As per attached

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

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.

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.

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.

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.