MOD 2 - Adjustment to Operational Boundary and Building Height

Submission for SSD-5066-Mod-2 and SSD-7709-Mod-1 Modification Applications - Objection

Thank you for the opportunity to participate in this planning process covering modifications to existing Concept and Stage consents for Moorebank Intermodal Precinct West. (MPW, and note: MPE for original Corrigan development partially in operation to MPW's east).

As for its final Determination we request that the planning authority withhold its full evaluation and findings until the current Class 1 Merits Appeal on the latest MPW Stage 2 Determination is completed.

From the outset it is important to acknowledge that the subject MPW land area of 220 hectares:

++ stands today empty of structure but with stands of cumberland plain woodland across the site
++ stands today as a large dirt/dust bowl with over $1.5 billion of tax-payer funds directly expended or loaned or lost by way of foregone revenues to bring it to such state.
++ stands today under the control of Qube/SIMTA with them on-selling the warehouse operations destined for MPW and MPE, valued at 80% of the sale figure of $2.6 billion.
++ comprises the bulk of planned "Warehouse Estate" lands, use of which is being sold for private profit at multiples of the land rent being paid, net of the aforementioned $1.5 billion tax-payer funding to date to bring the lands to current planning approvals.
++ has its origins in Labor's historical hatred of Chris Corrigan with the Rudd/Gillard/Rudd Labor Government using this subject development to block Corrigan's MPE interests "across the road" for over 4 years by withholding consent for the rail access line.
++ was put in control of Corrigan/Qube in 2014, based on negotiation through the hapless Moorebank Intermodal Company Limited (MICL).
++ is now primarily for use as a "Warehouse Estate" displacing the original freight intermodal operations that were Concept approved with "associated warehousing", to see this land use generate more traffic than originally planned.
++ has no "open access" assurance placed on its use in the MICL negotiations with Qube/SIMTA. As such commercial operations on public lands are under full control of the Corrigan/Qube interests.
++ was kept separate from the original Corrigan development (MPE) in the planning process as Corrigan MPE interests had already attained Concept Approval for its development. It seems they saw risk in the advancement of MPW approvals given the land form, its proximity to housing, its environmental sensitivity and its far higher traffic generation.
++ is due to be largely raised in height by 2 to 3 metres to manage storm water and flood consequences, with trucked in 1,600,000 m3 of earth fill
++ has its centre located 700 metres from established residential housing on higher lands, with the pleasant Georges River adjacent and in between established residential neighbourhoods.

Paragraphs of further fact are available to be written of each of the above acknowledgment points. And those facts would further highlight the perversity of corrupted processes that have seen these projects advance. And the question is; are they ongoing?

One sad and consequential fact is that there has never been an objective evaluation of the suitability of the site for its proposed development and use.
This is due to the fact, explained below, that the MPE and MPW sites have been aligned for or against the interests of a single citizen and his corporate entity(s).

This fact is the historical division of Mr. Chris Corrigan as hero and villain along the major political divide at work in Australia at all levels of government. There is his influence to lawfully advance the idea of Moorebank as a freight intermodal, via Liberal National Party election policy in 2004. There is his presence to stir up the local Labor tribal animosity near Moorebank at that time. With that agitation advancing to a NSW Planning Minister's office to see a Ministerial appointed body of business, industry, union and government appointees gives collective approval for MPW to emerge as a Report Recommendation in 2005 to become an Albanese infrastructure project from 2007.

That flow of activism saw the Labor promoted MPW used as a weapon to frustrate the advancement of MPE for almost four years. This was done via the Commonwealth withholding Land Owner Consent for MPE to connect to the freight rail link lines. This was reversed months after the 2013 election win by the LNP. Volumes of FOI documents exhibit prominent business and industry leaders making representations to Labor Ministers / Public Servants, as well as to Prime Minister Gillard, to see her bat them away to an underling.

The Corrigan interests then set about taking full advantage, as a hard-done-by corporate moral right it seems, of maximizing the benefits of the generous outcome granted to them in MPW. Indeed, the Qube Corporate Key Management team was rewarded with $1.5 million of bonuses in delivering the product.

The upcoming Class 1 Merit Appeal in the NSW Land & Environment Court against MPW's Stage 2 approval will highlight the deficiencies of Moorebank as a suitable site for such a development with its traffic generation and worsening of existing bad air quality. There are other deficiencies, but these two are observable facts.
Moorebank, in East Liverpool, is river-bound. It lays in a low river basin where bad air is observable. These facts are empirical , they can be seen, and they are measured.

The origins of Mr. Corrigan's interests in Moorebank was reported as observing these Commonwealth lands from the comfort of his recreational helicopter. He failed to observe the fact that East Liverpool is river bound on three sides, it is bridge reliant, and flood prone. He failed to observe that to its immediate south is the historic inalienable Liverpool Military Area which is aligned to the east side of the Georges River for over 25 kilometres. There are no other roads servicing the whole south west suburban and industrial region. The M5 Motorway is it. It travels due west from the Kingsford Smith Airport, and turns left at Moorebank/Casula to feed the burgeoning far south west of Sydney.
East Liverpool is a regional traffic corridor that carries traffic counts that match the Sydney Harbour Bridge and Tunnel. It is already congested. Any new road works will not ameliorate the congestion due to the need for heavy trucks to merge into congested but flowing regional traffic as slow moving vehicles. MPE vehicles are already worsening the congestion in this recognised Traffic Black Spot.

The East Liverpool Progress Association recognises the need for infrastructure to service both public and private industrial requirement. It acknowledges that the public interest requires decisions by Government that affect citizens where they live in marginal locations. Such decisions would need to be based on sound and fair financial analysis. Such analysis needs to be true and open to public scrutiny. In the case of the Moorebank Intermodal, all of those points have failed. There is no published Business Case. It is a fact that the $1.5 billion of tax payer funded costs did not feed into the final published financial analysis. A false figure has been used by the successive governments to justify dumping a 24 x 7 diesel emitting, noise emitting, light emitting industrial operation within 600 metres of established residential housing.


These latest Applications- SSD-5066-Mod-2 and SSD-7709-Mod-1 - continues the aforementioned maximization of benefit by the Applicant. Their request represents the worst of corporate values; that enough has to be more and more.

We strongly object to the application, and condemn the behaviour of the applicant and all involved, be it active or in their silence, with the advancement of the Moorebank Intermodal as a project in the public interest. As represented herein its origins were in error by Mr. Corrigan that could have been easily argued in an open forum. Its continuance has been worse than error, to the point of perversion where other agendas were played out across the structures driven by elites in politics, business and the people they employ with fear and plenty of favour. It stands as a sad and costly monument of broken public trust.

I am writing to address my concerns and that of my family for the Moorebank Intermodal Proposal. My husband has lived in the local area for 37 years and myself for 8 years, so we really love the suburb of Wattle Grove and are very concerned and upset with decision to build an Intermodal extremely close to our home and suburb. We have two young children who we hoped would be growing up with a very similiar childhood to what we both experienced. A friendly, family neighbourhood which is peaceful, clean and surrounded by happy neighbours who are supportive and long term residents.

An Intermodal in the U.S. at Centerpoint Intermodal Illnois Elwood is already up and running and now the community is suffering the effects from it. Please consider the definition of Urban vunerability: those of low-income residents of cities in developing countries. Exposure to environmental risk and hazard as a result of physical process creating these hazard (for example building, construction, urban planning, infrastructure provision or transportion), and human.

According to the Intermodal website by 2040..... 11,000 containers a day that need to travel by road coming to and more Moorebank. 5000 out of the Port Botany is a problem now! Why would 11,000 a day coming out of an Intermodal in the middle of built up suburb and the M5 and M7 that is already congested be more viable option?
You say air quality will be better due to LPG equipment instead of diesel. Also using road rather than rail, but still over the next 20 years it will increase to 11,000 trucks with diesel emissions with be using the terminal every single day/night by road polluting Wattle Grove, Casula and surrounding areas.

We already have contaminated ground water in Wattle Grove due to the Holsworthy Army Barracks use of fire fighting foam.

As railroads are moving Intermodal operations closer to their end markets, those end markets are fighting back against truck traffic they say tests the limits of local infrastructure, is dangerous to motorists and pedestrians, produces harmful noise and air pollution, and rapidly depreciates property values.

The new proposal modification for Dangerous Goods in this location is absolutely absurd to put all the surrounding suburbs and residents in danger. WIth the recent Ammonia Nitrate explosion in Beirut, Lebanon being close to residents and workplaces and the tragic number of deaths due to this accident, should be at the forefront in the Environment and Planning proposal, as the transport and storage of these dangerous goods is beyond deplorable and an large scale accident is foreseeable.
We recently have had two large factory fires in close proxity to the Intermodal and Wattle Grove. One on the 9th July, 2020 which required an 8th Alarm Response from NSW Fire and Rescue and surrounding ponds and stormwater drains were on fire due to a petroleum based fuel. Another large factory fire in Wattle Grove last year required two weeks to fully extinguish and the lavender oil emissions remained for months. If the Intermodal is to now store Dangerous Goods on site and already two occurences in recent times within close promixity to these proposed Dangerous good storage units, it will be a high risk to nearby homes and surrounding suburbs.

What level of protection can your assure will the dangerous goods have they are transported and protection surrounding the storage unit, as this should receive the same level of attention as the Nuclear Reactor at Lucas Heights . On the 14th April 2018 a bush fire burnt through 3,800 hectares from Casula Railway to West Menai in which the Holsworthy MIlitary Base and part of the Intermodal construction was burnt and homes in Wattle Grove came under attack for days. With storing Dangerous Goods in an area that can not have regular backburning due to the risk of ammunition exploding in the Military Base, how do you propose to protect the Intermodal, because when a fire of that ferocity and large scale required 500 Firefighters and 100 Fire Trucks and 15 Aircraft just for the Military Base, Nuclear Reactor and local homes alone?

Increasing the operational noise criteria has already been objected to in previous submission from local residents and that has not changed, how can this be allowed in peaceful suburb that we love living in! It will drive the residents out and house prices down and should never be approved, for the health and safety of the local residents. It is deplorable that the site will be operational 24 hours 7 days a week without adding to it an increase in the noise levels.

The height increase proposal of the Intermodal with it being 45 metres in height will look like an abominable fortress, the same height as a skyscraper and as its in the helicopter flight path it will need to have safety measures and lit up so as not cause any air crashes.

PLEASE DO NOT destroy out peaceful, family friendly neighbourhood with adding a freight train, 24/7 noise and lighting, heavy traffic,environmental impacts for our families, potential Georges River water contamination, extremely high walls and most importantly Dangerous goods!! We deserve to be heard and our wishes respected as this will have a huge impact on our community which houses a lot of Defence families who keep our country safe and deserve the same respect in return!

See attached PDF
Significantly object !

Please refer to my attachment (200824 Submission in relation to SSD-5066-Mod-2.pdf)

Thank you for making this platform available for comments.
Would prefer not to use this platform as it stops many elderly and new immigrants from making their submissions.
My objections relate to the height of the warehouses being increased in size from 21m by 214% to approximately 45m. The construction of additional rail sidings which have not been addressed in the N&V report nor compared to the original N&V report for MPE/MPW.


Section 02 EXISTING MASTERPLANS
means of adjustment to the internal Moorebank Precinct West (MPW) Boundary and access roads closer to the residents of Glenfield and Casula, including the construction of additional railway siding crossover points which are by nature inherently noisy as it a metal wheel crossing from one rail, over an air gap onto a second rail and then onto the final rail.
BUT that’s not the end of it.
This wills also the case for the second wheel. So that’s 6 metallic clangs for one set of wheels... What will be the noise from and engine and 20 TEUs. Assuming 20 carriages with four sets of wheels on each that’s 80 sets of wheels x 6 crossings clangs excluding the engines which could easily be 20 or more. 420 plus additional bangs for every train entering this new siding, and that’s only going into the siding, it will be the same going out. These where not taken into account during the original approval process so the background noise findings compared to the operational noise estimates for MPW and MPE have now been altered. How much noise will be generated by additional trains entering these additional crossings has not been defined except to say they are negligible.
• Amendment to the maximum building height established across selected portions of the Subject Site from approximately 21m up to and including 45m. This will blot out the horizon for many residents on eastern side of Casula looking down into the proposed site. No longer will they be looking down onto it but will be looking up onto the sides of a mammoth building
Poor quality of page 19 drawings Pixilation when zoomed. Is this to prevent astute investigations and prevent constructive comments?
Basin 3 is removed and it is difficult to determine what the old plan is against the new plans for Woolworths. The noise abatement walls seem to be removed. Additional Railway crossover points will create additional noise for the residents of Casula and Glenfield.

Proposed Modifications to SSD 7709
• Amendment to the maximum building height established across selected portions of the Subject Site from approximately 21m up to and including 45m
Section 3 Land Elevation Study page 22 map shows that the residential receivers are higher than the proposed site and there is a substantial chance of increased operational noise; see report information below with rebuttal comments
”The following factors provide some physical absorption capacity for the proposal and reduce the visibility of the site:
• Presence of surrounding industrial lands and potential future warehouses ( How do potential future fit into physical absorbing IF they are not constructed as per this study’s plans?)
• Dense vegetation with mature trees along Georges River corridor (Dense and mature trees have been removed to construct access road and will continue to be removed where required by future DAs. Sound Mitigation walls have been removed from planning)
• Compact configuration of residential areas with limited open views and publicly accessible areas facing the proposed site (The entire hilly range from Casula to Glenfield to the west of the Georges River looks down into the site and nothing can limit the open views so how can any of this provide some physical absorption)
• Landform west of the proposed site with a significant ridgeline which restricts the visual exposure of the proposal to views toward west (Dense and mature trees have been removed during land clearing for access road and the residential site to the west allows Casula and Glenfield to have full visual impact of the site. There are no restricted visual limits The Low Density Residential areas nearby Carroll Park are being assessed for Medium and High density residential
Houses along Buckland Road Casula have been assessed as having no direct view to the proposal. My home is in Buckland and I can see the ground works---how much more will I be impacted by the 45metre building moving closer to the Georges river.
View Point 4 page 34 it is the opinion of the report that the Magnitude is Moderate. Ask any of the residents it would be rated Very High as this building as can be seen high above existing tree canopies. There are already complaints about the one crane and its bright colours standing above the horizon and tree canopies, with a second to be installed. These will be blotted out of site by the 45m hibay warehouse. The Visual IMPACT is HIGH.
Compare existing to proposed skyline pictures as provided by report on page 45. These residents have homes which have seen beautiful views, some for over 50years….They have rights don’t they.
Viewpoint 6 page 38 Report describes Casula low impact as LOW from one point along the road and Magnitude as Negligible. A few hundred metres away is Canberra Ave with hundreds of residents on the eastern side of Canberra Ave which will have A VERY HIGH MAGNITUDE and VERY HIGH IMPACT. This report has picked the one spot that suits the reports goals…Not Reasonable or Feasible Reporting.
Existing vegetation changes over time, sometimes dense sometimes not.
They have been no consideration for night views (light spill) or summer winter sun shadows castings.
The reports assessment of there being NONE visual impact is their biased opinion to conceal the many that will be affected.
Pictures on page 39 are taken in the middle of a public road with houses looking over the site to the east of this point having massive impacts of visual and noise. As can be seen from picture currently a home is under construction and when it is finished the point from which picture is taken will have no impact but the house under construction will be impacted.


Therefore the report’s findings on page 47 are not satisfactory because there are misleading and biased to provide an outcome that suits Woolworths and not the residents of Casula and Glenfield.
.
We find that the report is not substantiated by the earlier MPE/MPW N&V reports already approved and that levels and finding have been reported and conducted to meet predetermined goals.
It will give the proponent an unfair financial advantage over existing warehouse tenants and disadvantage many residents that will have light spill and other impairments from this increased height building.
The proposal to move the building closer to the residents of Casula is also unacceptable because of noise and intrusions to the landscape views.
Please Consider the Many Casula Residents in their homes which will be severely disadvantage by the increase in height and background noise generated by the Operations of the HI bay warehouse, the additional railway crossings and relocations of the buildings closer to the residents
Thanking you

Michael and Leonie Russell and Family

RAID Moorebank Objects
On behalf of 10,000s of impacted residents and motorists.
Both those that have objected for the past decade and those who have yet to discover this ill conceived proposal.

See attached Preliminary Objection.
Detailed objections and appendices to follow.

I would like to make an additional comment on my previous submission re Section 4.5 (2)-SSD7709 (MOD 1) Page 20 Dangerous goods covered under B176.
Submission: I totally oppose any construction of warehouses to be totally dedicated for storage of dangerous goods.

To have a massive warehouses storing only DG's, being located in the middle of residential is absolutely frightening.

Yours sincerely,

Allan Corben

17/8/2020

Regarding unAustralian & AntiDemocratic & Prejudicial Interpretation of apparent Legislation which Excludes VOTERS from their Democratic Rights - 15 days to make a submission
Formal Objection Moorebank Intermodal Stage 3 - SSD 10431


Attention: Mr Craig Kelly (Representative for Voters) – Please advise what Action you are taking to fix this unAustralian and AntiDemocratic Mess




Dear Nathan (NSW Dept of Planning),

I am writing to formally object to the prejudicial interpretation of legislation which you seem to have applied by only allowing a 14 day exhibition period for modification applications (Concept and Stage 1 Modification 2 (SSD-5066-Mod-2) and Stage 2 Modification 1 (SSD-7709-Mod-1)).

If the goal is genuine engagement and robust community input, then exhibition periods must be 30 –45 days. It is not reasonable or feasible to expect the community to read all the material within a week and then compose a submission within a week. Assuming the notification is in fact noticed on or before the 1st day of exhibition. An unlikely proposition in the current climate [covid]. Moreover, the revised online submissions process is proving prohibitive for many in the community; particularly the older members [retired] and or the busy members [young families / parents]. The alternative postal option is equally prohibitive as it cuts the reading, comprehension and composition time down to approx. 10 days. But let us not fool ourselves; in the real world that means the bulk of the community will have just one weekend to tackle parallel mountains of planning material. Based on a decade of experience we can empirically say that the net result is generally a set of superficial objections that proponents have dismissed, or consent authorities have undervalued.

Again, if the goal of the Department is a democratic process and genuine engagement, then we emphatically suggest that the mark has been missed. In the parlance of archery that is a ‘sin’.

Therefore, please acknowledge this letter as a formal request on behalf of the community for an exhibition / submission extension to 21.09.2020, for both parallel modification applications.

Please confirm and advise at the earliest possible convenience.

At extremely short notice, I am formally objecting to this proposal.

In brief, some of the reasons for objection include:


• Establishment of a works compound: The entire site has long been known as a complex habitat for native flora and fauna including Threatened and Endangered species such as the Koala. Any and all clearing will put extreme pressure on this remnant woodland and riverine floodplain.

• Proposed earthworks, such as roads, utilities installation, stormwater and drainage, signage and landscaping mean that more of the native ecosystems will be lost permanently.

• Progressive subdivision of the site is obviously going to cause additional destruction to the woodlands as trees are removed being close to a site boundary and buildings constructed.

• Import of approximately 820,000m3 of Fill is the worst aspect of this abhorrent proposal. The entire area of Moorebank, Wattlegrove, Holsworthy and Milperra, as well as floodplains in the Bankstown LGA, will suffer flood-water displacement during the times of major flooding. We already know that catchment runoffs of flood water are exceeding speed-of-collection and volumes like have never been seen before. Already sites along the sweeping bend of the Georges River, which almost completely surrounds the site as an ‘island’, are overloaded with imported fill which should never have happened. People who have invested in homes in this region would never have thought such threats to their safety and property values would occur. It is a planning travesty.

In addition, during the past 12 years, we have protested about other negatives to Liverpool such as Air pollution, Traffic chaos, Noise and total unsuitability of the site for this purpose.

Please re-consider this Application and stop any further destruction.

Sincerely

I formally object to this proposal for a compound of worker accommodation, car parking hardstand, road construction, drainage and the importation of 280,000 unconsolidated and 540,000 structural fill, the subdivision and creation of nine allotments for terminal and warehousing purposes.

I take issue with this specific stage and the entire project and its merits. All of MPW is considered to be in breach of limits of approval of MPE Concept.

Stage 2 is considered to be in breach of the conditions of consent for MPW Concept. It is my view that Stage 3 continues to be founded on faulty traffic modelling and introduces new issues with traffic.

I refer to the public exhibition of the two matters which are on exhibition until 24th August and wish to submit a number of strong objections which have a huge impact on the area which if any previous objections are any guide will be ignored
1 There is much concern about the raising of building height from 21 metres to 45 metres and many are concerned if it is in relation to the storing of dangerous chemicals which with a 100000 in a 2km radius is not appropriate for the current location which will pose a massive health and safety issue for the area and with the massive traffic observed over the last 5 months is not possible

2 Noise is continually been overlooked and one wonders how it can be changed given previous court decisions. My experience is that noise cannot be mitigated as there have been many recent noises which I have located as being over 3km away as is experienced in Port Botany also residents have complained about the present noise levels which are never addressed
3 I have seen evidence on page 43 where there is talk of 2 concrete batching plants which have been previously denied in previous enquires which greatly alarms me adding to the pollution in the area which is already recognised as being the worst in NSW mainly as a result of huge traffic flows in the area and one must question the concern of our politicians who constantly talk of their concern for our welfare
4 With a large population with 53 per cent under 34 it would be better planning to have this project in a much more industrialised area and with the area the matter of a huge increase in population their vehicles have no chance in accessing our roads which would require upgrades to 34 intersections and the piecemeal attempts to improve traffic is a complete failure
5 The area currently has voters/residents with poor health ie with the highest number of residents with diabetes asthma and a 5 percent higher mortality rate
6 As stated I vigorously oppose this project for its impact on residents and how it will impact on our wildlife like koalas and 27 threatened endangered species and Plants like the Hibberia Fumana grevillea Cumberland plain trees
7 The area is on an island and having experienced huge flooding events in chipping Norton and Cambridge
8 There is talk about moving Moorebank Avenue closer to the wattle grove estate posing a much greater risk to residents re noise pollution

Received SIMTA's August 2020 "community update" leaflet which again demonstrates that there is NO Genuine Consultation/Communication with the Community !

However, it is Misleading/Deceptive/Omitting MANY Facts including:

1. requesting an increase in the noise generation criteria during operations into the future 24/7. ( just a formality no doubt as this is process is so Corrupt/UN Democratic)

2. Dangerous goods are to be stored on the site if approved (mitigation measures will preclude a Beirut incident? – if you believe that !)

3 Net job losses are totally ignored – Woolworths will down size its work force by 1,600 overall because of robotics and automation. Other prospective employment opportunities will no doubt also lead to net overall job losses. (a far cry from the premise by which this project was approved of being a job creator)

4. The Moorebank Ave re route is probably pre approved ( no consideration given to the residents within 400mtrs, who will bear the brunt of the traffic noise 24/7 !).

5. on site and visiting locomotives will be spewing out their toxic fumes 24/7 for all to Children/Famililes/Child Care Centers/Schools to enjoy within a 3 km radius and beyond. Not to mention the hundreds of daily truck movements in addition to that.

6 110,000 tCO2-e annually is somewhere in the future IF EVER. Making your ISCA “Excellent” design rating a sham and a rort to be given a $150 million loan!!


7 SIMTA/Qube’s success demonstrates “ask and you shall be rewarded” to continually request amendments and be approved, to the detriment of the local communities who were here first and should have a much higher degree of consideration given to their social well being and amenities.

I demand that the above document be RE-published with the CORRECTED Facts and the Community be provided with 2 months to read all of the relevant corrected information so that they can make informed decisions and then submit their Submissions based upon the CORRECTED FACTS

Yours Sincerely,

Subject: unAustralian & AntiDemocratic & Prejudicial Interpretation of apparent Legislation which Excludes VOTERS from their Democratic Rights - 15 days to make a submission
Importance: High

17/8/2020

Regarding unAustralian & AntiDemocratic & Prejudicial Interpretation of apparent Legislation which Excludes VOTERS from their Democratic Rights - 15 days to make a submission
Formal Objection Moorebank Intermodal Stage 3 - SSD 10431


Attention: Mr Craig Kelly (Representative for Voters) – Please advise what Action you are taking to fix this unAustralian and AntiDemocratic Mess




Dear Nathan (NSW Dept of Planning),

I am writing to formally object to the prejudicial interpretation of legislation which you seem to have applied by only allowing a 14 day exhibition period for modification applications (Concept and Stage 1 Modification 2 (SSD-5066-Mod-2) and Stage 2 Modification 1 (SSD-7709-Mod-1)).

If the goal is genuine engagement and robust community input, then exhibition periods must be 30 –45 days. It is not reasonable or feasible to expect the community to read all the material within a week and then compose a submission within a week. Assuming the notification is in fact noticed on or before the 1st day of exhibition. An unlikely proposition in the current climate [covid]. Moreover, the revised online submissions process is proving prohibitive for many in the community; particularly the older members [retired] and or the busy members [young families / parents]. The alternative postal option is equally prohibitive as it cuts the reading, comprehension and composition time down to approx. 10 days. But let us not fool ourselves; in the real world that means the bulk of the community will have just one weekend to tackle parallel mountains of planning material. Based on a decade of experience we can empirically say that the net result is generally a set of superficial objections that proponents have dismissed, or consent authorities have undervalued.

Again, if the goal of the Department is a democratic process and genuine engagement, then we emphatically suggest that the mark has been missed. In the parlance of archery that is a ‘sin’.

Therefore, please acknowledge this letter as a formal request on behalf of the community for an exhibition / submission extension to 21.09.2020, for both parallel modification applications.

Please confirm and advise at the earliest possible convenience.

VOTERS from their Democratic Rights - 15 days to make a submission
Importance: High


17/8/2020

Regarding unAustralian & AntiDemocratic & Prejudicial Interpretation of apparent Legislation which Excludes VOTERS from their Democratic Rights - 15 days to make a submission
Formal Objection Moorebank Intermodal Stage 3 - SSD 10431


Attention: Melanie Gibbons (Representative for Voters) – Please advise what Action you are taking to fix this unAustralian and AntiDemocratic Mess




Dear Nathan (NSW Dept of Planning),

I am writing to formally object to the prejudicial interpretation of legislation which you seem to have applied by only allowing a 14 day exhibition period for modification applications (Concept and Stage 1 Modification 2 (SSD-5066-Mod-2) and Stage 2 Modification 1 (SSD-7709-Mod-1)).

If the goal is genuine engagement and robust community input, then exhibition periods must be 30 –45 days. It is not reasonable or feasible to expect the community to read all the material within a week and then compose a submission within a week. Assuming the notification is in fact noticed on or before the 1st day of exhibition. An unlikely proposition in the current climate [covid]. Moreover, the revised online submissions process is proving prohibitive for many in the community; particularly the older members [retired] and or the busy members [young families / parents]. The alternative postal option is equally prohibitive as it cuts the reading, comprehension and composition time down to approx. 10 days. But let us not fool ourselves; in the real world that means the bulk of the community will have just one weekend to tackle parallel mountains of planning material. Based on a decade of experience we can empirically say that the net result is generally a set of superficial objections that proponents have dismissed, or consent authorities have undervalued.

Again, if the goal of the Department is a democratic process and genuine engagement, then we emphatically suggest that the mark has been missed. In the parlance of archery that is a ‘sin’.

Therefore, please acknowledge this letter as a formal request on behalf of the community for an exhibition / submission extension to 21.09.2020, for both parallel modification applications.

Please confirm and advise at the earliest possible convenience.

Heritage NSW comments attached.

Please see the attached response

See attached comments from the EPA

The Environment, Energy and Science Group of DPIE have no comments on this modification.

Hi Nathan,

Thanks for our discussion last week on this MOD on SSD 7709 MPW Stage 2.

As discussed, it is understood that the MOD is to accommodate a Woolworths Retail and Distribution Centre at 2 southern most warehouses in MPW Stage 2. These warehouses will be storing dangerous goods (DG) above the SEPP 33 thresholds in the Department’s SEPP 33. As such, a preliminary hazard analysis (PHA) [EA Appendix 15] was submitted.

In noting from EA Section 3.2 that the Applicant intends to modify condition B176, it would be critical for the Applicant to clearly identify the subject warehouse in a consistent manner within all the relevant documents and plans. This would allow the condition be modified to allow for the subject warehouses to store DG within the limits specified in the PHA. If the Applicant intends to store DG above SEPP 33 thresholds in other warehouses in future, condition B176 needs to be modified progressively for the relevant PHAs to be submitted pre-approval. This approach is in-line with the proper application of SEPP 33, requiring a PHA to be submitted during environmental assessments and not post-approval.

Clear identification of the warehouses is also critical to ensure that the PHA has been conducted in context of the other land uses surrounding the subject warehouses. These other land uses, although may be within SSD 7709, are still considered off-site risk receptors in context of the Department’s HIPAP No. 4. In this sense, we expect an analysis of full warehouse fires be performed in the PHA for the subject warehouses to demonstrate impacts to adjacent land uses, if any. We note that the analysis for full warehouse fire was not included in the current PHA, referring to PHA Section 4.14.1.

Moreover, we note that the current PHA did not assess the cumulative risk from both subject warehouses to surrounding land uses against the Department’s HIPAP 4 land use safety risk criteria. Although we note that likelihoods are analysed in terms of probability in various sections in the PHA, the cumulative risk analysis was not clearly analysed in terms of frequency per year which is the basis of the HIPAP 4 criteria (i.e. 50 x 10-6 chances per year for individual fatality risk at industrial land uses).

Considering the above, we request the following information to enable a detailed review of the PHA. Further information may be requested after considering the responses during the detailed review.

1. clear plans/diagrams indicating:
a. the location of the subject warehouses in context of the other warehouses within SSD 7709 and other land uses around SSD 7709;
b. the location of all dangerous goods and hazardous chemicals storages (class and maximum quantities) within the site plans of the subject warehouses and verify that this storage arrangement would be able to comply with all relevant Australian Standards.
c. consequence areas and risk contours bases on plans/diagrams a and b above.

2. analysis for full warehouse fire for the subject warehouses, including analysis if toxic combustion products from this fire in view of the range of dangerous goods classes to be stored within the warehouses.

3. revise the probabilistic risk analysis in the PHA to be consistent with the Department’s HIPAP 4 frequency-based land uses safety risk criteria and assess the cumulative risk from both subject warehouses to surrounding land uses against HIPAP 4.

Thanks.