amenity of Pottsville and its surrounds.

1.The Koala is a Landscape species, an increase in vehicle traffic such
as the proponent is seeking will deny the Koala the following
a) Breeding calls to be heard by other Koalas
b) Easy traversing of landscape for breeding, in search of food and
water and general activity - not restricted to non-daylight hours .
2.The unrelenting noise from constant truck movement will create
STRESS in Koalas leading to disease.
3.The amount of DUST created from that much truck movement and in
particular on Hot days ( most of the year ) will affect the day to day
existence of the Koalas who will need to search out water - again the
need to traverse the landscape including the road.
4.Koalas are native wildlife that cannot be organised by large
businesses to only travel over land between 5pm and 7am weekdays and
on Saturdays but able to roam freely on Public Holidays and Sundays!
5.The only way to protect Koalas from the stress and disease and high
risk of vehicle strike is to not permit big companies to change
conditions put in place by Dept of Planning only then the NSW
Government can openly and honestly say to the NSW public that they are
protecting our endangered and critically endangered species.
6.Have the NSW Government put in place any "Driver Koala Induction"
training for the drivers who participate in the vehicle movements
already? If not, why not? I understand there is training available at
Ballina RMS.
7. Does the proposed increased truck movement include water trucks to
dampen the dust? If not the figures of number of trucks are incorrect
and more truck movement is the reality. What is the real number of
truck movements including the water trucks?
8.Holcims response to Tweed Shire Council's initial response to
environmental concerns for this Development/Modification is
ridiculously simplistic. "No vegetation removal of core Koala Habitat"
does not magically "have no impact on general biodiversity in the area
or core Koala habitat. When the activities surrounding this core Koala
habitat have CHANGED then you create an unnatural situation. The dusty
environment created by Sand mining will accordingly alter the needs of
the Koalas within the core Koala habitat. The increase in noise will
STRESS the Koalas making them more likely to want to travel more
readily through the daytime hours and not contain them to only travel
at night when it is eventually quiet! God help Blinky Bill who may
have been roaming around after 5pm and then didn't make it back to a
tree before 7am!!!! Much like a game of musical chairs, except the
Koala/s caught out are really the losers!
9. When dealing with a project adjacent to a core Koala habitat it is
naïve for Holcim to state that because some roads without expensive
signs to warn of Koalas crossing means that the chances of them
crossing are highly unlikely. These signs were placed before the
Mining commenced therefore adding 80 truck movements per day into the
scenario and then wanting to increase that to 240 truck movements per
day will totally affect the koala movement records that have been held
to date. The likely hood of Koalas crossing at the intersection of
Quarry Access Rd and Pottsville Rd is more likely due to the change in
the surrounding environment activity.
10. Holcim cannot and should not be permitted to avoid the Development
provisions of the Tweed Coast Comprehensive Koala Plan of Management
which took 4 years to produce, is specific to our region and supports
the Tweed LEP in conservation and recovery of our endangered Tweed
Coast Koala. To depreciate its value and deny its existence as not
endorsed by the State is an attempt to avoid its guidance and ignores
the fact that this Tweed Coast Comprehensive KPOM included the
participation by the State Govt in order to create it. The Department
of Planning should acknowledge this fact and not accept this attempt
at a "technicality" when the lives of our endangered Tweed Coast
Koalas are in the balance. Hypocrisy will be noted by the
community/public as the NSW Premier Gladys Berijeklian has publicy
acknowledged the Koalas fragile status (mid 2018 on national TV), Hon
Gabrielle Upton Minister for Environment has allocated two large
parcels of land (Pottsville & Sleepy Hollow 2018) to assist in the
Tweed Coast Koalas recovery, so the Dept of Planning must take this
into consideration when Holcim requests this modification for pure
increase in revenue. The three fold increase of truck movements in a
well-known core Koala Habitat location should be rejected.
11.The only reason there are not more submissions against this
modification is that the members of our community are largely unaware
of what is proposed and how to object to it. Most people in the
community are unaware of the development/modification process , how to
learn about issues in our area and how to object to them if necessary
. It is community groups that care about our Koalas and wildlife who
are forced to bring this information to the publics notice and educate
them.

As per attached

TO: The NSW Department of Planning and Environment
(Attention: Director - Resource Assessments)

SUBMISSION FROM: David Norris, Community Representative on Tweed Shire
Council Koala Management Committee and Dunloe Sands Community
Consultative Committee

ADDRESS: 28 Toshack Place, POTTSVILLE NSW 2489

PHONE: 02 6676 0615

MOBILE: 0423 267 555

EMAIL: [email protected]

DATE: 8 October 2018

[PLEASE NOTE: I do not want the Department to delete my personal
information before publication and I have not made any reportable
political donations in the previous two years.]

MODIFICATION REQUEST: Holcim Dunloe Sands Modification 2 to Project
Approval 06/-0030, Application No MP 06_0030 MOD 2, Proponent: Holcim
( Australia ) Pty Ltd, Location: Pottsville-Moobal Road, Pottsville.

DESCRIPTION OF PROPOSED MODIFICATION: The modification seeks to amend
consent conditions to allow an increase in the number of daily vehicle
movements in and out of the site, from 80 to 240 Monday to Friday and
40 to 120 on Saturdays.


I OBJECT to the above proposal for the following reasons:-



RISK OF VEHICLE STRIKE AND IMPEDIMENT TO CONNECTIVITY

The EA Table 6-1 Identification of environmental issues (page 15)
states: 'The proposed modification will not involve any construction
or demolition works, therefore there will be no impacts to flora and
fauna as a result of the proposed modification..... No additional
assessment or mitigation is required'.

I disagree with the statement above for the following reasons:-

Vehicles up to the size of a 19-metre truck and dog trailer operate
from the Holcim mine site. The proposal seeks to triple the allowable
vehicle movements to, from and at the site. The Ecological Assessment
recommends that all heavy vehicles access and egress the site to/from
Cudgera Creek Road.

The haul road intersects with two koala linkages identified in the
Tweed Coast Koala Habitat Study (TCKHS) 2011, one within the mine site
which connects with the Sleepy Hollow highway underpass, and one where
trucks enter/exit the site at Pottsville/Moobal Road. The haul road
also runs parallel and adjacent to the koala black spot on
Pottsville/Moobal Road, identified in TCKHS 2011, and intersects the
black spot at the entry to and exit from the mine site [refer attached
map haul route and koala linkage corridors].

Page 1 of 7
Recent koala food tree plantings along the southern section of and
parallel to the haul road have the potential to attract koalas,
increasing the potential risk of vehicle strike.

The Mine Environmental Management Plan states: 'To minimise impacts on
native fauna, in accordance with the Development Consent, trucks and
machinery are to be confined to defined haulage routes and operate
during daylight hours only (7am-5pm weekdays, 7am-12pm weekends) at a
maximum speed of 30km/hr'.

However, koalas often move on the ground during daylight hours
particularly during koala breeding season (July to February) and are
at high risk of vehicle strike. For example, the automatic koala
protection gate was installed at the entrance to the Black Rocks
sports field (adjacent to the mine site) as a result of koalas being
evidenced on the ground during daylight hours.

Another example is a koala sighted and photographed during daylight
hours on the footpath at the intersection of Coronation Avenue and
Berkley's Lane in the middle of the Pottsville business area.

Male koalas are very single minded when it comes to chasing a female
during breeding season which makes them very vulnerable to vehicle
strike. Females are known to risk injury in order to escape a male on
the chase, making them also vulnerable to vehicle strike.

Pottsville Wetlands has been identified as part of a north-south and
east-west regional fauna corridor in the Northern Rivers regional
Biodiversity Management Plan (DECCW 2010) with linkages north and
south with Cudgen, Wooyung and Billinudgel Nature Reserves and west to
Mooball National Park and Cudgera Creek Nature Reserve.

The mine site is located within the regional corridor and adjacent to
the Pottsville Wetland. Native fauna including koalas move through the
mine site for feeding and breeding purposes.

The noise and visual impact associated with a tripling of vehicle
movements (ie on average one movement every two and a half minutes
during operational times) has the potential to form a barrier to koala
movement and compromise the effectiveness of the east/west and
north/south koala linkage corridors that the haul road intersects and
parallels . Effective connectivity to koala populations west of the
Pacific highway and south of the mine site is critical to survival of
the Tweed Coast koala population which is listed as endangered.



SUPPORTING QUOTES FROM TWEED COAST KOALA HABITAT STUDY 2011

TCKHS 2011 identifies barriers to koala movement as a process
threatening the survival of the koala on the Tweed Coast. 'Threatening
processes' (page 11) states: 'Fragmentation of koala habitat such that
barriers to movement are created that isolate individuals and
populations, hence altering population dynamics, impeding gene flow
and the ability to maintain effective recruitment levels.'

'Road mortalities/koala blackspots' (page 49) states: 'Dr. Phillips
(2002) reported vehicle-strike as responsible for 34% of koala
mortality on the Tweed Coast. While this statistic has decreased to
19% in the intervening decade, this result is more likely to be
attributable to overall population decline than an increase in care
and vigilance of drivers.'

Page 2 of 7
'Mitigation of threatening processes' (page 66) states: 'There is a
need for evaluation of existing underpass options along the Pacific
Highway that offer greatest potential for safe passage of koalas so as
to achieving meaningful east-west connectivity, with particular
emphasis on the Sleepy Hollow area where ameliorative measures are
also required'.

TCKHS 2011 has identified the following regarding the Tweed Coast
Koala population viability:-

144 Koalas remain in the Tweed Coast study area. '170 is the minimum
viable population size for long-term survival' [Phillips, unpub.Data,
refer page 61]. An estimated 35 Koalas occupy the Pottsville Wetland.

'Regarding the central Koala Management area (between Bogangar and
Pottsville) there is a need to consider the localised extinction of
Koalas south of the Tweed River to be a foreseeable event within the
next 2 - 3 decades' [refer page 64].

Three disjunct sub-populations of Koalas exist in the central Koala
Management Area south of Tweed River between Bogangar and Pottsville
[refer page 5].

For viable Koala metapopulation to survive, Koala recovery and
management actions must be focused between Bogangar and Pottsville
[refer page 6]. The central Koala Management Area must be of the
highest importance [refer page 65].

'Population Viability Analysis carried out by Phillips et al. 2007 has
determined that as little as a 2-3% increase (ie 4 Koalas in the
entire Tweed Coast koala population) in the naturally-occurring
mortality rate (as a function of total population size) due to
incidental factors such as road mortality, dog attack or the stressors
associated with disturbance generally, is sufficient to precipitate
decline [refer page 63].

The Tweed Coast Comprehensive Koala Plan of Management identifies that
safe koala movement through the koala black spot area is crucial to
the survival of the Pottsville Wetland koala sub population. The
proposed tripling of allowable vehicle movements through this area has
the potential to cause a major risk of koala vehicle strike and a
major impediment to koala movement.



SUPPORTING QUOTES FROM TWEED COAST COMPREHENSIVE KOALA PLAN OF
MANAGEMENT (refer attached Map Activity and Linkage precincts)

'Dunloe Park KLP' (Koala Linkage Precinct) states (page 19): 'The
precinct includes critical connectivity measures across the Pacific
Highway, including the fauna overpass south of the Pottsville
interchange and a bridge crossing under the highway at Sleepy Hollow
Road....Management focus within this precinct is retention and
extension of habitat with a specific focus on creating viable movement
corridors that link the adjoining KAPs to highly significant habitat
west of the highway.'

'Koala Habitat Restoration' (page 48) states: 'Areas of Preferred
Koala Habitat vary in condition and currently provide insufficient
connectivity between koala sub-populations on the Tweed Coast and
between coastal and western populations.'




Page 3 of 7
'Reducing Koala Road Mortality' (page 51) states: 'The Habitat Study
recognised that the Pacific Highway limits movement of individuals and
genetic flow between the Tweed Coast koala population and those in the
west. A further seven stretches of road on the Tweed Coast were termed
"blackspots" that accounted for the majority of koala road kill. This
Plan identifies these sections of road along with other high risk
sections of road where koala road kill is likely to occur due to its
proximity to koala habitat as "koala roads". These areas include:
Pottsville Road (Pottsville, Sleepy Hollow)'....Koalas are killed on
these roads because they bisect existing home ranges or movement
corridors for dispersing animals, thus they also reflect the locations
that are most vital for maintaining connectivity across roads. The
ranging behaviour of koalas cannot be modified, thus it is the
approach to road design and the attitude to road use in high risk
areas that must adjust in order to reduce this threat [refer attached
Map Haul Route and Koala Linkage Corridors and Map Activity and
Linkage Precincts]



TWEED COAST COMPREHENSIVE KOALA PLAN OF MANAGEMENT (KPOM ) 3.5.2.2
KOALA LINKAGE PRECINCTS (refer Map Activity & Linkage precincts
attached)

A Koala Linkage Precinct (KLP) is a mapped area adjacent to one or
more KAPs that provide optimal opportunities for improved habitat
management and connectivity.



Dunloe Park Koala Linkage Precinct:

Dunloe Park KLP is approximately 428 ha, consisting of the lands
between the Pacific Highway in the west, Pottsville KAP to the north,
Black Rocks KAP to the east and non-precinct areas to the south.

The precinct includes critical connectivity measures across the
Pacific Highway, including the fauna overpass south of the Pottsville
interchange and a bridge crossing under the highway at Sleepy Hollow
Road.

Management focus within this precinct is retention and extension of
habitat with a specific focus on creating viable movement corridors
that link the adjoining KAPs to highly significant habitat west of the
highway.



TWEED COAST COMPREHENSIVE KOALA PLAN OF MANAGEMENT KOALA LINKAGE
PRECINCT MANAGEMENT OBJECTIVES

i) The following management objectives will be used to guide this Plan
in relation to the Koala Linkage Precincts.

a) To actively reduce threats to existing koalas and their habitat.

b) To increase the area and quality of Core Koala Habitat with a focus
on improving connectivity between existing koala populations and KAPs.


Page 4 of 7
c) To ensure that new developments within a KLP minimise impacts on
koalas, whether or not they are currently present on site, through the
retention and protection of Core Koala Habitat and the application of
rigorous development controls.

d) To ensure that any development affecting koalas or their habitat
within a KLP contributes positively to koala recovery within the KLP
through improved connectivity of koala habitat.

e) To ensure that planning for future development within a KLP
positively contributes to koala recovery within the KLP through
improved connectivity of koala habitat.
f) To encourage all stakeholders, including private landholders and
the community, to positively contribute to koala recovery within the
KLP.



EXTRACT FROM TWEED COAST COMPREHENSIVE KOALA PLAN OF MANAGEMENT

For Development Proposals within a Koala Linkage Precinct without
evidence of koala usage, connectivity for koalas must be enhanced by
the planting of Preferred Koala Food Trees or the creation of
additional Preferred Koala Habitat. Such areas shall:

a) be within the property (or adjacent properties in the same
ownership) to which the development is proposed but outside of the
Development Envelope(including any envisaged infrastructure,
easements, bush fire asset protection zones and the like),any land
used for offsetting under Section 5.9.3 (iii) or retained under
Section 5.9.3 (iv), and b) be optimally located to improve koala
habitat connectivity.

The mine site is not considered Minor Development under The Tweed
Koala Plan of Management. In the event that the proposal is approved
please check if there is a requirement to comply with the above
clause.

The proposal should be examined to the fullest extent in relation to
its effect on the environment, ensuring that any proposed action has
minimal adverse impacts on the threatened species which inhabit the
land within and adjoining the mine site.



INCONSISTENT MATTERS

There has been no consideration of the endangered status of the Tweed
Coast koala population.

The proposal contradicts a focus of the Dunloe Park Koala Linkage
Precinct, which is to improve connectivity to the underpass under the
highway at Sleepy Hollow Road. The proposal also contradicts the KPOM
koala linkage precinct objectives, particularly objectives (a) ( c)
(d) and (f).

I believe that the above adverse impacts of the proposed action within
and on land adjoining the subject site are inconsistent with the
findings of the EA, which concludes that the proposed action will not
have a significant impact on koalas.



Page 5 of 7
I believe that the adverse impacts of the proposal are inconsistent
with the recommendations of TCKHS: 'Sustainable planning for Koalas
should endeavour to minimise the potential for adverse impacts in
known Koala habitat by ensuring that adequate areas of suitable
habitat, and linkages to assist ongoing processes of recruitment and
dispersal, are maintained or restored.'

In submit that considering the issues raised in this submission, the
proposal does constitute a `radical transformation', and that
continued use of Section 75W to modify the project approved under Part
3A (known as Transitional Part 3A Projects) cannot be relied upon
because the proposed changes cannot be considered a `modification'.



Outstanding Environmental Planning and Assessment Act matters:

I believe that the adverse impacts of the proposal should it be
approved will significantly impede connectivity causing fragmentation
between areas of koala habitat and breeding locations. The increase in
vehicle movements would result in degradation of the corridor value of
the land within and adjoining the mine site.

I believe that the adverse impacts of a tripling of vehicle movements
are likely to disrupt the life cycle of the species (Pottsville
Wetland koalas) such that a viable local population of the species is
likely to be placed at risk of extinction.

I believe the proposed action is inconsistent with the objectives or
actions of the Recovery Plan for the Koala which was approved by the
Minister for Climate Change and the Environment in November, 2008.

I submit that the proposal poses unacceptable impacts on the
environment in that the proposal is likely to have a significant
impact on the viability of a koala linkage corridor identified in the
Tweed Coast Koala Habitat Study 2011 and within the Dunloe Park Koala
Linkage Precinct as mapped in the Tweed Coast Koala Plan of
Management.

I believe that the proposal poses unacceptable social impacts on the
amenity of neighbours.

If the proposal is approved, up to 240 vehicle movements a week day
day will be allowed until 1 January 2035, but there has been no
consideration of how the proposed increased vehicle movements will
interact with the cumulative effects of traffic associated with other
proposed future development in the area. This includes the proposed
Dunloe Park urban development adjacent to the mine site. This
development proposal is presently undergoing a master-planned
community process and, if approved, is expected to house 6000 people.

There has been no consideration of how the proposed increased vehicle
movements will interact with the traffic generated by the North Byron
Parklands Splendour in the Grass and Falls music festivals which use
Pottsville Moobal Road and the Pottsville Pacific Highway interchange
as a designated access route. Currently an estimated 35,000 people
attend the Splendour in the Grass event over a 5 day period.

Considering the ecological values, disruption to connectivity and
impacts on threatened fauna within and/or adjacent to the mine site as
detailed in this submission, I submit that the application for the
proposed action should be rejected.

Page 6 of 7
Outstanding Environmental Protection Biodiversity Conservation Act
matters

Regarding assessment under the EPBC Act, I believe that the
Environmental Assessment and Review of Environmental Factors are
incomplete because they do not recognise the federally-listed
vulnerable status of the koala, and that the mine site is located
within a quality habitat corridor linking the Pottsville Wetlands with
the Wooyung and Billinudgel Nature Reserves to the south and koala
habitat to the west . This recognition is not reflected in the
findings and recommendations of these documents.

There is no reference in the EA to the koala's federally-listed
vulnerable status. TCKHS 2011 Koalas Population Viability presents a
number of very alarming statistics regarding predicted localised
extinction of koalas and a viable population size which is well below
the minimum. I believe that the impacts on Pottsville Wetland koalas
will have very serious consequences for their survival and will
significantly impact on the viability of the koala population on the
Tweed Coast.

I therefore believe that the proposal warrants referral to the SEWPC
Minister for impact assessment and Commonwealth approval under the
EPBC Act.



CONCLUSION

I submit that the issues raised in my submission must be assessed in
accordance with the relevant provisions of the EP&A Act and EPBC Act.

Considering the matters referred to in this submission, I submit that
the precautionary principle should be adhered to and the application
should be rejected.

Please note:- the attached maps are modifications of maps copied from
the Tweed Coast Koala Habitat Study 2011 and the Tweed Coast
Comprehensive Koala Plan of Management.

Page 7 of 7

The traffic assessment in the report is flawed and grossly underestimates
the traffic impact.

TO: The NSW Department of Planning and Environment
(Attention: Director - Resource Assessments)

I am now sending this submission again as I am not sure that the
Department received it yesterday 8 October 2018.

SUBMISSION FROM: David Norris, Community Representative on Tweed Shire
Council Koala Management Committee and Dunloe Sands Community
Consultative Committee

ADDRESS: 28 Toshack Place, POTTSVILLE NSW 2489

PHONE: 02 6676 0615

MOBILE: 0423 267 555

EMAIL: [email protected]

DATE: 8 October 2018

[PLEASE NOTE: I do not want the Department to delete my personal
information before publication and I have not made any reportable
political donations in the previous two years.]

MODIFICATION REQUEST: Holcim Dunloe Sands Modification 2 to Project
Approval 06/-0030, Application No MP 06_0030 MOD 2, Proponent: Holcim
( Australia ) Pty Ltd, Location: Pottsville-Moobal Road, Pottsville.

DESCRIPTION OF PROPOSED MODIFICATION: The modification seeks to amend
consent conditions to allow an increase in the number of daily vehicle
movements in and out of the site, from 80 to 240 Monday to Friday and
40 to 120 on Saturdays.


I OBJECT to the above proposal for the following reasons:-



RISK OF VEHICLE STRIKE AND IMPEDIMENT TO CONNECTIVITY

The EA Table 6-1 Identification of environmental issues (page 15)
states: 'The proposed modification will not involve any construction
or demolition works, therefore there will be no impacts to flora and
fauna as a result of the proposed modification..... No additional
assessment or mitigation is required'.

I disagree with the statement above for the following reasons:-

Vehicles up to the size of a 19-metre truck and dog trailer operate
from the Holcim mine site. The proposal seeks to triple the allowable
vehicle movements to, from and at the site. The Ecological Assessment
recommends that all heavy vehicles access and egress the site to/from
Cudgera Creek Road.

The haul road intersects with two koala linkages identified in the
Tweed Coast Koala Habitat Study (TCKHS) 2011, one within the mine site
which connects with the Sleepy Hollow highway underpass, and one where
trucks enter/exit the site at Pottsville/Moobal Road. The haul road
also runs parallel and adjacent to the koala black spot on
Pottsville/Moobal Road, identified in TCKHS 2011, and intersects the
black spot at the entry to and exit from the mine site [refer attached
map haul route and koala linkage corridors].

Page 1 of 7
Recent koala food tree plantings along the southern section of and
parallel to the haul road have the potential to attract koalas,
increasing the potential risk of vehicle strike.

The Mine Environmental Management Plan states: 'To minimise impacts on
native fauna, in accordance with the Development Consent, trucks and
machinery are to be confined to defined haulage routes and operate
during daylight hours only (7am-5pm weekdays, 7am-12pm weekends) at a
maximum speed of 30km/hr'.

However, koalas often move on the ground during daylight hours
particularly during koala breeding season (July to February) and are
at high risk of vehicle strike. For example, the automatic koala
protection gate was installed at the entrance to the Black Rocks
sports field (adjacent to the mine site) as a result of koalas being
evidenced on the ground during daylight hours.

Another example is a koala sighted and photographed during daylight
hours on the footpath at the intersection of Coronation Avenue and
Berkley's Lane in the middle of the Pottsville business area.

Male koalas are very single minded when it comes to chasing a female
during breeding season which makes them very vulnerable to vehicle
strike. Females are known to risk injury in order to escape a male on
the chase, making them also vulnerable to vehicle strike.

Pottsville Wetlands has been identified as part of a north-south and
east-west regional fauna corridor in the Northern Rivers regional
Biodiversity Management Plan (DECCW 2010) with linkages north and
south with Cudgen, Wooyung and Billinudgel Nature Reserves and west to
Mooball National Park and Cudgera Creek Nature Reserve.

The mine site is located within the regional corridor and adjacent to
the Pottsville Wetland. Native fauna including koalas move through the
mine site for feeding and breeding purposes.

The noise and visual impact associated with a tripling of vehicle
movements (ie on average one movement every two and a half minutes
during operational times) has the potential to form a barrier to koala
movement and compromise the effectiveness of the east/west and
north/south koala linkage corridors that the haul road intersects and
parallels . Effective connectivity to koala populations west of the
Pacific highway and south of the mine site is critical to survival of
the Tweed Coast koala population which is listed as endangered.



SUPPORTING QUOTES FROM TWEED COAST KOALA HABITAT STUDY 2011

TCKHS 2011 identifies barriers to koala movement as a process
threatening the survival of the koala on the Tweed Coast. 'Threatening
processes' (page 11) states: 'Fragmentation of koala habitat such that
barriers to movement are created that isolate individuals and
populations, hence altering population dynamics, impeding gene flow
and the ability to maintain effective recruitment levels.'

'Road mortalities/koala blackspots' (page 49) states: 'Dr. Phillips
(2002) reported vehicle-strike as responsible for 34% of koala
mortality on the Tweed Coast. While this statistic has decreased to
19% in the intervening decade, this result is more likely to be
attributable to overall population decline than an increase in care
and vigilance of drivers.'

Page 2 of 7
'Mitigation of threatening processes' (page 66) states: 'There is a
need for evaluation of existing underpass options along the Pacific
Highway that offer greatest potential for safe passage of koalas so as
to achieving meaningful east-west connectivity, with particular
emphasis on the Sleepy Hollow area where ameliorative measures are
also required'.

TCKHS 2011 has identified the following regarding the Tweed Coast
Koala population viability:-

144 Koalas remain in the Tweed Coast study area. '170 is the minimum
viable population size for long-term survival' [Phillips, unpub.Data,
refer page 61]. An estimated 35 Koalas occupy the Pottsville Wetland.

'Regarding the central Koala Management area (between Bogangar and
Pottsville) there is a need to consider the localised extinction of
Koalas south of the Tweed River to be a foreseeable event within the
next 2 - 3 decades' [refer page 64].

Three disjunct sub-populations of Koalas exist in the central Koala
Management Area south of Tweed River between Bogangar and Pottsville
[refer page 5].

For viable Koala metapopulation to survive, Koala recovery and
management actions must be focused between Bogangar and Pottsville
[refer page 6]. The central Koala Management Area must be of the
highest importance [refer page 65].

'Population Viability Analysis carried out by Phillips et al. 2007 has
determined that as little as a 2-3% increase (ie 4 Koalas in the
entire Tweed Coast koala population) in the naturally-occurring
mortality rate (as a function of total population size) due to
incidental factors such as road mortality, dog attack or the stressors
associated with disturbance generally, is sufficient to precipitate
decline [refer page 63].

The Tweed Coast Comprehensive Koala Plan of Management identifies that
safe koala movement through the koala black spot area is crucial to
the survival of the Pottsville Wetland koala sub population. The
proposed tripling of allowable vehicle movements through this area has
the potential to cause a major risk of koala vehicle strike and a
major impediment to koala movement.



SUPPORTING QUOTES FROM TWEED COAST COMPREHENSIVE KOALA PLAN OF
MANAGEMENT (refer attached Map Activity and Linkage precincts)

'Dunloe Park KLP' (Koala Linkage Precinct) states (page 19): 'The
precinct includes critical connectivity measures across the Pacific
Highway, including the fauna overpass south of the Pottsville
interchange and a bridge crossing under the highway at Sleepy Hollow
Road....Management focus within this precinct is retention and
extension of habitat with a specific focus on creating viable movement
corridors that link the adjoining KAPs to highly significant habitat
west of the highway.'

'Koala Habitat Restoration' (page 48) states: 'Areas of Preferred
Koala Habitat vary in condition and currently provide insufficient
connectivity between koala sub-populations on the Tweed Coast and
between coastal and western populations.'




Page 3 of 7
'Reducing Koala Road Mortality' (page 51) states: 'The Habitat Study
recognised that the Pacific Highway limits movement of individuals and
genetic flow between the Tweed Coast koala population and those in the
west. A further seven stretches of road on the Tweed Coast were termed
"blackspots" that accounted for the majority of koala road kill. This
Plan identifies these sections of road along with other high risk
sections of road where koala road kill is likely to occur due to its
proximity to koala habitat as "koala roads". These areas include:
Pottsville Road (Pottsville, Sleepy Hollow)'....Koalas are killed on
these roads because they bisect existing home ranges or movement
corridors for dispersing animals, thus they also reflect the locations
that are most vital for maintaining connectivity across roads. The
ranging behaviour of koalas cannot be modified, thus it is the
approach to road design and the attitude to road use in high risk
areas that must adjust in order to reduce this threat [refer attached
Map Haul Route and Koala Linkage Corridors and Map Activity and
Linkage Precincts]



TWEED COAST COMPREHENSIVE KOALA PLAN OF MANAGEMENT (KPOM ) 3.5.2.2
KOALA LINKAGE PRECINCTS (refer Map Activity & Linkage precincts
attached)

A Koala Linkage Precinct (KLP) is a mapped area adjacent to one or
more KAPs that provide optimal opportunities for improved habitat
management and connectivity.



Dunloe Park Koala Linkage Precinct:

Dunloe Park KLP is approximately 428 ha, consisting of the lands
between the Pacific Highway in the west, Pottsville KAP to the north,
Black Rocks KAP to the east and non-precinct areas to the south.

The precinct includes critical connectivity measures across the
Pacific Highway, including the fauna overpass south of the Pottsville
interchange and a bridge crossing under the highway at Sleepy Hollow
Road.

Management focus within this precinct is retention and extension of
habitat with a specific focus on creating viable movement corridors
that link the adjoining KAPs to highly significant habitat west of the
highway.



TWEED COAST COMPREHENSIVE KOALA PLAN OF MANAGEMENT KOALA LINKAGE
PRECINCT MANAGEMENT OBJECTIVES

i) The following management objectives will be used to guide this Plan
in relation to the Koala Linkage Precincts.

a) To actively reduce threats to existing koalas and their habitat.

b) To increase the area and quality of Core Koala Habitat with a focus
on improving connectivity between existing koala populations and KAPs.


Page 4 of 7
c) To ensure that new developments within a KLP minimise impacts on
koalas, whether or not they are currently present on site, through the
retention and protection of Core Koala Habitat and the application of
rigorous development controls.

d) To ensure that any development affecting koalas or their habitat
within a KLP contributes positively to koala recovery within the KLP
through improved connectivity of koala habitat.

e) To ensure that planning for future development within a KLP
positively contributes to koala recovery within the KLP through
improved connectivity of koala habitat.
f) To encourage all stakeholders, including private landholders and
the community, to positively contribute to koala recovery within the
KLP.



EXTRACT FROM TWEED COAST COMPREHENSIVE KOALA PLAN OF MANAGEMENT

For Development Proposals within a Koala Linkage Precinct without
evidence of koala usage, connectivity for koalas must be enhanced by
the planting of Preferred Koala Food Trees or the creation of
additional Preferred Koala Habitat. Such areas shall:

a) be within the property (or adjacent properties in the same
ownership) to which the development is proposed but outside of the
Development Envelope(including any envisaged infrastructure,
easements, bush fire asset protection zones and the like),any land
used for offsetting under Section 5.9.3 (iii) or retained under
Section 5.9.3 (iv), and b) be optimally located to improve koala
habitat connectivity.

The mine site is not considered Minor Development under The Tweed
Koala Plan of Management. In the event that the proposal is approved
please check if there is a requirement to comply with the above
clause.

The proposal should be examined to the fullest extent in relation to
its effect on the environment, ensuring that any proposed action has
minimal adverse impacts on the threatened species which inhabit the
land within and adjoining the mine site.



INCONSISTENT MATTERS

There has been no consideration of the endangered status of the Tweed
Coast koala population.

The proposal contradicts a focus of the Dunloe Park Koala Linkage
Precinct, which is to improve connectivity to the underpass under the
highway at Sleepy Hollow Road. The proposal also contradicts the KPOM
koala linkage precinct objectives, particularly objectives (a) ( c)
(d) and (f).

I believe that the above adverse impacts of the proposed action within
and on land adjoining the subject site are inconsistent with the
findings of the EA, which concludes that the proposed action will not
have a significant impact on koalas.



Page 5 of 7
I believe that the adverse impacts of the proposal are inconsistent
with the recommendations of TCKHS: 'Sustainable planning for Koalas
should endeavour to minimise the potential for adverse impacts in
known Koala habitat by ensuring that adequate areas of suitable
habitat, and linkages to assist ongoing processes of recruitment and
dispersal, are maintained or restored.'

In submit that considering the issues raised in this submission, the
proposal does constitute a `radical transformation', and that
continued use of Section 75W to modify the project approved under Part
3A (known as Transitional Part 3A Projects) cannot be relied upon
because the proposed changes cannot be considered a `modification'.



Outstanding Environmental Planning and Assessment Act matters:

I believe that the adverse impacts of the proposal should it be
approved will significantly impede connectivity causing fragmentation
between areas of koala habitat and breeding locations. The increase in
vehicle movements would result in degradation of the corridor value of
the land within and adjoining the mine site.

I believe that the adverse impacts of a tripling of vehicle movements
are likely to disrupt the life cycle of the species (Pottsville
Wetland koalas) such that a viable local population of the species is
likely to be placed at risk of extinction.

I believe the proposed action is inconsistent with the objectives or
actions of the Recovery Plan for the Koala which was approved by the
Minister for Climate Change and the Environment in November, 2008.

I submit that the proposal poses unacceptable impacts on the
environment in that the proposal is likely to have a significant
impact on the viability of a koala linkage corridor identified in the
Tweed Coast Koala Habitat Study 2011 and within the Dunloe Park Koala
Linkage Precinct as mapped in the Tweed Coast Koala Plan of
Management.

I believe that the proposal poses unacceptable social impacts on the
amenity of neighbours.

If the proposal is approved, up to 240 vehicle movements a week day
day will be allowed until 1 January 2035, but there has been no
consideration of how the proposed increased vehicle movements will
interact with the cumulative effects of traffic associated with other
proposed future development in the area. This includes the proposed
Dunloe Park urban development adjacent to the mine site. This
development proposal is presently undergoing a master-planned
community process and, if approved, is expected to house 6000 people.

There has been no consideration of how the proposed increased vehicle
movements will interact with the traffic generated by the North Byron
Parklands Splendour in the Grass and Falls music festivals which use
Pottsville Moobal Road and the Pottsville Pacific Highway interchange
as a designated access route. Currently an estimated 35,000 people
attend the Splendour in the Grass event over a 5 day period.

Considering the ecological values, disruption to connectivity and
impacts on threatened fauna within and/or adjacent to the mine site as
detailed in this submission, I submit that the application for the
proposed action should be rejected.

Page 6 of 7
Outstanding Environmental Protection Biodiversity Conservation Act
matters

Regarding assessment under the EPBC Act, I believe that the
Environmental Assessment and Review of Environmental Factors are
incomplete because they do not recognise the federally-listed
vulnerable status of the koala, and that the mine site is located
within a quality habitat corridor linking the Pottsville Wetlands with
the Wooyung and Billinudgel Nature Reserves to the south and koala
habitat to the west . This recognition is not reflected in the
findings and recommendations of these documents.

There is no reference in the EA to the koala's federally-listed
vulnerable status. TCKHS 2011 Koalas Population Viability presents a
number of very alarming statistics regarding predicted localised
extinction of koalas and a viable population size which is well below
the minimum. I believe that the impacts on Pottsville Wetland koalas
will have very serious consequences for their survival and will
significantly impact on the viability of the koala population on the
Tweed Coast.

I therefore believe that the proposal warrants referral to the SEWPC
Minister for impact assessment and Commonwealth approval under the
EPBC Act.



CONCLUSION

I submit that the issues raised in my submission must be assessed in
accordance with the relevant provisions of the EP&A Act and EPBC Act.

Considering the matters referred to in this submission, I submit that
the precautionary principle should be adhered to and the application
should be rejected.


Note:- The attached maps have modified versions of maps copied from
the Tweed Coast Koala Habitat Study 2011 and the Tweed Coast
Comprehensive Koala Plan of Management.
Page 7 of 7