Northern Coal Services Modification 5

I object to the project proposal. Detailed grounds for objection will be supplied. The key aspects of this objection include, but are not limited, to the following points:-

1. Misinformation: any ordinary person interested in the details of this project are likely to be confused and misinformed about its extent and nature as a direct consequence of multiple different names, descriptions, project titles used by the proponent since their submission of the original development application. As an example, the modification application document submitted by the proponent uses the title "Northern Coal Services Modification 5". The Modification report, however, uses a different project title, "Centennial: Northern Coal Logistics Modification Report for Modification 5 to SSD-5145 (MOD5)".

2. State and Federal Threatened Species Legislation: the proposal is vague, inaccurate and unclear about a range of ongoing issues regarding listed threatened species across the entire project boundary. Further intensive investigation and research of these issues is essential.

3. Community Consultation: there are longstanding and major issues regarding the integrity, extent, and validity of the proponent's consultation with the community. Nothing short of a major investigation of the operations of a number of so-called "Community Consultative Committees" is long overdue before the proponent should be permitted any further activity across the company's various convoluted mining leases in the area. There is clear evidence of failure to effectively engage with public concerns regarding the proponent's operations in the area over more than the last 16 years.

4.Deliberate Staging of Development Applications: the history of this proposal, and other instrumentally associated projects, have never been adequately or properly assessed under various laws as a direct consequence of incremental staging. For example, in 2009, in relation to the original development application, a major haul road construction was approved based on yet another earlier, stale development application from before 1999 which ought to have been subject to detailed assessment under the provisions of the Environmental Protection and Biodiversity Act 1999. Proper assessment never occurred. The proponent's activities need to be holistically assessed under all relevant state and federal legislation before this modification is assessed.

5. Confidential: additional issues warrant further sustained investigation before any approvals are given by Government.

On behalf of Five Bays Sustainable Neighbourhood Group, I object to this modification in its current form. My concerns relate to the "Beneficial use of a waste product as an engineering fill material."

Specifically, I object to the use of Rhondda and Wakefield Roads (LMCC roads) in Option 1, as outlined in section 7.1.1.2 Route Selection, page 44.

Reasons for objection:
1. Inefficient route: This option is circuitous, covering approximately 8.6km and requiring a right-hand turn onto Palmers Road.

2. Safety concerns: The intersection of Wakefield Road and Palmers/Cessnock Road poses safety risks, especially given its proximity to M1 exit points.

3. Population growth: Teralba's growing population, in line with State Government Planning, relies on this route to access the M1.

4. Conflicting developments:
a. The Black Rock Motor Resort, adjacent to the private haul road, will increase tourist traffic on Wakefield and Rhondda Roads [1].
b. Concrush's modification may further impact Wakefield Road traffic [2].

5. Better alternatives:
a. Option 2 is shorter and safer, using approximately 6.3km of public road.

b. An unexplored route utilising the private haul road network could be even more efficient [3]:
i. Exit private haul road onto Awaba Road.
ii. Turn left onto Cessnock Road, continuing to Palmers Road and M1 interchange.
iii. This route uses only 4.8km of public road.
iv. Awaba/Cessnock/Palmers Road is a gazetted State Road.

In conclusion, I urge consideration of these alternative routes to address safety concerns and minimise disruption to local traffic.

Yours sincerely,
Mark Howells - Secretary & Treasurer
Five Bays Sustainable Neighbourhood Group

Citations:
[1] https://www.lakemac.com.au/News-articles/Black-Rock-project-puts-city-in-pole-position-for-jobs-tourism
[2] https://www.planningportal.nsw.gov.au/major-projects/projects/modification-1-development-layout-and-annual-limits
[3] https://www.transport.nsw.gov.au/system/files/media/documents/2023/classified-roads-schedule.pdf

I fully support Centennial Northern Coal Services Pty Limited proposed modification of the development consent for the Northern Coal Services Project located in Lake Macquarie, New South Wales. The proposed modification has been well considered, aligning the current development consent conditions with the biodiversity offset strategy and conservation bond, providing an opportunity for beneficial use of washery reject material, whilst avoiding and minimising adverse biophysical, social and economic
impacts.

Please find my WORD Document submission;
Map of proposed option 6 as a jpeg;
Photos beginning with 20241029 the intersection of Wakefield/Palmers/Cessnock Road (3);
Photos of evidence for option 6.
Thank you.

Rhondda Road is already unsafe and carries too much heavy traffic for the steep and winding nature of the road. There is a significant crash history on Rhondda Road. It is unacceptable to send an additional 250,000 tonnes of material per year along Rhondda Road. It is an issue of road safety aswell as noise and air quality impact to Teralba residents.

I support the reuse of waste materials for beneficial use - this supports the circular economy and aligns with sustainable development. I support the proposal to use back haulage for materials transport - this reduces green house gas emissions and reduces traffic impacts.

I'm in favour of the modification.

Reusing a waste product is the responsible thing to do from an environmental and economic point of view. There is absolutely no reason this project should not go ahead.

The reuse of coarse coal reject is a win-win scenario for all. This proposal prevents usable materials being discarded in onsite landfill, whilst offsetting the requirement for comparable materials to be mined or excavated elsewhere. It provides the company with an additional revenue stream and creates another source of fill material in the market.