Moorebank Intermodal Precinct West - Concept & Stage 1

The cumulative effects from both the SIMTA and the MIC proposals need to be put together in one EIS FOR A WHOLE OF PRECINCT proposal. NOT SEPARATE as they are so close to each other and the cumulative effects of the 2 proposals running at the same time is disastrous for the local area.

Liverpool City Council (Council) raised significant concerns about the scale of impacts associated with the proposal and have raised its strongest objection to the development scheme. It engaged Cardno (NSW/ACT) Pty Ltd to prepare a submission on behalf of and in conjunction with council to the public exhibition period.
The review found that environmental impacts are extensive and primarily localised to the area around the site at Moorebank and along key transport routes servicing the site. It is Cardno's view that these impacts must be mitigated and requires sufficient analysis, supporting infrastructure, management plans, operating procedures and compensation schemes be developed, which the current scheme and associated assessment fails to provide. Consequently, Cardno found that the proposal at this location is unacceptable and should not proceed.
Key issues associated with the project include:
* Traffic congestion and associated impacts on amenity due to additional vehicles on the network.
* Noise and vibration impacts associated with site construction and operation, as well as vehicle movements beyond the site.
* Air quality impacts associated primarily with vehicle movements beyond the site, as well as site construction and operation.
* Hazard and risk both within the site and beyond the site boundary associated with the transport network.
* Human health impacts resulting from a reduced level of amenity within a heavily populated area.
During the assessment of the environmental aspects a number of reoccurring themes were identified that either created significant impacts individually, or reoccurred throughout the review and therefore had the potential for cumulative effects on account of their repetitive nature.
East Liverpool Progress Association : MIT destined to be a costly, stunted freight yard
Michael Byrne, president of the East Liverpool Progress Association said: "Dr Schott as chair of the Moorebank Intermodal Company in commenting on the Federal Government's approval of the Moorebank Intermodal Freight Terminal repeats the mantra that it will reduce traffic congestion.
"Dr Schott is talking through her hat. The development simply relocates the congestion from a port tucked away in a corner of Sydney to Moorebank, which is located in a corner of the region it is planned to service. "
"The most nonsense Dr Schott expresses is that the Trust, holding the publicly owned lands valued at over $500 million, will attain rental income streams to attract buyers," commented Mr Byrne.
The Moorebank Intermodal, in East Liverpool, from its earliest conception was justified on its proximity to the M5/M7 road systems and the Southern Sydney Freight Line. These massive public funded assets were there for the picking with smart property asset purchases beginning with SIMTA in 2009.
The facts are that the development contains an inbuilt deformation of stunted growth. The entire financial analysis for economic and commercial return is based on throughput of at least 1.05 million IMEX containers (TEU) annually. It is unattainable. East Liverpool is river bound and bridge reliant. It serves the existing and planned suburbs in the south west region of Sydney as a narrow, congested traffic corridor. To its immediate south runs the Liverpool Military Area for over 25 kilometres thus blocking eastern routes from the far south west area of Campbelltown. The two East Liverpool bridges carry more traffic than the bridges that serve the Sutherland Shire. And they plan to merge into them 5,000-8,000 daily B-doubles.
"Dr. Schott's grand development is now most likely to stand as a monumental infrastructure failure in the form of a much reduced secondary freight yard with Qube / Aurizon making a small margin, whilst over $500 million of public lands are wasted. Not to mention the great disruption to local neighbourhoods and our Georges River," said Mr Byrne.
Resident action group: decision ignores all facts
Allan Corben is a resident of Liverpool, NSW. He is a member of the Liverpool City Council No Intermodal Committee, and a community group named RAID (Residents Against the Intermodal Development). His work background included 47 years in the transport and logistics industry, with 13 years of that period in rail/container transport business.
"It was interesting to read in the media earlier this week that the Federal Government had agreed to enter into a partnership with a private organisation (SIMTA) to develop the Moorebank Intermodal. The majority of media releases were worded in a manner to suggest that the development had been approved to allow construction to commence.
"I'm of the opinion that the wording was such to give those involved in the opposition to this proposal the impression that the development was done deal, so as to have the opponents (local community) cease their opposition.
"Both the Federal and State Governments, together with SIMTA, are deliberately ignoring a number of critical facts covered below:
Traffic: It is well known that the Liverpool road network is near capacity. In an article published in the Daily Telegraph on 4 June, the Federal Government is quoted as rebuffing critics who say it will clog Western Sydney roads with trucks, but in a speech on the intermodal proposal made by NSW MP Ms Melanie Gibbons in the Legislative Assembly on 4 June, she made the following statement: `I have read through the information provided by the company for the next period of community consultation. It says that, should there be an accident on the M5 or Moorebank Avenue, the facility will need to close while the accident is being cleared.'
"Somewhat conflicting comments from the same people! I'm sure that transport companies servicing the site, warehouse tenants and their customers would be less than impressed with this prediction
"Although a traffic model, completed on behalf of our community, has shown that there are many roads and intersections that will require substantial upgrades, the proponent has only acknowledged only one upgrade being Moorebank Avenue, but not till 2029/2030. This is regardless of the fact they intend to bring upwards to an extra 10,000 truck and 5,700 car movements on to the local road network daily.
"One of the main selling points, claimed by the proponents, has been that Moorebank will take thousands of trucks off the Sydney roads each day, which is absolute garbage as all it will do is relocate the trucks to Moorebank, where they will enter the Sydney road network. The fact is that it will remove trucks in the interim from the M5 between Port Botany and Moorebank, but this will only be a short term reduction. The reason for this is due to the handling capacity of the Port Botany freight line. It has been suggested (government has refused to reveal capacity) that the line has a maximum capacity to handle 1.2 million containers per annum. If we consider that Port Botany currently receives 2 million containers per annum and is predicted to handle in excess of 4 millions in future years, how will the additional 2.8 million containers be delivered, simple, on the back of a truck.
Noise: The intermodal site is located in the middle of a number of residential suburbs that are home to many thousands of people. It is a known fact that residents living within a radius of three kilometres of the Port Botany container terminal are suffering from sleep disturbance, yet the proponents and government are obviously of the opinion that residents who live within a radius of 400 to 1000 metres from the proposed site will not be impacted by sleep disturbance. The government claims that the warehousing on what is currently SIMTA's site will act as a buffer zone to the suburb of Wattle Grove, but anyone who has been exposed to the level of noise created by this type of operation knows, the warehouse will barely reduce the overall noise level. The people living in the elevated suburb of Casula (400 metres on the Western side of the site) look directly down into the proposed area, with no chance of avoiding the noise level whatsoever. When asked how the proponents would mitigate the noise level, the CEO of MICL stated that it would be up to the successful company who was appointed to developed the site to address.
Air quality: It is well know that Liverpool area is one of the most polluted areas in Sydney. This is qualified in a statement made in the PAC SIMTA determination that has already shown that PM 2.5 levels in the local area are close to or above the advisory criteria, MICL state that: `Air quality monitoring has demonstrated that the concentration of different airborne pollutants in Liverpool is generally well below guidelines.' Again, conflicting statements.
"Regardless of the above, which substantiates that the proposed area is already highly polluted, the proponents intend to bring 10,000 + diesel trucks, ancient diesel locomotives and thousands of car movements into the site area daily. It should be noted that the emissions created by diesel types of equipment are carcinogenic and in the same category as asbestos, which is a well known cause of death.
Alternative site: With the announcement of the Badgerys Creek airport, it was suggested that the ideal site for the intermodal would be to amalgamate the two projects. This would eliminate the need to spend many millions of dollars upgrading the eastern area of the Liverpool road network, and totally eliminate noise and air quality issues. This suggestion has been completely dismissed by the government and the proponents as not possible due to (1) not sufficient time due the urgency of the predicted increase in import container arrivals, calling for additional handling facilities and (2) no rail line into the Badgerys' site.
Timeframe: There have been two changes that suggest that the urgency to build Moorebank no longer exists. Firstly, the Chullora terminal has announced that it has increased its handling capacity from 300,000 to 600,000 and secondly, the predicted annual increase in import containers of 7%, as advised by the proponents, has not been achieved and, in fact, is only in the area of 4%. Where's the hurry?
"Now that both developments have amalgamated into one, the EIS process should commence again on the overall development.
"We've seen the previous government waste billions of taxpayers dollars rushing into decisions that were an absolute waste of resources and money and we cannot allow the current government to follow suit. I'm afraid that the government, or some senators and MPs believe that Moorebank is the ideal location because the proposed site is next to the rail line and a motorway."

----------------------------------------------------------------------------------------------------------------

submission mic june 22, 2015
The Environmental Impact Statement prepared by the Moorebank Intermodal Company (MIC) states that the proposed Moorebank intermodal will allow imports and exports to grow through Port Botany. This will mean additional traffic on the already congested road network. 10,000 heavy vehicles per day will need to access and leave the terminal utilising the M5 and local roads.
The MIC state that an additional intermodal is required to reduce supply chain costs; however, it is questioned how the proposal at Moorebank will assist in reducing these costs. The proposed terminal in Moorebank will include transferring freight by rail less than 25 Kilometres from Port Botany, while increasing the handling costs of the supply chain with containers having to be loaded and unloaded multiple times in a very short distance. Infrastructure NSW has also questioned the viability of short haul freight and the funding of additional intermodal facilities until this has been properly investigated. That being the case, the increase in capacity at Chullora should be investigated with proper planning for a true intermodal at Badgerys Creek. Jenny Wiggins, in her Sydney Morning Herald article, states that Asciano is primed to invest $112 million to `compete "vigorously" with its own intermodal terminals', for example Chullora, and challenge the Moorebank intermodal

essentially casting doubts over the economic viability of the Moorebank site (Wiggins, J., 2014, `Asciano challenges Moorebank freight hub', Sydney Morning Herald, 2 July 2014).
To truly reduce supply chain costs, the intermodal location should be moved to Badgerys Creek, a facility more than 40 Kilometres from the Port with access to key roads such as the M7 and the proposed M9. This location will also have the capacity to support future growth centres. The M9 motorway will provide `a direct link between the Central Coast and the Illawarra, connecting the growth centres of Camden, Penrith and Windsor' (O'Rourke, J., 2014, `What Sydney needs to transport us to the future', Daily Telegraph, 3 November 2014). An intermodal at Badgerys Creek demonstrates good strategic and growth planning.
Why Badgerys Creek is a better location than Moorebank
The MIC, in their Environmental Impact Statement, attempt to describe why Moorebank has been selected as a location. However, Badgerys Creek is better suited to meet the criteria that the MIC has listed.
Badgerys Creek is an ideal location for an intermodal terminal to handle both interstate and import-export freight. This is because it is:
* long enough for interstate freight trains without the need for trains to be broken up and shunted, creating unnecessary additional noise in the area;
* big enough to handle the number of container movements required - up to 1.1 million twenty foot Equivalent Units (TEUs) per year of import-export freight and another 500,000 TEUs per year of interstate freight. This is a greater capacity than the proposed Moorebank site;
* strategically located in an area where a new rail line is planned for the airport;



* near the M7 Motorway, a link to the West and North West where it has been identified by Deloitte that most of the container freight will be headed, and accessible to the M5;
* near the proposed M9 Motorway, providing the ability of the intermodal to service future growth centres;
* near the Western Sydney Employment Area (WSEA), future industrial areas and future freight markets in Western Sydney, where two-thirds of container freight received at Port Botany will be transported.
* further from Port Botany than the Moorebank site, making rail a viable alternative to trucks, and reducing supply chain costs;
* in development, meaning that truck access can be configured into the $3.5 billion already allocated to the surrounding road infrastructure network rather than upgrading roads that are already at capacity in the Moorebank precinct; and
* owned by the Australian Government and available for use consistent with the airport.

Problems with the Moorebank proposal
The Moorebank site constrained by a number of issues:
* The area is already suffering from significant traffic congestion, the addition of an estimated 10,000 truck movements and approximately 5,000 passenger car movements per day will exacerbate this congestion.
* The Planning and Assessment Commission (PAC), following their community meeting on the SIMTA proposal, has identified that the Moorebank area is already suffering from significant traffic congestion. `The community has strongly argued that the



proposal is only going to move the congestion from Port Botany to the Liverpool/Campbelltown region. The Commission understands the Moorebank site is constrained by the surrounding residential and industrial land uses and the already heavily congested local and regional road network. If the concept plan were to be approved with the levels of throughput proposed by both SIMTA and MIC, then clearly the community's case is strengthened.' (2014, Planning and Assessment Commission, SIMTA assessment).
* The SIMTA Concept plan was approved by the PAC on the basis that they are limited to 250,000 TEU's, plus an additional 250,000 ONLY if the road network is able to handle the volume of heavy vehicle traffic. This being the determination made by the PAC, and in the absence of a master plan that would have enabled the commission to assess the impact of both proposals as part of the one process, this limit should apply to the operation of both SIMTA and Moorebank intermodal sites combined. TEU's should be limited to a total of 250,000 in this precinct.
* The economic viability of the site has been questioned due to the limits placed by the PAC on the number of TEUs SIMTA can move through their terminal. Chief Executive of Asciano has also questioned the economic viability of the site as previously mentioned, stating that Asciano plan to invest $112 million in their sites to increase capacity and making Chullora more competitive, able to handle an increased capacity from Port Botany, and open for operation before Moorebank (Wiggins, J., 2014, `Asciano challenges Moorebank freight hub', Sydney Morning Herald, 2 July 2014). With the Chullora intermodal capacity increased to 800,000 TEU it will easily be able to support increased in freight through Port Botany while the Badgerys Creek site is planned and constructed.

The Moorebank site is surrounded by water on all sides. This means that the complex road and rail upgrades needed to service an intermodal in this area will be extremely costly. Liverpool Council has estimated these upgrades are likely to cost in excess of $750 million.
* There are significant problems relating to air quality, construction and operational noise impacts created by the intermodals. A proposal of this size and nature should not be earmarked for a residential area.
* The PAC determination of the SIMTA proposal has already revealed that Particulate Matter 2.5 levels in the local area are close to or above the advisory criteria for this pollutant, this applies to the current background levels as well as the predicted impacts. Additional diesel and liquid natural gas powered vehicles in this area will exacerbate this problem.
* Noise impacts, light spill and air pollution will have a detrimental effect on the local community, some of whom live as close as 400 metres from the site. Residents around Port Botany living as far as three kilometres from the port are affected by these factors; many residents in Chifley for example have been very vocal about sleep disturbance in the online domain.
* The Moorebank site will have a detrimental impact on the Casula Powerhouse Arts Centre. The presence and accessibility of an art and cultural facility in a low socio-economic area, such as Liverpool, is essential for positive community growth.

Problems with the process
The Freight Infrastructure Advisory Board (FIAB) recommended a master plan for the site, this was not undertaken. Residents agree the SIMTA and MIC proposals should have been considered as a single precinct application. This has created an unfair advantage for the proponents with confusion being created among the community with both proponents presenting different figures. The fact that both proposals were assessed separately also means that media attention highlighting the different stages of the planning and assessment process has also created confusion in the community. Coupled with this, the relocation of the Defence National Storage Distribution Centre (DNSDC) and the current construction works at Holsworthy Barracks have also exacerbated this confusion with many people within the community thinking the proposal is already in its construction phase.
Liverpool Council, in meeting with PAC expressed disappointment that a master plan was not undertaken and confirms that this has created confusion within the community `The ad hoc approach .........leaves gaps and inconsistencies in the information available resulting in a lack of transparency and reduced faith in government decision making.'
A master plan would have reduced this confusion and allowed the community to better understand the impacts these proposals will have on their family, friends and neighbours. It would have allowed the community to better refute claims made by the proponents, and have a much greater grasp of any proposed mitigation strategies for this proposal.
The MIC has also created confusion and doubt within the community, adding to a reduced faith in government process and decision making. They have done this first by splitting their figures. Rather than telling the community that there will be 1.55 million TEUs going through the site, they have split these figures between import-export and interstate. And rather than stating that there will be an estimated 297 train movements expected at the site, they have again split these figures to make them sound lower. The Liverpool Leader, in their article `Intermodal company gives community $1m for compensation package but concerned residents aren't buying it', reports on community concerns around the consultation process. This `compensation package' will be completely inadequate to address the impacts this proposal will have on the area, and made MIC seem like it was trying to `buy community support'. At the same time MIC also made a highly publicised donation to the Liverpool Mayoral Ball, which Liverpool Council subsequently rejected (Hansen, N., 2014, `Liverpool Mayor knocks back $5k ball donation from intermodal group but the cash is still destined for charity', Liverpool Leader, 22 August 2014).
An intermodal at Badgerys Creek would not require this level of compensation, as it can be properly planned for a suitable area; it also has residential and council support.
Second, the Sydney Morning Herald in their article `Waterfront baron and Liberal Party donor scored inside running on freight hub tender' has highlighted a possible issue around transparency and due process in the awarding of tenders for the Moorebank precinct. In light of the recent ICAC investigations and the problems faced by the Newcastle community, transparency and due process are paramount in the government decision making process.

Key issues from the community
There were some issues raised by local representatives and the community at the PAC determination meeting on the SIMTA proposal. These have remained largely unchanged in relation to the MIC proposal. Traffic and access
* The proposal will move the congestion from Port Botany to Moorebank, which is already congested;
* Modelling does not include the predicted growth of the region;
* The intersections and road network are already congested,



how is it possible for the proposal to decrease traffic delays?
* Trucks `weaving' onto and off the M5 between the Moorebank and Hume Highway interchanges, this is going to cause accidents; and
* Trucks parking and taking short‐cuts through the nearby streets.

Noise
* There is no noise wall along the rail corridor along the Georges River, so noise will carry particularly at night;
* Noise from the unloading/loading and movement of containers within the terminal;
* Noise from the breaking and shunting of trains due to the site sizing constraints; and
* Wheel squeal from the trains exiting the SSFL, tight radius curves lead to wheel squeal.

Air quality
* Increased diesel fumes in the community generated from locomotives, heavy vehicles and other heavy equipment used on site;
* Health impacts from the increased diesel fumes;
* South‐west Sydney is already heavily polluted due to the topography; and
* Dust and odour, particularly during construction.

Two intermodal proposals (SIMTA and MIC)
* There is an ad hoc approach to the two proposals;
* Cumulative impacts of the two proposals have not been adequately addressed; and
* Confusion as to the total traffic generated from the two proposals, as the modelling for each is different.

Heritage
* Removal of heritage features from the site, particularly those of military and indigenous significance.

Location
* Site is surrounded by residential development; and
* Other sites are

preferable, such as Badgerys Creek, which is not surrounded by an established community.




Moorebank Intermodal Company EIS presentation
There was considerable concern from the community over the presentation that was given for the MIC EIS submission. Figures and statistics presented by MIC seemed to be inconsistent and the facilitator tried, on a number of occasions, to ask the community to voice their concerns directly to MIC representatives rather than in the public forum. At each of the three sessions the facilitator kept stating that she was conscious of time; however, the community feel that their questions about a proposal that will impact their family and community deserved an answer, and are more important than clock watching. The number of questions from the community at the final community information session saw the session run over time.

Traffic and Transport
* The MIC recognised that there are significant transport and traffic congestion problems in the Moorebank precinct; however, they claim that the additional 8,160 heavy vehicles and 5,724 cars they predict to be brought into this precinct every day due to an intermodal will not have any further impact.
* The Chief Executive Officer of MIC stated that there would be approximately 1.6 trucks required per TEU. He also stated that 1,400,000 TEUs would be required to leave the terminal by truck. According to this statement, and given that heavy vehicles will have to both arrive and leave from the precinct, the figure of 8,160 heavy vehicles per day seems low, this actually equates to 12,376 heavy vehicles per day. For the purposes of this document the figure of 10,000 heavy vehicle movements per day has been chosen as a more accurate representation of the figures.



* The Chief Executive Officer of MIC also confirmed that the Moorebank intermodal will not take heavy vehicles off the M5 between Port Botany and Moorebank, and that as Port Botany expands the number of heavy vehicle movements on this stretch of the M5 is expected to grow. It should be noted that Labour Minister Anthony Albanese previously claimed that the Moorebank intermodal would take trucks off the M5; this fallacy gained a lot of momentum especially in the media and it has never been publicly corrected.
* Questions were raised by the community about the problem of Trucks `weaving' onto and off the M5 between the Moorebank and Hume Highway interchanges. MIC recognises this as a significant problem. This `weaving' has the potential to cause a recognised `black spot', with potentially fatal consequences for the community. It is worth noting that a `black spot' is already located at the Nuwarra Road and Heathcote Road intersection, only 2 Kilometres from the `weave' site.
* The traffic modeller for MIC presented information about the predicted impacts on intersections both with the intermodal and without. Intersection surveys were undertaken on Tuesday 7 December 2010, and Tuesday 18 March 2014, in peak hours only. It is concerning that these surveys seem to only have been conducted on two days, four years apart, with the December date being in a peak holiday period.
* A Seven-day automatic traffic count was also conducted from Tuesday 7 December 2010 at only three locations along Moorebank Avenue. It is concerning that four year old data, gathered prior to a number of new and extensive residential developments in the area, is being used as a base for traffic modelling.



* The data presented by the traffic modeller showed a delay of over 200 seconds at some intersections when the intermodal is in operation. A 200 second delay, coupled with a 150-180 second cycle on a normal set of traffic lights is a significant impact (approximately six minutes at EACH set of lights), one that is likely to have flow on effects. He has compared data, which is based on a scenario where the intermodal is operating with road and intersection upgrades, with predicted data based on no intermodal without road upgrades. This is not comparing like for like. Given that intersections in this area are currently operating at D or E classification (near or at capacity), it is hard to believe that the roads in the area will not be upgraded by relevant authorities to attempt to reduce congestion before they reach an F classification.
* It has been noticed that traffic figures do not take into account the recently announced WestConnex which will have major traffic implications on the M5 during construction; this coincides with the proposed opening date of the Moorebank intermodal. The WestConnex project also aims to increase Port Botany by 272% more container ships by catering for a greater number of heavy vehicle traffic movements on the M5. Labour Minister Anthony Albanese criticises the WestConnex `proposal for not going near Port Botany, where it is expected there will be a large rise in the number of container trucks'. He also questions the government's transparency, citing that `the decision to release new information about the impact of WestConnex on Melbourne Cup Day indicates to me that those who support this route are aware of its



shortcomings and are keen to avoid public scrutiny.' (Saulwick, J., 2014, `Albanese pans plans for the WestConnex', Sydney Morning Herald, 10 November 2014).
* Residents are understandably concerned about the impact of intermodal traffic on local and residential roads. The MIC confirmed at the community information session that while they can implement some measures for traffic movements, it will ultimately be up to the design of the precinct, the way the precinct operators choose to use the precinct, and choices made by heavy vehicle drivers as to which route they choose to use. With heavy congestion on Moorebank Avenue and the M5, two of the key roads in the area, it is likely that Anzac Road and Cambridge Avenue will be used as `rat runs' for heavy vehicles.
* The MIC traffic modeller recognised that currently 6% of traffic on Anzac Road in the peak is heavy vehicle traffic; however he failed to include any heavy vehicle movements in his trip distribution figures for this road. In current heavy traffic conditions Anzac Road is a very attractive option, as demonstrated when the M5 is congested. Heavy traffic movements on a congested day are far higher than those measured by MIC. The omission of this traffic flow information from MIC data sets is hard to fathom. For the local residents, especially those with houses that back onto Anzac Road, it creates uncertainty and distrust in the accuracy of the information presented.
* The construction of an intermodal terminal at Moorebank shows a lack of strategic planning, particularly in relation to future traffic movements.
* An intermodal at Badgerys Creek will be a true intermodal with road, rail and air access. This area will serve the purpose of meeting the needs of future growth centres. The government currently has the ability to configure appropriate and safe truck access in the Badgerys Creek area with $3.5 billion in funding dedicated for road infrastructure.



predicted an additional 297 train movements each week, this figure does not include the interstate trains that may transit through the terminal.
* It was unclear how these train movements would impact residents in the area, due to three different rail entry options currently under consideration.
* Due to the length of trains, they will need to be broken up and shunted.
* MIC communicated that the actual rail entry will be decided once a tender for operation of the facility has been awarded. This makes it difficult for residents to understand the impacts of the rail access.
* It is unclear whether rail access will impact the passenger rail line and impact on travel times for people travelling by rail to the Sydney CBD.
* An intermodal at Badgerys Creek will not have the same rail implications. The size of the site will allow trains to remain whole within the terminal without the need for breaking and shunting.


Noise and vibration
* In order to ascertain acceptable noise levels in the area, the MIC have measured ambient noise levels between 2010 and 2011, and then from July 2012 to establish a base index. Approximately 20 of the 34 noise receptors set up and monitored by the MIC to establish this base index were located along train lines and major roads.
* Given that most residents in the area live in quiet, peaceful streets, it is a concern that the receptors set to ascertain the base index for ambient noise seems to have been placed in predominantly noisy locations.
* The residential suburbs of Casula, Wattle Grove and North Glenfield are the closest communities to the Project site; however, these will not be the only locations impacted by the noise generated from the proposed intermodal.
* In a recent article in the Sydney Morning Herald it was learned that `After more than a year of residents around Port Botany being told the night time noises they were complaining about did not exceed "sleep disturbance criteria", the Environment Protection Authority has admitted they were right.' (O'Brien, N., 2014, `EPA admits it was mistaken about Port Botany noise levels', Sydney Morning Herald, 17 August 2014).
* Residents in the precinct are understandably concerned that noise levels will exceed those acceptable. Above acceptable noise levels can have health impacts including: annoyance, sleep disturbance, performance issues (reduced concentration), cardiovascular health problems, hearing problems, mental health effects, and general health impacts (e.g. on the immune system).



* There is currently no noise wall along the rail corridor along the Georges River, so noise will carry particularly at night.
* There is no doubt there will be excessive noise from the unloading/loading and movement of containers within the terminal, which will operate 24 hours a day, as well the breaking and shunting of trains due to the site sizing constraints, and compression breaking of trucks on the surrounding roads.
* Wheel squeal from the trains exiting the SSFL have also been identified, as tight radius curves lead to wheel squeal. The MIC noise analyst has agreed that wheel squeal is likely to be a factor with some of the three different rail entry options currently under consideration. A factor that will apparently be decided once the tender is awarded, a decision that is likely to be economically based with no consideration for the nearby community.
* An intermodal at Badgerys Creek will not have the same noise implications, due to it being located in a purpose built heavy industrial area. The size of the Badgerys Creek site will also allow trains to remain whole within the terminal, negating the need for breaking and shunting of trains. Rail access will not be restricted by the construction of rail bridges over the Georges River, as is the case at Moorebank, reducing the instance of wheel squeal by negating the need for tight entry and exit points. Compression breaking can be limited through planned road upgrades specifically designed for heavy vehicle movements.

Local air quality

MIC have recognised that exposure to pollutants and particulate matter (PM) can contribute to, or exacerbate, respiratory and cardiovascular issues, including



premature mortality and morbidity, in addition to increasing associated hospitalisations. This supports that point that this proposal should not be planned for a residential area.
* Placing a heavy industrial facility in the middle of a residential area is negligent and will be detrimental to the community. The proposed site is located in a basin which allows pollution to lie, rather than easily move away. The NSW Planning and Assessment Commission have already recognised that the air quality in the Liverpool area is generally well below guidelines, particularly PM2.5 concentrations which are close to or above the advisory criteria. Additional diesel emissions and particulate matter released from this proposal will prove dangerous for residents, especially the most vulnerable: children, the elderly and disabled members of the community.
* Diesel fumes and particulate matter are carcinogenic, and as well as causing other serious illnesses, will be fatal for some members of the community.
* It has been identified that diesel locomotives and switch engines are significant contributors of SO2, NOx, PM10, PM2.5 and PAHs, while onsite mobile equipment (ITVs, side picks and forklifts) are the highest contributor to CO and VOC emissions, they also contribute substantially to PM10, PM2.5.
* It is understood the decision about onsite equipment will be made by the tender winner and based on economics rather than community welfare.
* During operation of the Project, combustion engine emissions (i.e. NOx, CO, SO2, PM2.5, PM10, VOCs and PAHs) from locomotives, mobile LNG equipment and heavy vehicles represent the greatest potential for air quality impacts.
* With 297 train movements each week and approximately 10,000 truck movements each day it is concerning that a proposal of this nature could be considered alongside



family homes, and close to pre-schools, primary schools, high schools, as well as aged care facilities.
* Badgerys Creek, an Australian Government owned area, is away from residential properties, and therefore not likely to cause the same risks as the Moorebank site. It is also well placed near the M7 and the proposed M9 Motorways, providing the ability of the intermodal to service future growth centres, near the Western Sydney Employment Area (WSEA), future industrial areas and future freight markets in Western Sydney, where two-thirds of container freight received at Port Botany will be transported.

Human health risks and impacts
* The NSW Chief Health Officer's Report (2010) identified that health gains achieved over the past few decades have not been equally shared across the entire NSW population and that there is a gap between those with good and poor health. This gap is exacerbated in poorer communities.
* South Western Sydney has some of the poorest communities in NSW as measured by the SIEFA data (Australian Bureau of Statistics (ABS 2011).
* South Western Sydney has higher rates of people with disabilities than the NSW average. People with disabilities have health conditions which may or may not be related to their disability.
* In 2004 - 2008, South Western Sydney residents had higher incidence of lung, kidney, head and neck, pancreas, thyroid, stomach, bladder, uterus and liver cancer than NSW.



* Mortality rates in South Western Sydney for cardiovascular disease at 83.9 per 100,000 are 5% higher than the NSW average of 100 and are significantly higher in Liverpool LGA (111.4) (2005/06).
* Very high psychological distress was reported by 13.2% of South Western Sydney residents (2.1% above the NSW average).
* As previously noted, MIC have recognised that exposure to pollutants and particulate matter (PM) can contribute to, or exacerbate, respiratory and cardiovascular issues, including premature mortality and morbidity, in addition to increasing associated hospitalisations. And that that diesel locomotives, switch engines, and onsite mobile equipment (ITVs, side picks and forklifts) are significant contributors of PM10, and PM2.5.
* As also noted, above acceptable noise levels that will result from an intermodal terminal can have health impacts including: annoyance, sleep disturbance, performance issues (reduced concentration), cardiovascular health problems, hearing problems, mental health effects, and general health impacts (e.g. on the immune system).
* Traffic impacts with the identified the problem of Trucks `weaving' onto and off the M5 is a significant problem. This `weaving' has the potential to cause a recognised `black spot', with potentially fatal consequences for the community.
* It is highly negligent of the Government to consider building an intermodal at the currently proposed Moorebank site. The site is located in the middle of a residential area, and the consequences of such a decision will prove dire to the community.
* Badgerys Creek is by far a site better suited to meet the criteria that the MIC has listed in their EIS summary.

Support from elected representatives
The role of three tiers of government is to ensure that community needs can be voiced to the government by their local elected representatives. These representatives are based within the community, they understand the local area, and are acutely aware of the geographic typography of the area and their constituents needs.
The representatives from the Liverpool area are all unequivocally stating that the Moorebank Intermodal proposal is in the wrong location. This includes the federal member for Hughes, Craig Kelly MP; the state member for Menai, Melanie Gibbons MP; and Liverpool City Mayor, Ned Mannoun.
It is worth noting these representatives recognise the need for an intermodal terminal within metropolitan Sydney to support future freight growth in New South Wales; however, Badgerys Creek is the ultimate location for this development. Liverpool Council have recently released a discussion paper titled `Badgerys Creek: the ideal location for an intermodal' (October 2014).
It is time for the government to listen to their party members who are voicing some very valid concerns, and join the discussion about a new location for this project.

Alternative uses for the land at Moorebank
The residents of Liverpool also support the Freight Infrastructure Advisory Board (FIAB) recommendation of the development of new intermodal freight capacity within metropolitan Sydney. However, the residents believe that the location of this development should be strategically placed to meet future growth and freight capacity. Therefore, it is proposed that Badgerys Creek, rather than Moorebank, is recognised as the consummate site for development.
`In 2011, the Australian Government developed the Liveable Cities Program (now called the Liveable Communities Programme) to support state, territory and local governments in meeting the challenges of improving the quality of life in our capitals and major regional cities' (2011, Department of Infrastructure and Regional Development website).
As part of this program, Parramatta City Council (the only Sydney council selected for the program) received $16,150,000 in funding to complete three missing links on the Parramatta Valley Cycle way, and undertake a series of related works on the Parramatta River Foreshore. The money used for this revitalisation has given Parramatta an economic and social boost.
The site identified for the Moorebank intermodal is prime, urban, riverfront land. This land should be used to assist the government in solving the housing crisis identified in the draft Metropolitan Strategy for Sydney, by using the development as a premium riverside residential lifestyle precinct. The land is situated less than 30 Kilometres from the Sydney CBD. It is in close proximity to public transport, including the T2 Airport and T2 Inner West & South lines (both of which have capacity to accommodate urban growth in this area), the Liverpool to Parramatta T-Way, the M90 Liverpool to Burwood bus route, and many suburban bus routes. In short, the Moorebank location is perfectly positioned and adequately serviced by public transport to assist the government in meeting its housing targets set in the Metropolitan Strategy for Sydney.

An independent valuation (Cushman and Wakefield Development Opportunity Liverpool Riverside Lands, September 2014) valued the SIMTA and MIC sites at more than $482 million. Revenue raised from the sale of this land could be used to assist in the funding of the infrastructure needed to support, and fast-track an intermodal at Badgerys Creek.
NSW Chief Health Officer's Report (2010) identified that there is considerable evidence that social factors (e.g. income, employment and education) have a critical role in health outcomes. A plan to revitalise the Liverpool area by embracing natural assets, such as the Georges River, and utilising land to its full potential presents an opportunity to lift the socio-economic status and improve overall health in the area. The Liveable Communities Programme in Parramatta is a testament to this.
Preserving the Casula Powerhouse Arts Centre and maintaining its accessibility to the community will boost the social economy of the area and contribute positively to community growth.
Linda Silmalis, in her Sunday Telegraph article (9 November 2014) says that `NEW housing sites for 11,000 homes will be unlocked today as the NSW government seizes on a building boom with one of the biggest land releases in Sydney this year.' On this topic, `State Planning Minister Pru Goward said the areas will help drive the housing construction boom, while placing downward pressure on house prices.' (Silmalis, L., 2014, `Grab your new home out west', Sunday Telegraph, 9 November 2014). Liverpool Council estimates that the land proposed for the Moorebank intermodals has the capacity for approximately 16,500 riverside dwellings, housing more than 40,000 people, and giving the community access to the Georges River. This will assist the government in meeting its targets, identified in the draft Metropolitan Strategy for Sydney, to develop housing for more than 1.6 million people. Affordable housing is a much better use of the land in this area.
Good, well considered, strategic planning is required to maintain New South Wales' status as the Premier State. This includes planning major infrastructure projects, such as an intermodal terminal, in the right location. The right location for this proposal is not Moorebank; Badgerys Creek is far better suited and situated to meet the Government's freight infrastructure needs.
Please reject this proposal on the grounds that it is not in the public interest of the residents of Liverpool or the wider community.

-------------------------------------------------------------------------------------------------------------------------
JOBS
One of the selling points for this proposal is the apparent large number of jobs for the people of the area. This is false advertising as everybody knows that jobs will be awarded on the basis of skill and experience, not location of where one lives.

It's anticipated 1650 full time jobs will be created during construction, and a further 1,700 people could be employed in the Liverpool region once the project is up and running.

Since a technology park or commercial development could employ 15,000 people on that block of land, 1700 jobs in the region, not even at the terminal, but every related industry from the lunch shop to the warehouse to the trucks that are going to congest local roads. That's over 13,000 local people forced to catch the overcrowded trains into town or drive to North Ryde or Rhodes or Mascot because the government doesn't want them to work locally.
This terminal robs around 13,000 local people of the opportunity to work in the local area. A commercial development of a similar density to Rhodes or Macquarie Park could easily accomodate 15,000 office workers on the site and with a station just across the river all that's needed to reduce the traffic is a foot bridge.

Many local residents have raised concerns about the likelihood that other land uses, such as commercial land uses, could provide many more jobs. At the PAC meeting we heard just how much worse a container terminal is as a source of jobs than a commercial development on a hectare for hectare basis.

What shocked me was hearing how the terminal actually takes jobs away from the local area!

If the terminal goes ahead, then it is reasonable to think that light industrial areas will be converted to warehousing. All of those containers have to go somewhere right? But large warehouses employ fewer people per hectare than light industrial developments - each small manufacturer and panel beater, and so write more pay cheques at the end of the week than a huge warehouse does.


TRUCKS OFF ROADS LIE
Another selling point for this proposal has been the false statements that it will take trucks off the M5 motorway between Port Botany and Moorebank. This falsity was even admitted by the CEO of the MIT, Ian Hunt in one of the community consultations in Casula.
"A new freight terminal in Sydney's south-west will take 3,300 trucks off Sydney roads" has been a phrase used to push this proposal through.
Now this lie is so obvious that I can't believe they aren't ashamed to say it. Each container that arrives on a train has to get back onto the same truck that would have taken it away from Port Botany. That's a sum total of zero trucks taken off the road. They might be closer to their destination, but they are still on the road and they are on roads they weren't on before.

Another statement widely used had been
"Moorebank is the ideal location because of its close proximity to major connecting routes such as the M5, M7 and the Southern Sydney Freight Line"

If all of these trucks are disappearing from the roads, why the emphasis on proximity to the M5 and M7? The truth is they are taking trucks off the roads in their electorates and putting them somewhere else. This doesn't fix the problem, it just moves it.



COMMUNITY CONSULTATION

This has been not covered adequately and appropriately. The information sessions at Casula of which I attended 2, were inadequate.

Firstly the timing of some of these meetings was unfair. It coincided with the everyday family's dinner time or after school arrangements or most of all occurred during normal business hours or at times when residents might be travelling home from work.

Secondly the rushed approach by the lady acting as a mediator or host of the meeting was inappropriate. There were many people with questions and concerns which needed answering and naturally that would take a long time to answer all of them. But that is what the community consultation is supposed to be for. It was like the MIT group were trying to dodge the issues and not face the facts that this proposal is inappropriate for Moorebank on so many levels.

The phone book size of each technical EIS relating to the various fields of study is too much information for the everyday person to read and comprehend and therefore makes a detailed technical submission very difficult to produce.



NOISE

Moorebank Intermodal Company state that some mitigation will be required to protect residents of Wattle Grove and Casula from substantial noise levels. I question the words, "some mitigation" due to the fact that residents who live in the suburbs that surround the Port Botany Container Terminal have for some time suffered from sleep disturbance. The noise created by the terminal is so loud that people living up to 3 kilometres from the SITE are being kept awake of a night.
What hope do MICL have of mitigating the noise level on those residents living as close as 400 to 900 metres from their facility. "They are certainly with the fairies"

The EIS states "Negligible increase in noise levels from 8160 trucks, 5724 small vehicles and 39 freight trains per day". How can this be so? Especially to resident living within 400 metres from the site.



POLLUTION

Base line studies for air pollution need to be accurate and based on a wide selection of the community. The testing stations should be placed in schools, child care centres, aged care facilities, local streets, parks etc. The figures should be made available to the public via a website and should be updated on an hourly/daily basis as they do in Japan so the public is warned when the pollution levels get too high for people to be outside for too long.

THE FUTURE

Ian Hunt said during the community consultation that MICL are in negotiations with SIMTA as the preferred operator of the terminal. Whether it is SIMTA or another company that ends up operating it, MICL plan to sell it regardless he told us.
It has also been stated in an MICL booklet that "the plans will be revised by the terminal operator so the final design is likely to be different from the concept plan".
Does this mean that the operator of the terminal will not have to strictly stick to the design features that MICL have said will:
1) mitigate or control the noise
2) mitigate or control the traffic congestion
3) mitigate or control air pollution
4) enhance the community or be beneficial to the community ie in relation to aesthetic appeal or number of predicted jobs

MICL will set the guidelines or recommendations as stated in their EIS, Project Plan and Approval Stage Processes that are intended or estimated (note: not guaranteed) to mitigate (note: not remove) any negatives as a result of the operation being built to their plans. If this isn't terrible enough for the nearby residents or commuters to accept, there is no guarantee that the future operator, as a business trying to save money, will strictly follow all of the recommendations made in the EIS. It is expected that as a company trying to save money, that they will cut corners at the detriment of the nearby residents and commuters of South Western Sydney.

Who will monitor their movements and practices?

How will statistics such as air and noise pollution be monitored and made available to the public?

Can we trust this information to be an accurate representation of the area? Even the EPA get things wrong-this fact was displayed recently when noise pollution figures at Port Botany were shown to be incorrect and the local residents within a 3 km radius were affected

Who will be responsible for all the noise, pollution and traffic accidents due to the operator not sticking to the guidelines set in the EIS?

Who will be responsible for all the noise, pollution, traffic congestion and traffic accidents due to the experts in their field that have carefully worded their part of the EIS by using weasel words and phrases such as "expected to", "not expected to", "likely", "unlikely" etc to remove any responsibility from themselves once the negative impacts actually begin to take place?

"Mitigating the impact" will not "remove" the negative impacts this intermodal will produce if built at Moorebank which are far too many in number to make this proposal a viable and fair project to go ahead with.

An MIC booklet states " Most of the vehicles using the terminal...are expected to enter the terminal from , and exit to the north....Entrances to the terminal will be designed to prevent trucks travelling to/from the south".
To me this does not give any guarantee to what they are implying because it is only "expected to" (not guaranteed) and "will be designed" (does not mean will be built that way).
This sort of terminology throughout all of the documents does not give the local residents and commuters any sense of security as to what they can expect in the future should this monstrosity be built.

On the same page, "the terminal is likely to have a small impact on vehicle speeds on the M5 Motorway, Hume Hwy and other roads near the terminal. Some local intersections may experience a slightly longer delay time. These impacts will be further investigated in the EIS for the terminal's project approval".
This message is subjective. The words "small" and slightly longer delay time" might mean something totally different to the roads expert writing the EIS verses the commuter who uses the local roads on a daily basis. I also find it hard to believe that only small increase in delay at intersections will be experienced as a result of the terminal's operations in the year 2030 given the volume of vehicles expected to use this site on a 24 hour basis..


Who will pay for all the upgrades to the roads (not on Moorebank Ave) that will be required should this intermodal go ahead? I can see a blame game will start to occur and nothing will get done and commuters will suffer.
Upgrades to roads from Anzac Road to Newbridge Road via the intersections of Wattle Grove Drive, Nuwarra Road, Heathcote Road, Brickmakers Drive have not been mentioned in any literature. Trucks and smaller vehicles will use these roads and nothing has been said about upgrading them to cope with the traffic generated from the intermodal.


Other more appropriate locations have been suggested but everyone seems to be turning a blind eye and going with a poorly considered and ill-conceived plan. Badgerys Creek and Eastern Creek do not cause the same impacts and would make far more sense.

--------------------------------------------------------------------------------------------------------------------------


POLLUTION
Placing a heavy industrial facility in the middle of a residential area is negligent and will be detrimental to our community. The proposed site is located in a basin which allows pollution to lie, rather than easily move away. The NSW Planning and Assessment Commission have already recognised that the air quality in the Liverpool area is generally well below guidelines. Additional diesel emissions and particulate matter released from this proposal will prove dangerous for residents, especially children and the elderly.

TRAFFIC CONGESTION/INFRUSTRUCTURE REQUIREMENTS
The M5 motorway and surrounding roads in the South West Region are already suffering from chronic traffic congestion and this will significantly worsen with the 10,000 additional truck movements per day expected from the new Intermodal - that's an extra truck every 8 seconds, 24 hours a day, 7 days a week. It will also mean $750 million worth of works will be required on major road and rail connections to accommodate this outdated proposal.


LOCATION
MOOREBANK may not the best place for two proposed intermodal freight terminals, the Leader of the Government in the Senate, Eric Abetz, has conceded.
During a community meeting in Wattle Grove Senator Abetz said that he supported Liverpool Council's campaign to have the terminals relocated to Badgerys Creek.
"The proposed intermodal, which may have been a good idea all those years ago, is no longer a good idea," he said.
Senator Abetz said something that might have been a good idea 10 or 15 years ago was not necessarily a good idea today.
"A good government, I believe, should always be open-minded and should always be flexible," he said. "I happen to agree, that with the current financial status we face as a nation, any decision we make should be looking at the best economic opportunity.
"From what I have heard there is apparently no doubt. That is the message I will be taking back to my ministerial colleagues, that putting an intermodal here, on the face of it, would be extremely inefficient."

The good news is that there is a smart alternative, and this is to build the new Intermodal at the site of the new international airport at Badgerys Creek. Here, it can connect with existing and planned major transport routes while also reducing traffic on our roads.

Badgerys Creek is the better option

It is located where $3.5 billion of new roads and rail lines will be built for the new airport and will save tax payers money
It is big enough to handle the 1.1 million containers each year with room to grow in the future
It would save money as the road and rail upgrades needed for the Moorebank plan would cost more than $750 million.
It will reduce truck traffic in a highly populated residential area, protect air quality and the local environment around the Georges River from permanent degradation, leading to better health outcomes
It is closer to the industial and freight markets of Western Sydney
Badgerys Creek is already owned by the government
The sale of land at Moorebank could raise more than $482 million to fund an intermodal at Badgery's Creek and would house 40,000 people
DEMAND OR NEED FOR AN INTERMODAL AT MOOREBANK
Existing intermodals in Western Sydney have the capacity to expand. The economic viability of the proposed intermodals at Moorebank have already been questioned by the industry (se Asciano challenges freight hub, SMH, July 2, 2014). The PAC's decision to limit the operational capacity of the Moorebank site further calls into question it's viability.
Any intermodal at Moorebank will attract heavy competition from Chullora intermodal in which $112 million is being invested to expand it's capacity to 600,000 TEUs per year by 2015. It is reported that there is further potential to increase capacity at Chullorato 800,000 TEUs per year and the Enfield intermodal is expected to accept up to 300,000 TEUs per year.
Development of the proposed intermodal at Moorebank will take considerable time as it involves the construction of complex rail spurs and intersection upgrades. Chullora and Enfield could address Sydney's freight problems in the short term leaving room to plan for the Badgerys Creek option.

Decades ago, when Moorebank was put forward as the site for the Intermodal, Sydney was not facing a chronic housing crisis and cities didn't value their rivers like we do now. If developed into premium riverside homes, the Moorebank site, worth $482 million, has the potential to help alleviate the current housing crisis identified in the Metropolitan Strategy for Sydney.

A plan to revitalise the Liverpool area by embracing natural assets, such as the Georges River, and utilising land to its full potential presents an opportunity to lift the socio-economic status and improve overall health in the area. Liverpool should be considered as a prime location for the government's Liveable Communities Programme which has been successful in other locations.


MORE REASONS AGAINST AN INTERMODAL AT MOOREBANK

Political leaders Local, State and Federal agree that the intermodals should not be at Moorebank for so many reasons.
Just ask Craig Kelly MP, Melanie Gibbons MP, The Mayor of Liverpool , Ned Mannoun and now Senator Eric Abetz.
Craig Kelly MP and Melanie Gibbons MP have made informative speeches in their parliaments outlining why an intermodal at Moorebank is the wrong thing to do. As not many people were in the house at he time to hear these speeches I feel their message is not getting through to the decision makers. Copies of their speeches displaying just some of the evidence as to why Moorebank is the wrong move can be found on the Hansard records.


In Craig Kelly MP's words in Parliament of Australia:
Mr CRAIG KELLY (Hughes) (17:45)
Tuesday, 16 June 2015
Page: 59
"By having an intermodal at Moorebank instead of at Badgerys Creek, we are losing one of our abilities as a nation to fund the railway line into Badgerys Creek. The member for Grayndler emphasised the importance of building that railway line, but our funding is not unlimited. By investing in Moorebank--by pouring Commonwealth money down the toilet in Moorebank--we are simply making it harder and harder. That money should have been put into the rail link to get it set up at Badgerys Creek.
That draws me to an article that I came across after reading an article by Nick Cater today. This article is called 'Policy and planning for large infrastructure projects: problems, causes, cures'. It is a World Bank working policy from December 2005, and it talks about the exact problem that we have with Badgerys Creek, the 'planning fallacy'. It says:
... a major problem in the planning of large infrastructure projects is the high level of misinformation about costs and benefits that decision makers face in deciding whether to build, and the high risks such misinformation generates.
This is exactly what we have at Moorebank. It goes on, and it cites examples of how forecasts for rail projects have failed. It does a study across different continents, and for rail transportation infrastructure projects it finds the cost overruns, averaged across more than 50 projects, are 44.7 per cent measured in prices. It finds not only that the cost is more than 40 per cent higher but that the actual passage of traffic is 51 per cent lower than predicted. We have seen this in Sydney with our planning debacles: the Cross City Tunnel and the Lane Cove Tunnel. We have seen this in Brisbane. The article goes on:
84 percent of rail passenger forecasts are wrong by more than ... 20 per cent.
9 out of 10 rail projects have overestimated traffic.
Again, this is what we are at risk of seeing at Moorebank. It goes on to ask why this is happening, and it says:
In the grip of the planning fallacy, planners and project promoters make decisions based on delusional optimism rather than on a rational weighting of gains, losses, and probabilities. They overestimate benefits and underestimate costs. They involuntarily spin scenarios of success and overlook the potential for mistakes and miscalculations.
That sums up the Moorebank Intermodal to a tee. It also gives a warning about how to overcome this. It says:
The key weapons in the war on ... waste are accountability and critical questioning.
That is again the problem that we have with Moorebank. There is simply no answering of the critical questions. There are three completely failed premises: it takes trucks off the road, it reduces air pollution and it saves costs. Any critical analysis of those three premises shows that they are completely faulty. In the Moorebank Inter+

Exhaustive environmental and economic studies must be conducted. I do not believe this has been properly addressed. In fact, I am appalled at the "find results to match the desired outcome" method of the whole process.

Citizens' concerns about air quality have been pooh-poohed. One morning, attempting to cross Newbridge Road near Moorebank Avenue on my bicycle, I had to get off my bike because I was about to faint. I had to walk carefully because I was gagging and woozy. I could taste the exhaust fumes in my mouth. I eventually made it to Light Horse Bridge, where there was a bit of air movement and I was able to get back on my bike. This is OK by you? And we don't have an intermodal yet!

The river is sick and filthy as it passes through Liverpool. Hardstand developments should not be built on the banks of rivers. All over the world, waterfront land is being reclaimed from industry and returned to the people. Why is Liverpool being treated as if it were a third world country?

The fundamental appropriateness of this development has never been examined. It is not appropriate because it is on the banks of the river, in the middle of residential areas, surrounded by schools and cultural centres.

The traffic will not function. You are talking about traffic volumes exceeding Sydney Harbour bridge. Think about the support infrastructure around Sydney Harbour Bridge. This is what will need to be built in Liverpool in order for the intermodals to function. Neither State nor Federal governments have signed up for that. Why is this so hard to understand?

The social, health and economic disbenefits to this community have not been addressed.

The newly-built Enfield intermodal still has not commenced operation. Why is there a problem getting someone to operate it? Could it be that it is not economically viable? It is only a stone's throw from Chullora, who have just doubled their capacity with the introduction of new technology. If they cannot even get Enfield up and running, why on earth are you considering opening another at Moorebank?

It should be built at Eastern Creek for now, and Badgery's Creek down the track.

I am appalled that reason has had to date so little influence on decision making.

I oppose the Moorebank Intermodal Terminal for the following reasons:
* The proposal should be relocated to Badgerys Creek in order to reduce supply-chain costs and cater for future urban growth.

* The proposal will move the congestion from Port Botany to Moorebank, which is already congested;
* Trucks parking and taking short cuts through the nearby streets will make the area unsafe for me, my family and friends.

Noise
There is no noise wall along the rail corridor along the Georges River, so noise will carry, particularly at night. Residents up to 3km from Port Botany are kept awake at night, I don't want this for my family.

Air quality
* There will be increased diesel fumes in the community generated from locomotives, heavy vehicles and other heavy equipment used on site. These fumes are carcinogenic;
* South West Sydney is already heavily polluted due to the topography of the area;
* There will be dust and odour generated from this site, particularly during the construction period.

Health
The government should not plan industrial development in a residential area.

Heritage
We have a strong military history in this area and we are proud of our heritage. Removal of heritage features from the site will break ties for the community.

Location
This area is a quiet, leafy suburb with strong community connections,
* This development will be detrimental to the area and depreciate its value; and
* Other sites are preferable, such as Badgerys Creek, which does not have a residential development nearby.

Contamination
* The unloading of imported containers in this area will have the potential to destroy native flora and fauna; and
* The unloading of imported containers in this area will have the potential to destroy the Georges River.

I am a resident of Casula and overlook the old Casula Links Golf Course next to the Georges River. I object wholeheartedly with an Intermodal being built at Moorebank. Not only is it in the wrong place to build this in general, it will impact me directly and so many others.. As I live up on a hill overlooking this area I hear all noises from that area. I hear when the Army does testing.
The Intermodal plans to build bridges and railway lines over the Georges river for freight trains right in the old golf links that my home overlooks. This is not fair, and will cause me and many people extreme hardship. The people that make these decisions don't care who or how they affect people. This intermodal will affect tens of thousands maybe hundreds of thousands of people in a bad way. The traffic kaos we have already is going to be unbearable, So too will be unbearable the noise, the dirty pollution and emissions from hundreds of trucks in the area and cars that will move so slowly that it will be almost a car park in Liverpool. We Can't have this! property values will drop, quality of life will suffer for all in this area etc etc. This is not the place to put heavy industry, it is so obvious.
.

I strongly object to the Moorebank Intermodal Terminal, I think the terminal could be built in a much better location like at the (new international airport at Badgerys Creek), if the terminal was located at Badgerys Creek airport it would be used to its full potential for not only rail but for road and air, it would connect with existing and planned major transport routes and with the added bonus of the convenient location of the airport which would make the terminal's day to day operation a lucrative one.

If the Intermodal was at Moorebank it will cause more traffic, more noise and more pollution on the already choked M5 and surrounding roads and I do not think these roads are capable of taking any more strain and the choked/gridlocked roads would detrimentally impact the day to day operation of the Terminal. The strain on the environment is also a big concern with more noise and pollution. Please do not make a major and regrettable mistake by putting the Intermodal Terminal at Moorebank.

South West Sydney is wonderful place to live, please reconsider the location of the Moorebank Intermodal Terminal!

Thank you.

I strongly object to this land being used for the development of the proposed Intermodal. Moorebank residents do not deserve this project being dumped in their backyard.
This development and the works associated with it will during construction and upon operation will make Moorebank an undesirable place to live.

Dear Sir/Madam,

Claims that Moorebank Intermodal Terminal will reduce the number of Port Botany containers moved by truck are false. According to the NSW Bureau of Transport Statistics (February 2014), 6.9 million Port Botany containers will be moved by truck in 2046, compared with 1.9 million in 2013. BTS assumes intermodals operating at Moorebank and Eastern Creek.

BTS estimates that 4 million containers will be moved by rail in 2046 , compared with 0.3 million in 2013. This requires building new rail freight lines to Port Botany, and between Chullora and Eastern Creek. For containers that are railed to Moorebank, the road system is unable to sustain any increase in traffic. Already, key traffic intersections are frequently gridlocked.

For these reasons, most of the federal government's business case for the Moorebank intermodal is redacted.

22 June 2015
XXXX XXXX
Wattle Grove
Application Number: SSD-5066

Please find below my submission on the MICL Moorebank Intermodal Terminal.
I would like to firstly state that now that the SIMTA and MICL intermodals have been approved to become one project, I believe that the EIS process should start from the beginning again as this is a totally different, much larger proposal we are now talking about. The original proposal spoke of 2,600 truck movements to your site daily and now that has blown out to 10,000. Of course this will mean a monumental increase in air pollution, traffic, noise, vibration, etc and will impact the people, flora, fauna as well as the river - so much worse than the original proposal. It is immoral to totally change the ballgame part way through and just expect the public to accept the ramifications.
It seems that SIMTA and MICL, as well as the government, have not listened to the residents at all. So much for the community consultation sessions held by both parties! None of our concerns have been answered. All we hear constantly is talk of mitigation but nobody can tell us how the effects of the intermodal on our health, traffic, etc will be mitigated. I am firmly of the belief that none of our concerns will be mitigated as there seems to be no way of doing so. I believe that the community consultation has just been a matter of ticking boxes that you've held these sessions as there has been no evidence you have listened to us and taken any action in relation to our many concerns.
It seems that the only reason the intermodal will be built at Moorebank is its proximity to the M5, M7 and the current freight line. This seems to override the fact that there are 39,000 people living in close proximity that will be impacted on severely by this intermodal. This is not a good enough reason, in fact there is no good enough reason to put the lives of people at risk and that is what you are doing. There have been several excellent suggestions for better locations such as Eastern Creek, Badgerys Creek and even Newcastle. These areas have much lower housing density and so not nearly as many people will be impacted. Eastern Creek, in particular, is a good area since it has been proven that 45% of the containers are destined for Western Sydney, not South Western Sydney (where Moorebank is). There is significantly less industry at Moorebank so it just doesn't make sense to put an intermodal here. I've recently heard that a new freight line will need to be built in any case so the freight line can be built to Eastern Creek. This will make much more sense than sending containers by rail to Moorebank to be unloaded, only to the have the last (and largest part of the journey) to be made by truck anyway to its end destination - double handling much? This is NOT taking trucks of Sydney's roads is it? Also since Chullora's site has now increased its capacity from 300,000 to 600,000 there is certainly no rush to build an intermodal as soon as possible.
It has also been shown by local traffic modelers that at least 32 intersections would need to be upgraded for the intermodal to work as the area is already at capacity in regards to traffic. You are only suggesting upgrading Moorebank Avenue up until it reaches the M5 motorway and not even this will happen until 2029/30. Your trucks will be going NOWHERE and neither will any of the residents. In a speech on the intermodal proposal made by Melanie Gibbons in the Legislative Assembly on 4 June, Ms Gibbons made the following statement, "I have read through the information provided by the company for the next period of community consultation. It says that, should there be an accident on the M5 or Moorebank Avenue, the facility will need to close while the accident is being cleared". This is not an efficient way to run a business and just highlights one of the reasons that an intermodal cannot work at Moorebank.
There is also a huge problem with noise. There are residents at 3km away from the Port Botany terminal that are having major sleep deprivation issues so how can residents as close as 400 metres to the proposed Moorebank site supposed to get any sleep? There is also the issue with the poor people who live near the freight line at Casula who are already experiencing sleep deprivation problems and now you want to increase the number of trains that go past them every day and every night. This is just inhuman!
Air quality is a huge issue and one that I am particularly concerned about. We know that Moorebank is in the Sydney basin and, therefore, pollution is already higher. The PAC SIMTA determination showed that PM2.5 levels in the area are already close or above the advisory criteria. A project of this size can only increase the pollution substantially particularly of the PM2.5 and PM10 cancer causing particulates with the increase of 10,000 trucks per day as well as old diesel trains not to mention the extra cars on the road for the employees. The World Health Organisation likens PM2.5 and PM10 to asbestos. Should the residents and workers of Moorebank and surrounding areas be exposed to this? I think not.
Lastly, I would like to discuss creation of jobs. There have been television programs as well as newspaper articles in the last two weeks showing the further automation of Port Botany and the efficiency this brings about as many jobs have become redundant. We know that a brand new intermodal will be fully automated so there will be very few jobs created for the amount of land used. This land would be much better used as a technology park where many more jobs would be created for the same amount of land.
In summary there are no positive aspects of building an intermodal at Moorebank and I believe if this does go ahead it will be proven in a short time to be financially unviable as well as impossible to operate due to the congestion of the road system in this area.
Yours faithfully,
XXXX XXXX
Wattle Grove resident

To whom this may concern,

My name is Valent Karlusic and I'm writing to you regarding my concerns about the proposed Moorebank Intermodal development. Yes, that includes SIMTA as well - amazing how everyone is confused as to who is proposing what? I, along with my wife Melita and children (Anton - 22 month old boy and Stephanie - 6 month old girl), are the owners of our little dream house in Casula which will be within a mouse's roar (~300m) of the Intermodal's western boundary.

I ask that the following questions be posed to the people in charge of implementing this project:
1) would you allow your children to be subjected to the noise, visual and most importantly of all, air pollution that the massive number of diesel-powered locomotives and trucks will emit once this monstrosity is operating at full capacity?
I hear them all say from the comfort of their homes which are no where near the site "of course I would because the modelling SUGGESTS that nothing will change and if it did, the mitigation measures would protect my family and I from any adverse health effects." Now, looking at the proposed mitigation measures which range from the laughable (instructing crane operators not to `bang' containers together and greasing train bogies to stop squeal!?) to the non-existent (the visual landscape will be obliterated) tells me that this project is a foregone conclusion. Why do I say that? Nobody in their right mind would propose this level of idiocy be rubber-stamped BEFORE all the mitigation measures have been detailed and shown to WORK IN THE REAL WORLD. Not on paper, not on a computer screen as part of a modelling software package, but the REAL WORLD.
2) what financial compensation will I receive when I'm forced to sell my house at well-below market price?
Surely they don't expect that when my front-yard view of the Holsworthy plains is replaced with a few 30m high cranes and 1000's of shipping containers the value of my house will remain the same? What about when a container clangs onto a semi-trailer or the diesel loco squeals into the terminal at 3am on a Sunday morning? I suppose my children can listen to that instead of the relaxing sounds from the Bell birds. Would the proponents of this lunacy pay top-dollar to live in this area once they're finished with it? They wouldn't want to work in that area let alone EAT, SLEEP, RELAX AND PLAY WITH THEIR YOUNG CHILDREN in the area. Even Kingsford Smith Airport doesn't operate 24/7 - yet we're supposed to put up with this forever? Yes, that's right - until we either die or move out. No rest or respite whatsoever. Doesn't sound like a `home' environment, does it?

In short - this is not an infrastructure project that you just plonk in the middle of a couple of residential suburbs. If it goes ahead it will turn out to be one of the most idiotic project implementations' ever. When it eventually dies a slow death due to traffic congestion (do they really think the expected 10000+ semi-trailer movements a day are possible in that area?) the public will crucify (in more ways then one) whoever was involved.

Is it required? Maybe. Actually, if it helps out the rest of the city, then why not? But is it the right area? NO!

Thank you for taking the time to read my submission.

Valent

It is ridiculous to think a development of this size is suitable for this residential area. It will bring more trucks onto our streets with increased traffic to and from the site. It is obvious that there has been no consideration for the residents who purchased in this area well and truly before any type of development had been proposed.
What about our quiet neighbourhood? It will be noisy and dirty.
What about our children and the health impacts? The construction of this site will bring increased dust and pollution to the area alone!
What about the flora and fauna? It will be destroyed and so will the health of the river that is being regenerated!
Take a hard look at yourselves! Would you like to live next to this? I think not!

Political puppets work only for the money not for the people or environment. Persons who recommend the moorebank Intermodal option must be held libel in future for diesel cancer causing agents already identified as being a dangerous killer in people exposed to the vapours. The World Health Org has already exposed and identified these killers. Any person being a consultant, government employee and politicians are now libel for duty of care and will remain accountable in the future when the identified damage to the community manifests itself. With world wide information and research available on the murder by diesel community safety cannot be ignored.

This develoment is in the wrong location. For reasons of health, traffic, environment, economy and social equity. It is ill advised and unfair. It is extremely bad use of taxpayers' money. In this location, it is extremely damaging and detrimental to Liverpool and surrounding region

Dear Sir/ Madam,

We would like to understand if there is likely to be any negative impact on ABB Australia ("ABB") in either getting access to or leaving our site - which is located at the end of Bapaume Road.

Secondly, how will the traffic flow/ management change along Moorebank Avenue and Bapaume Road.

Along our adjoining properties what buildings/ infrastructure will be erected and what trading hours will be it be operational? How will any proposed improvements to these parcels of lands alter the street scape and what will be its main function/ the forecasted increase to vehicular movements.

What major changes will Bapaume Road to be subject to and expected time frame and likely commencement date.

We would like some level of reassurance that ABB will not be adversely affected by the Moorebank Intermodal Terminal or any of its ancillary or allied entities/ functions either when it's in operation or in its construction phase/s.

Obviously, this is not intended to be an exhaustive reply, but rather one to help us better understand what "the neighbours are doing".

I refer to the noise assesments part of the Environmental Impact statement. I have these queries and would like a response.

- Section 7.4 of the Noise and Vibration Impact Assessment (SLR, October 2014) states "It has been assumed that all equipment will be designed to control potential noise characteristics of tonality, low frequency and impulsivity. No modifying correction factors have been applied to the noise emission sources or predicted noise levels.". Seeing as though the terminal will be unloading trains using a rail mounted gantry train, the nature of the noise is expected to be highly impulsive and / or low frequency or tonal, and modifying factors from the Industrial Noise Policy should be applied accordingly. This would result in an increase of predicted noise levels of up to 10dB, and according to Table 50 of the report, reduction requirements of up to 23dB at Full Build. This would be an unachievable reduction and would result in large exceedances of project noise goals, even with all feasible and reasonable mitigation measures in place.
- Sleep disturbance criteria are presented in Section 5.4 of the report but these criteria do not apply to rail traffic noise, as stated in the sleep disturbance assessment in Section 13. Nonetheless, they do provide context for the magnitude of sleep disturbance that nearby residences will experience. Sleep disturbance criteria of 48dB(A) is established for Casula. A design criterion of 80dB(A) LAFmax has been adopted for the SSFL, as stated in the sleep disturbance assessment in Section 13. The proposition that noise reaching 48dB(A) from an industrial source is likely to cause sleep disturbance, but rail noise below 80dB(A) will not is unreasonable. Sleep disturbance criteria stated in Section 5.4 should be applied to all noise sources as the source of noise plays no role in the level of disturbance to sleep. To this end, LAFmax levels of up to 86dB(A) are predicted at the nearest receivers in Casula, 38dB above sleep disturbance criterion presented in Section 5.4. These levels indicate a high level of daily disturbance will affect sleep in a large number of residences in the area.

--------------------------------------------------------------------

Large communities will suffer.

-----------------------------------------------------------------------

I strongly disagree that Moorebank is the right place to locate "Australia's biggest intermodal freight project". There are homes and communities which are only short distances from the planned facility. This is currently a nice quiet neighborhood, should the intermodal project proceed, trucks and container movements will be heard from kilometers away, destroying our community's peace, environment and property value. Such a project should be developed in an industrial area such as Eastern Creek, Badgerys Creek or similar.

Please consider the communities in surrounding areas - Moorebank is NOT the right location for this project.

SIMTA's traffic modelling shows that the capacity of the local road network is 94,941 ''passenger car unit'' (PCU) trips per day and that this capacity was exceeded in 2010. In 2030, estimated traffic demand on the local road network will exceed capacity by 53 per cent, comprising future background traffic growth of 19,625 PCU and intermodal traffic of 30,204 PCU.

How will a ''planning process'' address a 53% deficit in local road network capacity?


I object to the proposed freight intermodal(s) at Moorebank/Wattle Grove.

The proponents and governments should have more respect for the health of local residents with 39,000 living in a 2km radius and 100,000 in a ten kilometre radius not counting the many hundreds of thousands who live in the area from Port Botany to Liverpool and the general area the Locomotives operate to.

Our Children's Health will be Damaged by the Pollution and Pedestrian Accidents - with 10 Schools and 19 Childcare Centres within a 2,000m radius of the proposed development. You will Kill many.

Please see attachment regarding how Diesel pollution Kills and Damages.


I writing to object to the proposed freight intermodal(s) at Moorebank/Moorebank.

There are Huge problems with the proposed Intermodal at Moorebank including Environmental, Social, Engineering and Economical which need to be addressed. Moorebank is unsuitable because there are too many Government Sponsored projects all in the one place such as Sydney South West Freight Line, Widening of Moorebank Ave, Spur Line Construction from SSFL, Major Ramp Construction to M5 off Moorebank Ave, Noise barriers and MORE. Any assessment should be of ALL the Imminent Projects to judge the TOTAL Damage to South West Sydney!

Most importantly, Liverpool is a deep basin so Diesel Fumes do not easily leave the Residents HOMES that surround the proposed 2 Intermodals! Compensation costs for Diesel Pollution will be Huge! Experience from other Inland Intermodals in America prove Increased Asthma, Cancer and ultimately Shorted Life Spans from Diesel Fumes.

The Federal Ministry of Infrastructure and Transport are doing the wrong thing by stating that the Moorebank proposal will remove Trucks off the roads in the Eastern Suburbs around Port Botany when it's just to suit the politics of that area. It will just move the problem to a worse situated are.

Liverpool Council is against the proposed 2 Moorebank Intermodals and wants it instead placed on the Government owned land at Badgeries Creek (in another part of Liverpool). Penrith City Council also wants it moved to Badgeries Creek.

Widespread opposition has been demonstrated by the fact that Residents of Liverpool have DEMONSTRATED against the Moorebank proposal.

Yours Sincerely,

Dominic Scutella
118 Daintree Drive
Wattle Grove
NSW 2173
Phone 0408 9731 97


We are against the SIMTA proposal for an Intermodal at Moorebank for many reasons:

* The EIS should be completed on the total number of projects proposed for the area, i.e. Federal Government Intermodal on the Australian Army Engineers site, SIMTA proposed intermodal as well as the SSFL since the effects will be felt of the total projects that are proposed not just the SIMTA proposal. Anything less does not give an accurate picture of the outcome.

I could not find any information that referred to the cumulative effects on air quality, noise and traffic that would occur from both the SIMTA proposal and the widely known about Moorebank Project Office proposal operating simultaneously. This renders any information on SIMTA's EIS inappropriate, inaccurate and does not tell the true story. This is misleading and unfair to the people of Liverpool and to anyone that uses this area whether to travel through it , provide serices or use services provided by the area.


ROADS AND TRAFFIC

-Impacts to Traffic should be considered including the exiting and entry of trucks to and from the site and the deadly impact this will have as these trucks attempt to merge onto the M5 with traffic travelling at 100kph. Trucks merging from Moorebank Ave onto the M5 travelling towards the M7 will inevitably cause accidents as those already on the M5 travelling in the same direction swerve to avoid them or simply crash into the back of them. Also as cars travelling in that same direction on the M5 try to merge into the far left lanes in order to get onto the Hume Hwy whilst trucks from the SIMTA intermodal are merging from Moorebank Ave onto the M5 travelling towards the M7, accidents are inevitable. For these scenarios to be mitigated would possibly mean lowering the speed limit on the M5 for that area or building complexed and expensive underpasses, overpasses or tunnels. Not enough information has been provided in SIMTA's EIS regarding mitigating or providing solutions to such matters. Any information provided is vague and does not display who would be responsible implementing for such action.

In Appendix N, SIMTA say " M5 Motorway/Moorebank Avenue interchange. The analysis has suggested the need for additional capacity improvements in the form of widening at the following ramp locations including:
 M5 westbound off ramp;
 M5 westbound on ramp;
 M5 eastbound off ramp. "


My comment to this remark by SIMTA is............
This action is insufficient to prevent accidents such as those I have mentioned above from occurring. SIMTA boast about all the widening and work they recommend will need doing on Moorebank Ave but have not addressed the crucial aspect of the traffic accidents on the M5.

- "SIMTA supports all measures to stop trucks driving through local
streets on the way to and from the intermodal terminal."


My question is to this remark by SIMTA is............

What will it do to implement procedures to prevent trucks from using local streets? How will it follow through, monitor and carry out these these procedures? What are the so called local streets specifically? Please name them specifically?

- there will be a huge impact to the residents living close by as well as a significant impact to all people living within a 10km radius of this site. The location is within very close proximity to houses. How would anyone expect our lives to be with all the air pollution that would be generated, the noise and the light 24/7. Not discussing the rail impact, our streets are already very congested and as it stands now it is almost impossible to go on the local roads during peak hours let it be with 2000 trucks more. The M5 is already over full capacity during these peak hours and roads in the surrounding areas of the proposed Intermodal would become gridlocked.

- I am glad that 3300 trucks are taken off the road from Botany to
Moorebank Avenue. But how wrong is it to put 3300 trucks back on the
road from Moorebank Avenue in an existing pollution basin. The truth behind this simple fact has been hidden by SIMTA as well as the Moorebank Project Office from the beginning of these proposals.
With up to one million trucks expected to enter and depart Moorebank Ave to and from the SIMTA terminal annually, many of them using the M5....How is this NOT due to the SIMTA freight terminal???
How can they say that this number of trucks they intend to bring to the Liverpool area will not increase truck movements on the M5? It may be on a different section of the M5 ie between Moorebank Ave and the M7 junction but the same number of trucks and more will still be using the M5 due to the fact that goods must be delivered from Moorebank to the warehouses in the west and south west of Sydney.
I feel the Liverpool community are being fed lies by SIMTA to avoid conflict with residents on their proposal.

SIMTA have said "Moorebank Avenue will be assessed to investigate if it would support increased truck traffic to and from the intermodal terminal.
Appropriate upgrades would be implemented as required.''

My question is to this remark by SIMTA is............

When will it be considered appropriate to upgrade the road? At what point? When is the right time and when is it too late? How will this progress or regress be measured?


-"Together with the Moorebank Avenue widening, roads
approaching the traffic lights at Moorebank Avenue/Anzac Road
may also need to be widened.''

My question is to this remark by SIMTA is............

Is this to accomodate trucks turning on and off Anzac Ave? I thought the trucks will not use Anzac Ave according to previous satatements by SIMTA. Are these more lies?


AIR QUALITY AND PEOPLE'S HEALTH
Air Quality is really important. Australia has one of the worlds highest incidents of Asthma. Residents suffer from many other lung complaints as well. Any degradation in air quality will make these conditions worse. Every truck that they take off the road at Port Botany will have to start at Moorebank, queuing with its engine running, pushing pollution into the air.

Air Pollution has really serious health effects. Studies show the following:
* Air Pollution from busy roads shortens life expectancy
* Asthma symptoms (and childhood hospitalisations) caused by truck exhaust
* Babies are more likely to be premature or have low birth weight if mum lives near high traffic areas
* Respiratory symptoms in two year olds linked to Traffic
* Asthma more common in children who live near freeways
* Children (and people generally) who live near busy roads are more likely to develop cancer
* Air Pollution causes more traffic related deaths than accidents
This link has an index of relevant studies from the San Diego Earth Times.

Another study http://www.ehjournal.net/content/6/1/23 talks about the Cardiac and Pulmonary effects of living in close proximity to pollution.

Specific questions to be addressed in the terms of reference should include;
a) what increases in PM10 and PM2.5 will occur at different locations in the local environment, arising from all sources related to the proposed Moorebank
Intermodal Terminal Facility
b) what increases in PM10 and PM2.5 will occur at different locations in the local environment, arising from the combined effects the proposed Moorebank
Intermodal Terminal Facility and the Department of Finance Intermodal
terminal project.
c) Will the increases in PM10 and PM2.5 arising from the Intermodal developments push the levels of PM10 and PM2.5 (in any location) above the guidelines set by the World Health Organization.
d) What, if any health effects are likely to occur in the local population resulting from increases in PM10 and PM2.5 levels associated with the Intermodals.
e) What are the economic costs (loss of productivity, cost of health care, etc) of any adverse health effects.
f) If the proposed Intermodal facility was to be located in another area of Sydney,what PM10 and PM2.5 levels would result in these other local areas.


- The proponents of the massive terminal complex at Moorebank say that residents won't be impacted by noise, but residents are not convinced.

Overseas, authorities acknowledge the noise impacts on local residents. The Port of Houston Authority in Texas has offered $US40,000 "mitigation payment" per house for houses as far as 920m (Baywood Ave Shoreacres) from the Bayport Container Terminal so home owners can install soundproofing.

You can read all about it here.
http://www.bayportmitigationsolution.com/

- In 1997 the Holsworthy Airport proposal was scrapped, one of the reasons being that the air pollution would adversely affect the region. 15 years later that population is now substantially bigger and more people would be affected by a much bigger proposal. The location is the wrong place for such an operation


- Since pollution in the area is already high compared to a lot of areas in Sydney any increase in pollution must be considered to be dangerous and must be monitored in full and in all conditions. Any adverse findings must be reported and remediated including fines and/or criminal penalties where applicable.

- There has been a mountain of research from all over the world that diesel emissions cause great problems to residents even short term exposure.It effects the brain lungs diabetes child birth weight hearts as diesel contains 40 toxic chemicals. And still it appears the ones deciding on these freight terminals are choosing to ignore the facts and the resident's concerns. It is unbelievable that governments and companies can be so short sited when planning such infrastructure in residential areas. Or is it simply neglect?

- The SIMTA construction has been noted as extending over a period of 12 years and some of the equipment used will bring noise levels of 122 dbs /. Also it is noted that they say that freight trains will bring sound levels of 41-45 decibels along Casula Liverpool when residents have been complaining about excessive noise levels up to 97 decibel. Also I have noted that the receptor pollution points are in areas that doesn't represent the levels of pollution in heavy industrialised areas. It has been recorded in the Local area pollution rate of 20.22 which is over the world health organisation (WHO) maximum of 20. It can only get worse with the growth of freight numbers.



OTHER ISSUES

-"Operations at the intermodal terminal would schedule truck arrival
times to minimise queuing.''

My question is to this remark by SIMTA is............

And what about when there is a hold up between Port Botany and Moorebank via the M5 which occurs frequently or at Port Botany itself? Schedule times will mean nothing. This may unfortunately for the Wattle Grove residents produce poisonous diesel emissions in their living spaces as the trucks are forced to queue on nearby roads. Many will leave their engines on to use their airconditioning in their cabin as they wait.




- The threat of terrorist attack on the Intermodal site including freight and infrastructure. With only 3% of containers currently being checked for illicit and illegal goods how can we be certain that terrorists will not attempt to attack and cripple Sydney's Freight flow, particularly as it seems that the Government is concentrating all of the freight flow into 1 or 2 narrow freight corridors.


- The potential for an accident with unknown container contents spillage or leaking into the George's River, local watertables, soil or air is of concern


- The potential for an explosion resulting from an accident or careless handling of containers resulting in damage to resident's homes and other surrounding infrastructure.



-Most of the 13,000 families within 2km of the container terminal are paying off a mortgage and they are worried about the effect of having a huge container terminal appear next to their house.
Houses next to terminals drop in value, a lot. Local residents don't deserve a slug like that.
What compensation will be on offer for residents within the 2km zone from the Intermodal?




- Why is the Crime and statistics of the suburb of Moorebank studied so heavily when in fact the planned intermodal lies closer to the residential areas of Wattle Grove and Casula than it does to the predominant residential area of Moorebank? It seems Wattle Grove and Casula have not been considered in the planning and the social and health requirements of these suburbs will not be considered by SIMTA.
I realise this is not part of the DGR but it just shows SIMTA's attitude and disregard towards the local residents.


- Nowhere in the planning for Moorebank complex has there been any mention of compensating residents so they can insulate themselves against noise or top up their mortgage so the drop in property value doesn't leave them with negative equity.


- I have to remind the planners of these Intermodals both Federal and Private that flooding of the Georges River is of great concern.
There have been numerous times flooding has occurred along Newbridge Rd near Flower Power and heavy rain in a short period can cause flooding along Newbridge Rd which has the Georges River at 2 points near the area.
With heavy rain recently part of the area has been flooded and to believe you could operate a freight hub with such uncertainty beggars belief and if the flooding occurred it would cause great damage and inconvenience to the SSFL freightline and the transport of diesel trucks along Newbridge Rd , Moorebank Ave and other heavily patronised roads.

Can you please listen to these concerns and reply with a personal response?

Our community would appreciate the chance for your group to meet with us to discuss these and other concerns.

Kind Regards,

Dominic Scutella
Phone 0408 9731 97
118 Daintree Drive
Wattle Grove
NSW 2173


The Environmental Impact Statement prepared by the Moorebank Intermodal Company (MIC) states that the proposed Moorebank intermodal will allow imports and exports to grow through Port Botany. This will mean additional traffic on the already congested road network. 10,000 heavy vehicles per day will need to access and leave the terminal utilising the M5 and local roads.
The MIC state that an additional intermodal is required to reduce supply chain costs; however, it is questioned how the proposal at Moorebank will assist in reducing these costs. The proposed terminal in Moorebank will include transferring freight by rail less than 25 Kilometres from Port Botany, while increasing the handling costs of the supply chain with containers having to be loaded and unloaded multiple times in a very short distance. Infrastructure NSW has also questioned the viability of short haul freight and the funding of additional intermodal facilities until this has been properly investigated. That being the case, the increase in capacity at Chullora should be investigated with proper planning for a true intermodal at Badgerys Creek. Jenny Wiggins, in her Sydney Morning Herald article, states that Asciano is primed to invest $112 million to `compete "vigorously" with its own intermodal terminals', for example Chullora, and challenge the Moorebank intermodal essentially casting doubts over the economic viability of the Moorebank site (Wiggins, J., 2014, `Asciano challenges Moorebank freight hub', Sydney Morning Herald, 2 July 2014).
To truly reduce supply chain costs, the intermodal location should be moved to Badgerys Creek, a facility more than 40 Kilometres from the Port with access to key roads such as the M7 and the proposed M9. This location will also have the capacity to support future growth centres. The M9 motorway will provide `a direct link between the Central Coast and the Illawarra, connecting the growth centres of Camden, Penrith and Windsor' (O'Rourke, J., 2014, `What Sydney needs to transport us to the future', Daily Telegraph, 3 November 2014). An intermodal at Badgerys Creek demonstrates good strategic and growth planning.
Why Badgerys Creek is a better location than Moorebank
The MIC, in their Environmental Impact Statement, attempt to describe why Moorebank has been selected as a location. However, Badgerys Creek is better suited to meet the criteria that the MIC has listed.
Badgerys Creek is an ideal location for an intermodal terminal to handle both interstate and import-export freight. This is because it is:
* long enough for interstate freight trains without the need for trains to be broken up and shunted, creating unnecessary additional noise in the area;
* big enough to handle the number of container movements required - up to 1.1 million twenty foot Equivalent Units (TEUs) per year of import-export freight and another 500,000 TEUs per year of interstate freight. This is a greater capacity than the proposed Moorebank site;
* strategically located in an area where a new rail line is planned for the airport;
* near the M7 Motorway, a link to the West and North West where it has been identified by Deloitte that most of the container freight will be headed, and accessible to the M5;
* near the proposed M9 Motorway, providing the ability of the intermodal to service future growth centres;
* near the Western Sydney Employment Area (WSEA), future industrial areas and future freight markets in Western Sydney, where two-thirds of container freight received at Port Botany will be transported.
* further from Port Botany than the Moorebank site, making rail a viable alternative to trucks, and reducing supply chain costs;
* in development, meaning that truck access can be configured into the $3.5 billion already allocated to the surrounding road infrastructure network rather than upgrading roads that are already at capacity in the Moorebank precinct; and
* owned by the Australian Government and available for use consistent with the airport.
Problems with the Moorebank proposal
The Moorebank site constrained by a number of issues:
* The area is already suffering from significant traffic congestion, the addition of an estimated 10,000 truck movements and approximately 5,000 passenger car movements per day will exacerbate this congestion.
* The Planning and Assessment Commission (PAC), following their community meeting on the SIMTA proposal, has identified that the Moorebank area is already suffering from significant traffic congestion. `The community has strongly argued that the proposal is only going to move the congestion from Port Botany to the Liverpool/Campbelltown region. The Commission understands the Moorebank site is constrained by the surrounding residential and industrial land uses and the already heavily congested local and regional road network. If the concept plan were to be approved with the levels of throughput proposed by both SIMTA and MIC, then clearly the community's case is strengthened.' (2014, Planning and Assessment Commission, SIMTA assessment).
* The SIMTA Concept plan was approved by the PAC on the basis that they are limited to 250,000 TEU's, plus an additional 250,000 ONLY if the road network is able to handle the volume of heavy vehicle traffic. This being the determination made by the PAC, and in the absence of a master plan that would have enabled the commission to assess the impact of both proposals as part of the one process, this limit should apply to the operation of both SIMTA and Moorebank intermodal sites combined. TEU's should be limited to a total of 250,000 in this precinct.
* The economic viability of the site has been questioned due to the limits placed by the PAC on the number of TEUs SIMTA can move through their terminal. Chief Executive of Asciano has also questioned the economic viability of the site as previously mentioned, stating that Asciano plan to invest $112 million in their sites to increase capacity and making Chullora more competitive, able to handle an increased capacity from Port Botany, and open for operation before Moorebank (Wiggins, J., 2014, `Asciano challenges Moorebank freight hub', Sydney Morning Herald, 2 July 2014). With the Chullora intermodal capacity increased to 800,000 TEU it will easily be able to support increased in freight through Port Botany while the Badgerys Creek site is planned and constructed.
* The Moorebank site is surrounded by water on all sides. This means that the complex road and rail upgrades needed to service an intermodal in this area will be extremely costly. Liverpool Council has estimated these upgrades are likely to cost in excess of $750 million.
* There are significant problems relating to air quality, construction and operational noise impacts created by the intermodals. A proposal of this size and nature should not be earmarked for a residential area.
* The PAC determination of the SIMTA proposal has already revealed that Particulate Matter 2.5 levels in the local area are close to or above the advisory criteria for this pollutant, this applies to the current background levels as well as the predicted impacts. Additional diesel and liquid natural gas powered vehicles in this area will exacerbate this problem.
* Noise impacts, light spill and air pollution will have a detrimental effect on the local community, some of whom live as close as 400 metres from the site. Residents around Port Botany living as far as three kilometres from the port are affected by these factors; many residents in Chifley for example have been very vocal about sleep disturbance in the online domain.
* The Moorebank site will have a detrimental impact on the Casula Powerhouse Arts Centre. The presence and accessibility of an art and cultural facility in a low socio-economic area, such as Liverpool, is essential for positive community growth.
Problems with the process
The Freight Infrastructure Advisory Board (FIAB) recommended a master plan for the site, this was not undertaken. Residents agree the SIMTA and MIC proposals should have been considered as a single precinct application. This has created an unfair advantage for the proponents with confusion being created among the community with both proponents presenting different figures. The fact that both proposals were assessed separately also means that media attention highlighting the different stages of the planning and assessment process has also created confusion in the community. Coupled with this, the relocation of the Defence National Storage Distribution Centre (DNSDC) and the current construction works at Holsworthy Barracks have also exacerbated this confusion with many people within the community thinking the proposal is already in its construction phase.
Liverpool Council, in meeting with PAC expressed disappointment that a master plan was not undertaken and confirms that this has created confusion within the community `The ad hoc approach .........leaves gaps and inconsistencies in the information available resulting in a lack of transparency and reduced faith in government decision making.'
A master plan would have reduced this confusion and allowed the community to better understand the impacts these proposals will have on their family, friends and neighbours. It would have allowed the community to better refute claims made by the proponents, and have a much greater grasp of any proposed mitigation strategies for this proposal.
The MIC has also created confusion and doubt within the community, adding to a reduced faith in government process and decision making. They have done this first by splitting their figures. Rather than telling the community that there will be 1.55 million TEUs going through the site, they have split these figures between import-export and interstate. And rather than stating that there will be an estimated 297 train movements expected at the site, they have again split these figures to make them sound lower. The Liverpool Leader, in their article `Intermodal company gives community $1m for compensation package but concerned residents aren't buying it', reports on community concerns around the consultation process. This `compensation package' will be completely inadequate to address the impacts this proposal will have on the area, and made MIC seem like it was trying to `buy community support'. At the same time MIC also made a highly publicised donation to the Liverpool Mayoral Ball, which Liverpool Council subsequently rejected (Hansen, N., 2014, `Liverpool Mayor knocks back $5k ball donation from intermodal group but the cash is still destined for charity', Liverpool Leader, 22 August 2014).
An intermodal at Badgerys Creek would not require this level of compensation, as it can be properly planned for a suitable area; it also has residential and council support.
Second, the Sydney Morning Herald in their article `Waterfront baron and Liberal Party donor scored inside running on freight hub tender' has highlighted a possible issue around transparency and due process in the awarding of tenders for the Moorebank precinct. In light of the recent ICAC investigations and the problems faced by the Newcastle community, transparency and due process are paramount in the government decision making process.
Key issues from the community
There were some issues raised by local representatives and the community at the PAC determination meeting on the SIMTA proposal. These have remained largely unchanged in relation to the MIC proposal.
Traffic and access * The proposal will move the congestion from Port Botany to Moorebank, which is already congested;
* Modelling does not include the predicted growth of the region;
* The intersections and road network are already congested, how is it possible for the proposal to decrease traffic delays?
* Trucks `weaving' onto and off the M5 between the Moorebank and Hume Highway interchanges, this is going to cause accidents; and
* Trucks parking and taking short‐cuts through the nearby streets.
Noise * There is no noise wall along the rail corridor along the Georges River, so noise will carry particularly at night;
* Noise from the unloading/loading and movement of containers within the terminal;
* Noise from the breaking and shunting of trains due to the site sizing constraints; and
* Wheel squeal from the trains exiting the SSFL, tight radius curves lead to wheel squeal.
Air quality * Increased diesel fumes in the community generated from locomotives, heavy vehicles and other heavy equipment used on site;
* Health impacts from the increased diesel fumes;
* South‐west Sydney is already heavily polluted due to the topography; and
* Dust and odour, particularly during construction.
Two intermodal
proposals
(SIMTA and MIC)
* There is an ad hoc approach to the two proposals;
* Cumulative impacts of the two proposals have not been adequately addressed; and
* Confusion as to the total traffic generated from the two proposals, as the modelling for each is different.
Heritage * Removal of heritage features from the site, particularly those of military and indigenous significance.
Location * Site is surrounded by residential development; and
* Other sites are preferable, such as Badgerys Creek, which is not surrounded by an established community.
Moorebank Intermodal Company EIS presentation
There was considerable concern from the community over the presentation that was given for the MIC EIS submission. Figures and statistics presented by MIC seemed to be inconsistent and the facilitator tried, on a number of occasions, to ask the community to voice their concerns directly to MIC representatives rather than in the public forum. At each of the three sessions the facilitator kept stating that she was conscious of time; however, the community feel that their questions about a proposal that will impact their family and community deserved an answer, and are more important than clock watching. The number of questions from the community at the final community information session saw the session run over time.
Traffic and Transport
* The MIC recognised that there are significant transport and traffic congestion problems in the Moorebank precinct; however, they claim that the additional 8,160 heavy vehicles and 5,724 cars they predict to be brought into this precinct every day due to an intermodal will not have any further impact.
* The Chief Executive Officer of MIC stated that there would be approximately 1.6 trucks required per TEU. He also stated that 1,400,000 TEUs would be required to leave the terminal by truck. According to this statement, and given that heavy vehicles will have to both arrive and leave from the precinct, the figure of 8,160 heavy vehicles per day seems low, this actually equates to 12,376 heavy vehicles per day. For the purposes of this document the figure of 10,000 heavy vehicle movements per day has been chosen as a more accurate representation of the figures.
* The Chief Executive Officer of MIC also confirmed that the Moorebank intermodal will not take heavy vehicles off the M5 between Port Botany and Moorebank, and that as Port Botany expands the number of heavy vehicle movements on this stretch of the M5 is expected to grow. It should be noted that Labour Minister Anthony Albanese previously claimed that the Moorebank intermodal would take trucks off the M5; this fallacy gained a lot of momentum especially in the media and it has never been publicly corrected.
* Questions were raised by the community about the problem of Trucks `weaving' onto and off the M5 between the Moorebank and Hume Highway interchanges. MIC recognises this as a significant problem.
This `weaving' has the potential to cause a recognised `black spot', with potentially fatal consequences for the community. It is worth noting that a `black spot' is already located at the Nuwarra Road and Heathcote Road intersection, only 2 Kilometres from the `weave' site.
* The traffic modeller for MIC presented information about the predicted impacts on intersections both with the intermodal and without. Intersection surveys were undertaken on Tuesday 7 December 2010, and Tuesday 18 March 2014, in peak hours only. It is concerning that these surveys seem to only have been conducted on two days, four years apart, with the December date being in a peak holiday period.
* A Seven-day automatic traffic count was also conducted from Tuesday 7 December 2010 at only three locations along Moorebank Avenue. It is concerning that four year old data, gathered prior to a number of new and extensive residential developments in the area, is being used as a base for traffic modelling.
* The data presented by the traffic modeller showed a delay of over 200 seconds at some intersections when the intermodal is in operation. A 200 second delay, coupled with a 150-180 second cycle on a normal set of traffic lights is a significant impact (approximately six minutes at EACH set of lights), one that is likely to have flow on effects.
He has compared data, which is based on a scenario where the intermodal is operating with road and intersection upgrades, with predicted data based on no intermodal without road upgrades. This is not comparing like for like. Given that intersections in this area are currently operating at D or E classification (near or at capacity), it is hard to believe that the roads in the area will not be upgraded by relevant authorities to attempt to reduce congestion before they reach an F classification.
* It has been noticed that traffic figures do not take into account the recently announced WestConnex which will have major traffic implications on the M5 during construction; this coincides with the proposed opening date of the Moorebank intermodal.
The WestConnex project also aims to increase Port Botany by 272% more container ships by catering for a greater number of heavy vehicle traffic movements on the M5.
Labour Minister Anthony Albanese criticises the WestConnex `proposal for not going near Port Botany, where it is expected there will be a large rise in the number of container trucks'. He also questions the government's transparency, citing that `the decision to release new information about the impact of WestConnex on Melbourne Cup Day indicates to me that those who support this route are aware of its shortcomings and are keen to avoid public scrutiny.' (Saulwick, J., 2014, `Albanese pans plans for the WestConnex', Sydney Morning Herald, 10 November 2014).
* Residents are understandably concerned about the impact of intermodal traffic on local and residential roads. The MIC confirmed at the community information session that while they can implement some measures for traffic movements, it will ultimately be up to the design of the precinct, the way the precinct operators choose to use the precinct, and choices made by heavy vehicle drivers as to which route they choose to use. With heavy congestion on Moorebank Avenue and the M5, two of the key roads in the area, it is likely that Anzac Road and Cambridge Avenue will be used as `rat runs' for heavy vehicles.
* The MIC traffic modeller recognised that currently 6% of traffic on Anzac Road in the peak is heavy vehicle traffic; however he failed to include any heavy vehicle movements in his trip distribution figures for this road. In current heavy traffic conditions Anzac Road is a very attractive option, as demonstrated when the M5 is congested. Heavy traffic movements on a congested day are far higher than those measured by MIC. The omission of this traffic flow information from MIC data sets is hard to fathom. For the local residents, especially those with houses that back onto Anzac Road, it creates uncertainty and distrust in the accuracy of the information presented.
* The construction of an intermodal terminal at Moorebank shows a lack of strategic planning, particularly in relation to future traffic movements.
* An intermodal at Badgerys Creek will be a true intermodal with road, rail and air access. This area will serve the purpose of meeting the needs of future growth centres. The government currently has the ability to configure appropriate and safe truck access in the Badgerys Creek area with $3.5 billion in funding dedicated for road infrastructure.
Rail access
* MIC has predicted an additional 297 train movements each week, this figure does not include the interstate trains that may transit through the terminal.
* It was unclear how these train movements would impact residents in the area, due to three different rail entry options currently under consideration.
* Due to the length of trains, they will need to be broken up and shunted.
* MIC communicated that the actual rail entry will be decided once a tender for operation of the facility has been awarded. This makes it difficult for residents to understand the impacts of the rail access.
* It is unclear whether rail access will impact the passenger rail line and impact on travel times for people travelling by rail to the Sydney CBD.
* An intermodal at Badgerys Creek will not have the same rail implications. The size of the site will allow trains to remain whole within the terminal without the need for breaking and shunting.
Noise and vibration
* In order to ascertain acceptable noise levels in the area, the MIC have measured ambient noise levels between 2010 and 2011, and then from July 2012 to establish a base index. Approximately 20 of the 34 noise receptors set up and monitored by the MIC to establish this base index were located along train lines and major roads.
* Given that most residents in the area live in quiet, peaceful streets, it is a concern that the receptors set to ascertain the base index for ambient noise seems to have been placed in predominantly noisy locations.
* The residential suburbs of Casula, Wattle Grove and North Glenfield are the closest communities to the Project site; however, these will not be the only locations impacted by the noise generated from the proposed intermodal.
* In a recent article in the Sydney Morning Herald it was learned that `After more than a year of residents around Port Botany being told the night time noises they were complaining about did not exceed "sleep disturbance criteria", the Environment Protection Authority has admitted they were right.' (O'Brien, N., 2014, `EPA admits it was mistaken about Port Botany noise levels', Sydney Morning Herald, 17 August 2014).
* Residents in the precinct are understandably concerned that noise levels will exceed those acceptable. Above acceptable noise levels can have health impacts including: annoyance, sleep disturbance, performance issues (reduced concentration), cardiovascular health problems, hearing problems, mental health effects, and general health impacts (e.g. on the immune system).
* There is currently no noise wall along the rail corridor along the Georges River, so noise will carry particularly at night.
* There is no doubt there will be excessive noise from the unloading/loading and movement of containers within the terminal, which will operate 24 hours a day, as well the breaking and shunting of trains due to the site sizing constraints, and compression breaking of trucks on the surrounding roads.
* Wheel squeal from the trains exiting the SSFL have also been identified, as tight radius curves lead to wheel squeal. The MIC noise analyst has agreed that wheel squeal is likely to be a factor with some of the three different rail entry options currently under consideration. A factor that will apparently be decided once the tender is awarded, a decision that is likely to be economically based with no consideration for the nearby community.
* An intermodal at Badgerys Creek will not have the same noise implications, due to it being located in a purpose built heavy industrial area. The size of the Badgerys Creek site will also allow trains to remain whole within the terminal, negating the need for breaking and shunting of trains. Rail access will not be restricted by the construction of rail bridges over the Georges River, as is the case at Moorebank, reducing the instance of wheel squeal by negating the need for tight entry and exit points. Compression breaking can be limited through planned road upgrades specifically designed for heavy vehicle movements.
Local air quality
* MIC have recognised that exposure to pollutants and particulate matter (PM) can contribute to, or exacerbate, respiratory and cardiovascular issues, including premature mortality and morbidity, in addition to increasing associated hospitalisations. This supports that point that this proposal should not be planned for a residential area.
* Placing a heavy industrial facility in the middle of a residential area is negligent and will be detrimental to the community. The proposed site is located in a basin which allows pollution to lie, rather than easily move away. The NSW Planning and Assessment Commission have already recognised that the air quality in the Liverpool area is generally well below guidelines, particularly PM2.5 concentrations which are close to or above the advisory criteria. Additional diesel emissions and particulate matter released from this proposal will prove dangerous for residents, especially the most vulnerable: children, the elderly and disabled members of the community.
* Diesel fumes and particulate matter are carcinogenic, and as well as causing other serious illnesses, will be fatal for some members of the community.
* It has been identified that diesel locomotives and switch engines are significant contributors of SO2, NOx, PM10, PM2.5 and PAHs, while onsite mobile equipment (ITVs, side picks and forklifts) are the highest contributor to CO and VOC emissions, they also contribute substantially to PM10, PM2.5.
* It is understood the decision about onsite equipment will be made by the tender winner and based on economics rather than community welfare.
* During operation of the Project, combustion engine emissions (i.e. NOx, CO, SO2, PM2.5, PM10, VOCs and PAHs) from locomotives, mobile LNG equipment and heavy vehicles represent the greatest potential for air quality impacts.
* With 297 train movements each week and approximately 10,000 truck movements each day it is concerning that a proposal of this nature could be considered alongside family homes, and close to pre-schools, primary schools, high schools, as well as aged care facilities.
* Badgerys Creek, an Australian Government owned area, is away from residential properties, and therefore not likely to cause the same risks as the Moorebank site. It is also well placed near the M7 and the proposed M9 Motorways, providing the ability of the intermodal to service future growth centres, near the Western Sydney Employment Area (WSEA), future industrial areas and future freight markets in Western Sydney, where two-thirds of container freight received at Port Botany will be transported.
Human health risks and impacts
* The NSW Chief Health Officer's Report (2010) identified that health gains achieved over the past few decades have not been equally shared across the entire NSW population and that there is a gap between those with good and poor health. This gap is exacerbated in poorer communities.
* South Western Sydney has some of the poorest communities in NSW as measured by the SIEFA data (Australian Bureau of Statistics (ABS 2011).
* South Western Sydney has higher rates of people with disabilities than the NSW average. People with disabilities have health conditions which may or may not be related to their disability.
* In 2004 - 2008, South Western Sydney residents had higher incidence of lung, kidney, head and neck, pancreas, thyroid, stomach, bladder, uterus and liver cancer than NSW.
* Mortality rates in South Western Sydney for cardiovascular disease at 83.9 per 100,000 are 5% higher than the NSW average of 100 and are significantly higher in Liverpool LGA (111.4) (2005/06).
* Very high psychological distress was reported by 13.2% of South Western Sydney residents (2.1% above the NSW average).
* As previously noted, MIC have recognised that exposure to pollutants and particulate matter (PM) can contribute to, or exacerbate, respiratory and cardiovascular issues, including premature mortality and morbidity, in addition to increasing associated hospitalisations. And that that diesel locomotives, switch engines, and onsite mobile equipment (ITVs, side picks and forklifts) are significant contributors of PM10, and PM2.5.
* As also noted, above acceptable noise levels that will result from an intermodal terminal can have health impacts including: annoyance, sleep disturbance, performance issues (reduced concentration), cardiovascular health problems, hearing problems, mental health effects, and general health impacts (e.g. on the immune system).
* Traffic impacts with the identified the problem of Trucks `weaving' onto and off the M5 is a significant problem. This `weaving' has the potential to cause a recognised `black spot', with potentially fatal consequences for the community.
* It is highly negligent of the Government to consider building an intermodal at the currently proposed Moorebank site. The site is located in the middle of a residential area, and the consequences of such a decision will prove dire to the community.
* Badgerys Creek is by far a site better suited to meet the criteria that the MIC has listed in their EIS summary.
Support from elected representatives
The role of three tiers of government is to ensure that community needs can be voiced to the government by their local elected representatives. These representatives are based within the community, they understand the local area, and are acutely aware of the geographic typography of the area and their constituents needs.
The representatives from the Liverpool area are all unequivocally stating that the Moorebank Intermodal proposal is in the wrong location. This includes the federal member for Hughes, Craig Kelly MP; the state member for Menai, Melanie Gibbons MP; and Liverpool City Mayor, Ned Mannoun.
It is worth noting these representatives recognise the need for an intermodal terminal within metropolitan Sydney to support future freight growth in New South Wales; however, Badgerys Creek is the ultimate location for this development. Liverpool Council have recently released a discussion paper titled `Badgerys Creek: the ideal location for an intermodal' (October 2014).
It is time for the government to listen to their party members who are voicing some very valid concerns, and join the discussion about a new location for this project.
Alternative uses for the land at Moorebank
The residents of Liverpool also support the Freight Infrastructure Advisory Board (FIAB) recommendation of the development of new intermodal freight capacity within metropolitan Sydney. However, the residents believe that the location of this development should be strategically placed to meet future growth and freight capacity. Therefore, it is proposed that Badgerys Creek, rather than Moorebank, is recognised as the consummate site for development.
`In 2011, the Australian Government developed the Liveable Cities Program (now called the Liveable Communities Programme) to support state, territory and local governments in meeting the challenges of improving the quality of life in our capitals and major regional cities' (2011, Department of Infrastructure and Regional Development website).
As part of this program, Parramatta City Council (the only Sydney council selected for the program) received $16,150,000 in funding to complete three missing links on the Parramatta Valley Cycle way, and undertake a series of related works on the Parramatta River Foreshore. The money used for this revitalisation has given Parramatta an economic and social boost.
The site identified for the Moorebank intermodal is prime, urban, riverfront land. This land should be used to assist the government in solving the housing crisis identified in the draft Metropolitan Strategy for Sydney, by using the development as a premium riverside residential lifestyle precinct. The land is situated less than 30 Kilometres from the Sydney CBD. It is in close proximity to public transport, including the T2 Airport and T2 Inner West & South lines (both of which have capacity to accommodate urban growth in this area), the Liverpool to Parramatta T-Way, the M90 Liverpool to Burwood bus route, and many suburban bus routes. In short, the Moorebank location is perfectly positioned and adequately serviced by public transport to assist the government in meeting its housing targets set in the Metropolitan Strategy for Sydney.
An independent valuation (Cushman and Wakefield Development Opportunity Liverpool Riverside Lands, September 2014) valued the SIMTA and MIC sites at more than $482 million. Revenue raised from the sale of this land could be used to assist in the funding of the infrastructure needed to support, and fast-track an intermodal at Badgerys Creek.
NSW Chief Health Officer's Report (2010) identified that there is considerable evidence that social factors (e.g. income, employment and education) have a critical role in health outcomes. A plan to revitalise the Liverpool area by embracing natural assets, such as the Georges River, and utilising land to its full potential presents an opportunity to lift the socio-economic status and improve overall health in the area. The Liveable Communities Programme in Parramatta is a testament to this.
Preserving the Casula Powerhouse Arts Centre and maintaining its accessibility to the community will boost the social economy of the area and contribute positively to community growth.
Linda Silmalis, in her Sunday Telegraph article (9 November 2014) says that `NEW housing sites for 11,000 homes will be unlocked today as the NSW government seizes on a building boom with one of the biggest land releases in Sydney this year.' On this topic, `State Planning Minister Pru Goward said the areas will help drive the housing construction boom, while placing downward pressure on house prices.' (Silmalis, L., 2014, `Grab your new home out west', Sunday Telegraph, 9 November 2014). Liverpool Council estimates that the land proposed for the Moorebank intermodals has the capacity for approximately 16,500 riverside dwellings, housing more than 40,000 people, and giving the community access to the Georges River. This will assist the government in meeting its targets, identified in the draft Metropolitan Strategy for Sydney, to develop housing for more than 1.6 million people. Affordable housing is a much better use of the land in this area.
Good, well considered, strategic planning is required to maintain New South Wales' status as the Premier State. This includes planning major infrastructure projects, such as an intermodal terminal, in the right location. The right location for this proposal is not Moorebank; Badgerys Creek is far better suited and situated to meet the Government's freight infrastructure needs.
Please reject this proposal on the grounds that it is not in the public interest of the residents of Liverpool or the wider community or to the Economy.


I am against the proposal for an Intermodal at Moorebank for many reasons:

* The EIS should be completed on the total number of projects proposed for the area, i.e. Federal Government Intermodal on the Australian Army Engineers site, SIMTA proposed intermodal as well as the SSFL since the effects will be felt of the total projects that are proposed not just the SIMTA proposal. Anything less does not give an accurate picture of the outcome.

I could not find any information that referred to the cumulative effects on air quality, noise and traffic that would occur from both the SIMTA proposal and the widely known about Moorebank Project Office proposal operating simultaneously.
By splitting the projects, it is is misleading and unfair to the people of Liverpool and to anyone that uses this area whether to travel through it , provide serices or use services provided by the area.


ROADS AND TRAFFIC

-Impacts to Traffic should be considered including the exiting and entry of trucks to and from the site and the deadly impact this will have as these trucks attempt to merge onto the M5 with traffic travelling at 100kph. Trucks merging from Moorebank Ave onto the M5 travelling towards the M7 will inevitably cause accidents as those already on the M5 travelling in the same direction swerve to avoid them or simply crash into the back of them. Also as cars travelling in that same direction on the M5 try to merge into the far left lanes in order to get onto the Hume Hwy whilst trucks from the intermodal are merging from Moorebank Ave onto the M5 travelling towards the M7, accidents are inevitable. For these scenarios to be mitigated would possibly mean lowering the speed limit on the M5 for that area or building complexed and expensive underpasses, overpasses or tunnels. Not enough information has been provided in EIS regarding mitigating or providing solutions to such matters. Any information provided is vague and does not display who would be responsible implementing for such action.

- What will you do to implement procedures to prevent trucks from using local streets? How will it follow through, monitor and carry out these these procedures? What are the so called local streets specifically? Please name them specifically?

- there will be a huge impact to the residents living close by as well as a significant impact to all people living within a 10km radius of this site. The location is within very close proximity to houses. How would anyone expect our lives to be with all the air pollution that would be generated, the noise and the light 24/7. Not discussing the rail impact, our streets are already very congested and as it stands now it is almost impossible to go on the local roads during peak hours let it be with 2000 trucks more. The M5 is already over full capacity during these peak hours and roads in the surrounding areas of the proposed Intermodal would become gridlocked.

- I am glad that 3300 trucks are taken off the road from Botany to
Moorebank Avenue. But how wrong is it to put 3300 trucks back on the
road from Moorebank Avenue in an existing pollution basin. The truth behind this simple fact has been hidden by SIMTA as well as the Moorebank Project Office from the beginning of these proposals.
With up to one million trucks expected to enter and depart Moorebank Ave to and from the SIMTA terminal annually, many of them using the M5....How is this NOT due to freight terminals???
How can they say that this number of trucks they intend to bring to the Liverpool area will not increase truck movements on the M5? It may be on a different section of the M5 ie between Moorebank Ave and the M7 junction but the same number of trucks and more will still be using the M5 due to the fact that goods must be delivered from Moorebank to the warehouses in the west and south west of Sydney.
I feel the Liverpool community are being fed lies to avoid conflict with residents on their proposal.

-

AIR QUALITY AND PEOPLE'S HEALTH
Air Quality is really important. Australia has one of the worlds highest incidents of Asthma. Residents suffer from many other lung complaints as well. Any degradation in air quality will make these conditions worse. Every truck that they take off the road at Port Botany will have to start at Moorebank, queuing with its engine running, pushing pollution into the air.

Air Pollution has really serious health effects. Studies show the following:
* Air Pollution from busy roads shortens life expectancy
* Asthma symptoms (and childhood hospitalisations) caused by truck exhaust
* Babies are more likely to be premature or have low birth weight if mum lives near high traffic areas
* Respiratory symptoms in two year olds linked to Traffic
* Asthma more common in children who live near freeways
* Children (and people generally) who live near busy roads are more likely to develop cancer
* Air Pollution causes more traffic related deaths than accidents
This link has an index of relevant studies from the San Diego Earth Times.

Another study http://www.ehjournal.net/content/6/1/23 talks about the Cardiac and Pulmonary effects of living in close proximity to pollution.

Specific questions to be addressed in the terms of reference should include;
a) what increases in PM10 and PM2.5 will occur at different locations in the local environment, arising from all sources related to the proposed Moorebank
Intermodal Terminal Facility
b) what increases in PM10 and PM2.5 will occur at different locations in the local environment, arising from the combined effects the proposed Moorebank
Intermodal Terminal Facility and the Department of Finance Intermodal
terminal project.
c) Will the increases in PM10 and PM2.5 arising from the Intermodal developments push the levels of PM10 and PM2.5 (in any location) above the guidelines set by the World Health Organization.
d) What, if any health effects are likely to occur in the local population resulting from increases in PM10 and PM2.5 levels associated with the Intermodals.
e) What are the economic costs (loss of productivity, cost of health care, etc) of any adverse health effects.
f) If the proposed Intermodal facility was to be located in another area of Sydney,what PM10 and PM2.5 levels would result in these other local areas.


- The proponents of the massive terminal complex at Moorebank say that residents won't be impacted by noise, but residents are not convinced.

Overseas, authorities acknowledge the noise impacts on local residents. The Port of Houston Authority in Texas has offered $US40,000 "mitigation payment" per house for houses as far as 920m (Baywood Ave Shoreacres) from the Bayport Container Terminal so home owners can install soundproofing.

You can read all about it here.
http://www.bayportmitigationsolution.com/

- In 1997 the Holsworthy Airport proposal was scrapped, one of the reasons being that the air pollution would adversely affect the region. 15 years later that population is now substantially bigger and more people would be affected by a much bigger proposal. The location is the wrong place for such an operation


- Since pollution in the area is already high compared to a lot of areas in Sydney any increase in pollution must be considered to be dangerous and must be monitored in full and in all conditions. Any adverse findings must be reported and remediated including fines and/or criminal penalties where applicable.

- There has been a mountain of research from all over the world that diesel emissions cause great problems to residents even short term exposure.It effects the brain lungs diabetes child birth weight hearts as diesel contains 40 toxic chemicals. And still it appears the ones deciding on these freight terminals are choosing to ignore the facts and the resident's concerns. It is unbelievable that governments and companies can be so short sited when planning such infrastructure in residential areas. Or is it simply neglect?

OTHER ISSUES

- The threat of terrorist attack on the Intermodal site including freight and infrastructure. With only 3% of containers currently being checked for illicit and illegal goods how can we be certain that terrorists will not attempt to attack and cripple Sydney's Freight flow, particularly as it seems that the Government is concentrating all of the freight flow into 1 or 2 narrow freight corridors.


- The potential for an accident with unknown container contents spillage or leaking into the George's River, local watertables, soil or air is of concern


- The potential for an explosion resulting from an accident or careless handling of containers resulting in damage to resident's homes and other surrounding infrastructure.



-Most of the 13,000 families within 2km of the container terminal are paying off a mortgage and they are worried about the effect of having a huge container terminal appear next to their house.
Houses next to terminals drop in value, a lot. Local residents don't deserve a slug like that.
What compensation will be on offer for residents within the 2km zone from the Intermodal?




- Why is the Crime and statistics of the suburb of Moorebank studied so heavily when in fact the planned intermodal lies closer to the residential areas of Wattle Grove and Casula than it does to the predominant residential area of Moorebank? It seems Wattle Grove and Casula have not been considered in the planning and the social and health requirements of these suburbs will not be considered by SIMTA.


- Nowhere in the planning for Moorebank complex has there been any mention of compensating residents so they can insulate themselves against noise or top up their mortgage so the drop in property value doesn't leave them with negative equity.


- I have to remind the planners of these Intermodals both Federal and Private that flooding of the Georges River is of great concern.
There have been numerous times flooding has occurred along Newbridge Rd near Flower Power and heavy rain in a short period can cause flooding along Newbridge Rd which has the Georges River at 2 points near the area.
With heavy rain recently part of the area has been flooded and to believe you could operate a freight hub with such uncertainty beggars belief and if the flooding occurred it would cause great damage and inconvenience to the SSFL freightline and the transport of diesel trucks along Newbridge Rd , Moorebank Ave and other heavily patronised roads.

Can you please listen to these concerns and reply with a personal response?

Our community would appreciate the chance for your group to meet with us to discuss these and other concerns.

Kind Regards,

Dominic Scutella


The consultations regarding the proposed Intermodal(s) at Moorebank/Wattle Grove are illegal.

According to the 2011 Census, Wattle Grove's population included 27.8 % of people who did not speak English, however the consultations (both the limited posted material and the limited in person meetings) have not included any translated material or provided any interpreters. Specifically, other languages spoken included 4.1% Arabic, 3.0% Other, 2.5% Language spoken at home not stated, 2.4% Hindi, 1.6% Tagalog, 1.5% Tamil, 1.3% Greek, 1.3% Cantonese, 1.3% Bengali.


A study has found that the Liverpool road network without the Intermodal, the traffic demand will exceed the network capacity by 21% by 2030.

With the Intermodal, the traffic demand will exceed the network capacity by 53% by 2030.

How can the proponents possibly claim that Moorebank is the ideal location for this development. What Liverpool will be is a parking station.

Question: (1) What has been put in place to ensure the road network is upgraded to cope with the traffic volume.

Question: 2 This now being basically a private development, the developer should be responsible for the cost of the upgrades, not the taxpayer.


Moorebank is the wrong place to put an intermodal. The poisonous diesel emissions from 10,000 trucks a day, outdated diesel trains as well as an increase in other related traffic will destroy our health. Our roads, at capacity already will be impassable and we won't get any sleep due to noise and sound vibration 24 hours a day, 7 days a week. Don't destroy our homes and our health.


Dear Sir/Madam,

The proposed Moorebank Freight Intermodals are based on Corruption, Lies on a number of levels and are a Break of Contract with Australian Voters.

The BIG Problem is that DEFENCE HOUSING AUSTRALIA in a previous entity SOLD THE LAND NEXT DOOR to the MOOREBANK INTERMODAL FIASCO for a Big FAT PROFIT!.......The Commonwealth of Australia cannot now decide to wreck the adjoining residential 1000 Block land project to suit a profit motif.
The NSW Planning DEPARTMENT is Being Used to Validate a Complete Con Trick
The lack of HIGHER MORALITY by the Commonwealth of AUSTRALIA demonstates the POLLUTION of VALUES IN THE GOVERNMENT OF THE COUNTRY>
The residents of Wattle Grove to be affected detrimentally in this instance next to the Moorebank Site whom bought in good faith the properties adjoining cannot now be affected by an enconomically expedient decision OTHERWISE NO FUTURE COMMONWEALTH LAND SALE WOULD WARRANT RESPECT OR VALUE ON THE AUSTRALIAN PROPERTY MARKET+

I oppose this development on grounds of increase to traffic, increase in diesel particulate pollution, 24 hour noise pollution, light spill in surrounding areas, sighted to close to environmentally sensitive Georges River and parklands, Power House Arts Centre.
Totally the wrong place to put it, should be at Bringelly or Eastern Creek away from residential areas. New EIS should be carried out due to change in many factors since the idea was first put up.
If this goes ahead I call on the State Gov to remove house sale stamp duty for those people who wish to move away from such an ill conceived project.

I have serious concerns with this plan to build an Intermodal only 500m from by back fence. We bought this house for it's quiet position in a lovely suburb only to find out that you plan to put a noisey, poisonous freight hub so close to a residential area. There are far more suitable places for this and should be seriously considered. Money should not be a short term consideration, the health and welfare of the local population is far more important.

To whom it may concern,

I wish to show my disapproval of the chance that the intermodal may be built in my local area of Holsworthy.
My reasons behind this are many and they are as follows.

1. Excessive traffic within the area.
To me this creates a number of problems. One of them being pollution in the form of vehicle fumes and also noise pollution.
Noise pollution to all the surrounding areas of this proposed storage yard as well as freight trains running 24hrs per day 7 days per week.

2. Traffic congestion not only on the motorways but also when there are truck break downs in the local areas around Hammondville, Holsworthy, Moorebank and Chipping Norton. I have seen what a single broken down car does to the flow of traffic let alone broken down trucks on a regular basis. Having to put up with this not only around our local schools but also the when traffic is diverted of the M5 motorway and on to Newbridge Road the extra vehicle driving through the night make it almost impossible to sleep.

3. What about the safety side of it? The amount of extra trucks that will be driving past schools and school children populated areas during school hours has the potential for children to be injured or possibly even killed.

4. If this does go ahead and a child is harmed because of this, I would really hate to be the one to say " I told you so"

Please think long and hard about this and move this construction to Badgerys Creek.

Concerned Local Resident,

Perry Wills

------------------------------------

To whom it may concern,
I wish to show my disapproval of the chance that the intermodal may be built in my local area of Holsworthy.
My reasons behind this are many and they are as follows.
1. Excessive traffic within the area.
To me this creates a number of problems. One of them being pollution in the form of vehicle fumes and also noise pollution.
Noise pollution to all the surrounding areas of this proposed storage yard as well as freight trains running 24hrs per day 7 days per week.
2. Traffic congestion not only on the motorways but also when there are truck break downs in the local areas around Hammondville, Holsworthy, Moorebank and Chipping Norton. I have seen what a single broken down car does to the flow of traffic let alone broken down trucks on a regular basis. Having to put up with this not only around our local schools but also the when traffic is diverted of the M5 motorway and on to Newbridge Road the extra vehicle driving through the night make it almost impossible to sleep, It is already bad enough with the amount of trucks using exhaust brakes through out the night with out more.
3. What about the safety side of it? The amount of extra trucks that will be driving past schools and school children populated areas during school hours has the potential for children to be injured or possibly even killed.
4. If this does go ahead and a child is harmed because of this, I would really hate to be the one to say " I told you so"

Please think long and hard about this and move this construction to Badgerys Creek.

Concerned Local Resident,

Perry Wills

To allow the Intermodal to be built at Moorebank would be madness.
The negative effect it would have on our health, traffic conditions,the Georges River, The Powerhouse Museum and our lifestyle would be detrimental to all.
Chullora can handle it all. If it must be built, it should be at Badgereys Creek near the airport and the distribution centres that these trucks will have to drive to.
Please consider us out here and prove that we DO matter

You will be responsible for CREATING an almighty traffic gridlock and total consistent impediment to the traffic flow on the M% at Moorebank.
You will also be responsible for an increasing number of accidents and their severity when you approve this "proposal" just by the dynamics of the heavy vehicles merging and demerging at high speed at the M5 and Moorebank Avenue intersection.

I find it astonishing that the Air quality study does not monitor or report on Diesel particulate matter.
The WHO has recently added Diesel particulate matter to its list of carcinogens affecting human life.
With the introduction of thousand more diesel engines annually, when they're under duress and at their dirtiest, into the residential area the people deciding and approving the "proposal should be held culpable for many preventable deaths and injuries!