Clyde Refinery Conversion

I submit that SSD- 5147 (Clyde) should be assessed concurrently with SSD- 5148 (Gore Bay Terminal)

I believe that the operations at Clyde and Gore Bay need to be considered together as they are both parts of the same overall operation - which is the import of various types of fuel, sending it through pipelines for storage and distribution from Clyde.

I do not think that a piecemeal approach by looking at the two projects separately will serve the public interest.

If the Clyde SSD is assessed and approved prior to Gore Bay, any decision on Gore Bay could be limited by the Clyde approval.

The EIS for Gore Bay Terminal is expected to be lodged early in 2014.

A delay in the assessment of the Clyde SSD will not unduly disadvantage Shell given it has taken Shell 22 months since the release of the Director General's requirements to submit their EIS and the Gore Bay EIS is imminent.

That the EIS for SSD-5147 should be withdrawn until SSD-5147 is amended to include the pipeline that runs between Gore Bay Terminal and Clyde.
Shell should then be required to consult the communities and local councils that are adjacent to the pipeline as part of the SSD Consultation process.
Only after the consultation outlined above, the EIS as amended with pipeline included should be re-exhibited and submissions in respect thereof accepted.

The pipeline that carries product from Gore Bay Terminal to Clyde is a key component of the Shell operation.

It is 19km long and a critical part of Shell's infrastructure but it is not included as part of the EIS for Clyde and it is not contemplated within the Scoping Report for Gore Bay Terminal. Unless the pipeline is brought within the SSD process, there will be no external assessment of the pipeline as part of the SSD process.
The proposed operations at Clyde have and will continue to impact on the nature and flow rate of product pumped through the pipeline, in particular the ceasing of crude oil pumping and its replacement by petrol.
Leakages of petrol are far more volatile and explosive than leakages of crude oil.
The SSD should be amended as outlined above and the consultation and exhibition processes should be adapted appropriately to allow a fuller review of the whole operation.

Dear Sir/Madam,
I strongly oppose the proposed development because:
1. It involves continuation of a dangerous industrial process in an area surrounded unacceptably close to residential and estuarine areas, and in conflict as I understand with Parramatta City Council's planning proposals.
2. It unreasonably pre-empts later project stages involving higher flows of a more volatile fuel in pipelines for many kilometres along Sydney Harbour foreshore unacceptably close to hundreds of people's homes.
3. It supports the continued long term use of climate damaging fossil fuels, when the science overwhelmingly accepts we are in a critical decade of needing to reduce this usage to avoid dangerous anthropogenic global warming. We should instead be decommissioning such sites near residential areas, rehabilitating them and supporting greater use of electric cars and more funding for public transport.
Yours sincerely,
Phillip Bradley
20/12/13

To whom it may concern,

RE: Shell Clyde Refinery Conversion

As a resident in the local government area of the City of Ryde, I am concerned about the safety of the proposed modification works to the Shell Gore Bay Terminal and Clyde Refinery. In January 2012, Shell submitted to your Department, scoping reports for two major developments:
1. SSD-5147, which pertain to proposed modification works to convert the Clyde Refinery for use as a finished fuels terminal.
2. SSD-5148, which pertain to modification works at Gore Bay Terminal to convert it to a finished fuels import terminal.

The ensuing decisions made in respect of the SSD- 5147 Shell Clyde Refinery Conversion will undoubtedly have significant consequences for the assessment and possible outcomes of the SSD-5148 Gore Bay Terminal conversion given they are inextricably linked. As you can understand, this will be of great relevance for those living and working along the Gore Bay Terminal to Clyde Refinery pipeline given that refined petroleum products derived from crude oils carries very different risk profiles.

In the interests of transparency and to enable the public to give an informed response to the SSD, details of plans for Shell's proposed modification works at both sites are necessary. Accordingly, I support Friends at Gore Bay (FOGB) in requesting that:

1. The Department withdraw SSD- 5147 Shell Clyde Refinery Conversion from exhibition until such time that SSD-5148 Shell Gore Bay Terminal Conversion is exhibited.
2. The Department request Shell to submit the EIS for SSD-5148 Shell Gore Bay Terminal Conversion as soon as practicable so that the departmental review can commence prior to Christmas (pending NSW Health comments), with clear instructions to Shell that no change of use or alterations and additions (including the use of crude tanks to store diesel fuel) can proceed outside the SSD - 5148 process.
3. Given the impact of both SSD projects on residents in five local government areas (LGAs) in the Sydney Metropolitan area, that the Department's notification of both SSD applications encapsulate residents adjacent to the location of the pipeline across all four LGAs in addition to those residents adjacent and opposite to Gore Bay and Clyde, the five LGAs being North Sydney, Lane Cove, Hunters Hill, Ryde and Parramatta.

Thank you for your attention to this matter.

Best wishes,
Name withheld on request

SUBMISSION FROM PHIL JENKYN DATED 22 DECEMBER 2013

RE: SSD-5147 SHELL CLYDE REFINERY CONVERSION RE EIS AND GENERALLY
RE: SSD-5148 SHELL GORE BAY FUEL TERMINAL
RE: DA 14/2 SHELL APPLICATION TO NSW ROADS AND MARITIME SERVICES

1. INTRODUCTION
I am a resident in Woolwich Road, Hunters Hill near the Shell pipeline that extends between Gore Bay and Clyde. However I am also a citizen committed to the pursuit of the public interest and the common good. Issues of public safety and security, environmental protection, health and community well-being are matters that are relevant to all citizens.

2. THE SHELL APPLICATIONS
2.1 The application in relation to the Shell Clyde Refinery SSD-5147 identifies a proposal to convert it from essentially refining crude oil to an import and distribution terminal for `finished petroleum products'. The Environmental Impact Statement (EIS) must adequately address, amongst other things, "receiving finished products by pipeline from Shell's Gore Terminal site", "distributing finished products by pipeline", "the nature and destination of fuels to be received and distributed", "risk assessment of the potential environmental impacts of the development", "identify the hazards associated with the existing site and the proposed development, as well as any external hazards to determine the potential for off-site impacts".
2.2 The application in relation to the Gore Bay Terminal SSD -5148 was lodged in March 2012 and awaits completion of a draft EIS for exhibition. This application seeks modifications to tanks and other works to turn it into a finished fuels terminal involving receipt from ships, storage and transfer by pipeline.
2.3 Apparently there is a further application by Shell to NSW Roads and Maritime Services relating to Gore Cove but it is obvious that Gore Cove Terminal is a designated Major Hazards facility and any application in the circumstances should be subject to the State Government's Major Approvals (SSD) process.

3. SHELL'S REFINERY AND TERMINAL OPERATION IN SYDNEY
3.1 Shell's operation in Sydney involves ships offloading petroleum products at Gore Bay at Greenwich in Sydney Harbour and then transporting those products by way of a 300mm underground pipeline constructed in 1962. This pipeline proceeds for 19 kilometres directly through the built up residential and recreational areas of the Lane Cove, Hunters Hill, Ryde and Parramatta local government areas, to Clyde Refinery in Rosehill.
3.2 In October 2012 Shell stopped importing crude oil to be refined at Clyde having decided to change its operation solely to importing fuels and petrol products for distribution to Sydney and elsewhere in the State.
3.3 Shell intends to grow the amount of fuel it brings in through Gore Bay to send to Clyde along the pipeline. It anticipates that Jet fuel to Mascot and diesel will increase by 4% per annum and that it will be supplying ever increasing needs especially as western Sydney develops.
3.4 Gore Bay is now the only facility left in Sydney Harbour where ships offload dangerous petroleum products. All other such facilities, Caltex at Ballast Point, BP at Balls Head, and Mobil at Pulpit Point closed down some time ago for good reason and relocated.

4. AN EXTREMELY HAZARDOUS AND OFFENSIVE OPERATION
Both proposed developments at Clyde and Gore Bay involve extremely hazardous and dangerous materials. These operations involve serious risk of death or injury were an accident to occur, and any spillage or leakage into the environment whether ignited or not would have catastrophic impacts.

5 THERE MUST BE ONE SSD ASSESSMENT
5.1 Shell has deliberately decided to lodge two separate applications, one for Clyde and one for Gore Bay. It has made no application in relation to the 19 kilometre pipeline built in 1962. This is disturbing as there is but one operation, one very dangerous operation, importing hazardous fuels up Sydney Harbour by ship, off-loading and storing them at Gore Bay, then pumping hazardous material 24 hours a day through a lengthy pipeline whose exact whereabouts are not known to the public or contractors or builders.
5.2 The SSD applications are defective. To reasonably assess risks involves an assessment of the whole operation, from `go to whoa', and this very much includes the pipeline. There must be one SSD assessment.

6. THE HIGHLY HAZARDOUS PIPELINE
6.1 It is with incredulity that an examination of the EIS reveals that there has been no assessment of the Gore Bay to Clyde pipeline. There are simply the bald statements "Shell does not intend to modify the existing pipeline". It is clear from the EIS that there will be a 24 hour operation involving ever increasing quantities of fuel. Nothing in the EIS, no evaluation, nothing about the consequences of increased use, the pipe's condition, its maintenance history, its leakages and accidents, its `life expectancy', nothing - a total silence in spite of what is required to be done as set out in paragraph 2.1 above and from Shell's obligations at law.
6.2 Up until October 2012 the main use of the pipeline was to carry crude oil. A spill or leakage of crude or a rupture of the pipeline could produce environmental damage and involve health risks, but not the likelihood of catastrophic explosion. On the other hand petrol is very volatile forming explosive mixtures with air over varying concentrations. Any ignition source, could lead to a massive explosion. The change from mainly pumping crude through the pipe to mainly pumping highly flammable petrol is a significant change of use with a dramatic increase in risk.
6.3 The pipeline runs right along the middle of the residential areas of Woolwich, Hunters Hill, Boronia Park, Hunleys Point, Huntleys Cove, Henley and Gladesville - all within the Municipality of Hunters Hill. The Municipality is in essence a narrow peninsula surrounded by water on three sides. It is of national historic and heritage significance. A broken pipeline ignited by an explosion and petrol continuing to spew out would all but destroy Hunters Hill. There could be many deaths and injuries and huge environmental damage. This could occur anywhere along the pipeline, not just in Hunters Hill.
6.4 There have been previous accidents and leakages. For example in 1976 there was a major accident in Gore Bay with 2 killed and 5 injured. In August 1999 there was a significant oil spill in Gore Bay. There has been apparently an emergency services event or exercise in Woolwich along a section of the pipeline in recent times. If Shell was to produce its records in relation to accidents and spillages and exercises and the like in relation to Clyde, Gore Cove and the connecting pipeline, there would in all probability be an interesting list that would accurately highlight this real and apparent danger. Shell clearly does not want to allow communities along the way of this pipeline to learn of its real dangers.
6.5 It is understood that in the USA there are OHSA codes that prevent the storage and transfer of hazardous materials in residential zones along the lines that Shell is doing here in Sydney. Shell's present operation must not be allowed to continue.

7. EIS NEEDS TO COVER THE WHOLE OPERATION INCLUDING PIPELINES
7.1 It is clear that the EIS is defective. The Summary (p395) of the EIS on exhibition is grossly inadequate. It states that the Project conforms to the principles of Ecologically Sustainable Development (ESD). It does no such thing. The EIS has failed to evaluate all the environmental consequences from the Shell development and operations, especially in relation to the pipeline, it has failed to look at the likely risks for the future from accidents and spillages from the pipeline, it fails to adequately deal with all health and environmental risks.
7.2 The pipeline should be closed immediately and a proper environmental assessment done. The community is rightly cynical in relation to any EIS directed and paid by the proponent. Any assessment should be truly independent and have access to all Shell's records, including accidents, leaks, risk and environmental assessments.

8. FAILURE TO PROPERLY CONSULT AND NOTIFY
There has been a failure to notify and consult communities along the length of the pipeline, including both Hunters Hill and Ryde Councils. The process is fatally flawed and must start again with proper notification to all those residents and councils that could be affected. That is if Shell wants to continue to operate these facilities.

9. CLOSURE OF GORE BAY TERMINAL
Gore Bay Terminal should close. It is not appropriate to now bring hazardous and highly inflammable material by ship up Sydney Harbour and use a site within the residential area of Greenwich as an expanding storage and distribution terminal, then pump dangerous petrol through residential areas for 19 kilometres to Clyde, and then pump Jet fuel all the way through residential areas to the airport in Botany Bay. Shell should move its operations to Botany Bay as have other petrol companies.

10. SUMMARY
10.1 The EIS is fatally flawed.
10.2 As there is one interconnected operation, there should be one SSD application, which clearly must include consideration of the pipeline.
10.3 As there has been a dramatic increase in risk of catastrophic accident since October 2012 from Shell's operations, the pipeline between Gore Cove and Clyde should be immediately shut down.
10.4 Shell should after further consideration move its operations to Botany Bay.

PHIL JENKYN OAM,
30 Woolwich Road,
Hunters Hill, NSW 2110
Email: [email protected]
Mob: 0422 442 677
22 December 2013

I am very concerned about the health and safety aspects of petrol being pumped underneath our area.

Clyde Refinery Conversion SSD - 5147
We understand that the planning for this conversion does not take account of the fact that the product that will flow though the pipeline from Gore Bay will be petrol, not crude oil as in the past. Since petrol is a more flammable, even explosive substance than crude, we submit that more more stringent assessment factors be included. Some details are
1. The Shell pipeline should have been included in both SSD-5147 and SSD-5148 (or in individual applications in respect of each local government area) because:
· since October 2012, there has been a significant change in the product being pumped through this pipeline
· there has been consequential increased risks associated with the transfer of petrol, being a far more volatile product and
· there will be significant future intensification of throughput in this pipeline through the reduction in storage capacity at Clyde.

2. Notwithstanding these impacts, residents adjacent to the Shell pipeline have not been consulted in relation to SSD-5147 nor have they been individually notified of the exhibition of the EIS or advised through advertisement in their local newspapers.

3. I submit in relation to SSD-5147 that:-
(1) the impact of the application on the chemical composition of product that has been and will be transferred through the pipeline be included in the matters to be considered as part of the assessment of SSD-5147
(2) the impact of the application on operational details of the product transfer through the pipeline be considered as part of the assessment of SSD-5147
(3) all residents living within a 5 kilometer radius of the pipeline, be advised as soon as is reasonably practicable of the exact location of the pipeline, its contents, the exact details of the security provided for the pipeline and the Shell corporation and State emergency response plans and procedures should there be a leakage from the pipeline
(4) all residents living within a 5 kilometer radius of the pipeline be notified of the exhibition of the DA and EIS for SSD-5147 in a manner deemed appropriate by the Department of Planning and Infrastructure
(5) in respect of the residents described in (4) above, that the deadline for submissions should be extended beyond the holiday period and the steps described above taken to ensure that there is adequate

17 Mitchell St
Greenwich NSW 2065
23 December 2013
The Minister of Planning
NSW Government
Macquarie St
SYDNEY NSW 2000

Dear Sir

I am writing as Greenwich resident who has followed with interest changes at Shell's Gore Bay terminal and the plans to change its modus operandi following the cessation of refining of crude oil at Clyde.

A number of issues have arisen that I believe warrant close examination for the health and safety of affected residents at Greenwich, along the pipeline to Clyde and at Clyde and its surrounds.

Because changes at Clyde and at Greenwich are interdependent it is vital the two developments - and the connecting pipeline be assessed as one project.

Accordingly I make the following submissions:

Submission 1
That SSD- 5147 (Clyde) should be assessed concurrently with SSD- 5148 (Gore Bay Terminal)

The operations of Clyde and Gore Bay Terminal are integral parts of a single operation being a product import, storage and distribution operation.

Any assessment made in respect of Clyde impacts on what takes place at Gore Bay Terminal.

Prior approval of the Clyde SSD will constrain the capacity of the authority assessing the Gore Bay Terminal to make sound decisions in respect of Gore Bay Terminal as these decisions will be limited or impacted by what has been approved for Clyde.

The EIS for Gore Bay Terminal is expected to be lodged early in 2014.

A delay in the assessment of the Clyde SSD will not unduly disadvantage Shell given it has taken Shell 22 months since the release of the Director General's requirements to submit their EIS and the Gore Bay EIS is imminent.

Submission 2
That the EIS for SSD-5147 should be withdrawn until SSD-5147 is amended to include the pipeline that runs between Gore Bay Terminal and Clyde.
Shell should then be required to consult the communities and local councils that are adjacent to the pipeline as part of the SSD Consultation process.
Only after the consultation outlined above, the EIS as amended with pipeline included should be re-exhibited and submissions in respect thereof accepted.
The pipeline that carries product from Gore Bay Terminal to Clyde is a key component of the Shell operation.

It is 19km long and a critical part of Shell's infrastructure but it is not included as part of the EIS for Clyde and it is not contemplated within the Scoping Report for Gore Bay Terminal. Unless the pipeline is brought within the SSD process, there will be no external assessment of the pipeline as part of the SSD process.
The proposed operations at Clyde have and will continue to impact on the nature and flow rate of product pumped through the pipeline, in particular the termination of crude oil pumping and its replacement by petrol.
Leakages of petrol are far more volatile and explosive than leakages of crude oil.
The SSD should be amended as outlined above and the consultation and exhibition processes should be adapted appropriately to allow a fuller review of the whole operation.
Submission 3
That the proposed decommissioning of storage capacity at Clyde (currently proposed from 638ML to 264ML.) should be reviewed to ensure that adequate storage capacity is available at Clyde to hold all petrol immediately after it is unloaded at Gore Bay.

Petrol is a volatile product and a leakage of petrol, even a small amount, has the capacity to cause a major explosion. Recent examples include the Buncefield incident, the petrol tanker incident at Mona Vale , and the extensive disruptions adjacent to the Caltex Port Botany facility when a leak was detected.

Residential development around the Gore Bay Terminal goes right to the boundary of the Terminal and storage of petrol would place the community at an unacceptable level of risk.

The Clyde site has a significantly wider buffer area between it and residential development.
It is critical to ensure that the proposed storage capacity at Clyde can handle all importation of petrol so that under no circumstances will petrol need to be stored at Gore Bay, even in a "holding tank".
Recent Shell Australia material on its web site indicated that petrol could be held for 24 -48 hours at Gore Bay prior to pumping to Clyde. As ship visits are virtually continuous into Gore Bay this would mean a re-circulating level of petrol product being continuously held on the site.

Submission 4
That no further steps be taken in respect of the assessment of SSD-5147 until Shell has engaged in consultation with and the EIS is notified to
* all residents who are adjacent to or who are likely to be impacted by an incident related to the pipeline from Gore Bay to Clyde
* all local councils responsible for the areas in which the pipeline is located and
* all Community groups in the relevant areas.

Appendix F Preliminary Hazard Assessment of the EIS outlines risks associated with the pipeline on the Clyde site.
The impacts on the Clyde site are as just as likely to occur outside the site but those potentially affected have not been consulted or advised of the SSD and the contents of the EIS.

Submission 5
That the impact of the proposals foreshadowed in SSD-5147 on the chemical properties of product transferred through the pipeline from Gore Bay to Clyde and operational details of the pipeline be considered as part of the assessment of SSD-5147.
That all residents living within a 5 kilometer radius of the pipeline, be advised as soon as is reasonably practicable of the exact location of the pipeline, its contents, the exact details of the security provided for the pipeline and the Shell corporation and State emergency response plans and procedures should there be a leakage from the pipeline.
That all residents living within a 5 kilometer radius of the pipeline be notified of the exhibition of the DA and EIS for SSD-5147 in a manner deemed appropriate by the Department of Planning and Infrastructure
That, in respect of the residents described) above, that the deadline for submissions should be extended beyond the holiday period and the steps described above taken to ensure that there is adequate notification and consultation of these communities.

Since the closure of the Shell refinery operation at Clyde in October 2012, the Shell operation is now mainly a continuous petrol distribution process that involves three main steps:-
* transfer of petrol from ships carrying petrol at the Gore Bay terminal
* pumping of this product through the 19km Shell pipeline from Shell Gore Bay to Shell Clyde
and
* the subsequent storage and distribution of this product from Clyde by road tanker.

The chemical composition of product transferred through the pipeline and the operational details of the transfer are inextricably linked to the activities at Shell Gore Bay and Shell Clyde.
Since October 2012 the main product carried through the pipeline has been petrol and this will continue to be the case with the closure of the refinery at Clyde.
The main product transferred through the pipeline before October 2012 was crude oil.
It is a fact that leakage of petrol poses a far greater risk of explosion than did leakage of crude oil.
Since October 2012, there has been a significant change in the product being pumped through this pipeline.
There have been consequential increased risks associated with the transfer of petrol, being a far more volatile product and there will be significant future intensification of throughput in this pipeline through the reduction in storage capacity at Clyde.

Notwithstanding these impacts, residents adjacent to the Shell pipeline have not been consulted in relation to SSD-5147 nor have they been individually notified of the exhibition of the EIS or advised through advertisement in their local newspapers.
I look forward to your response to these issues so that a proper assessment of the integrated project can be undertaken.


Yours faithfully



John Southwood
M 0412 137 080
[email protected]

I am a long time resident of the 2065 postcode.

The operations of Clyde and Gore Bay Terminal are integral parts of a single operation being a product import, storage and distribution operation.

Any assessment made in respect of Clyde impacts on what takes place at Gore Bay Terminal.

Prior approval of the Clyde SSD will constrain the capacity of the authority assessing the Gore Bay Terminal to make sound decisions in respect of Gore Bay Terminal as these decisions will be limited or impacted by what has been approved for Clyde.

The EIS for Gore Bay Terminal is expected to be lodged early in 2014.

A delay in the assessment of the Clyde SSD will not unduly disadvantage Shell given it has taken Shell 22 months since the release of the Director General's requirements to submit their EIS and the Gore Bay EIS is imminent.

Thank you for considering my submission.

The operations of Clyde and Gore Bay Terminal are integral parts of a single operation being a product import, storage and distribution operation.

Any assessment made in respect of Clyde impacts on what takes place at Gore Bay Terminal.

Prior approval of the Clyde SSD will constrain the capacity of the authority assessing the Gore Bay Terminal to make sound decisions in respect of Gore Bay Terminal as these decisions will be limited or impacted by what has been approved for Clyde.

The EIS for Gore Bay Terminal is expected to be lodged early in 2014.

A delay in the assessment of the Clyde SSD will not unduly disadvantage Shell given it has taken Shell 22 months since the release of the Director General's requirements to submit their EIS and the Gore Bay EIS is imminent.

1. Shell has taken almost two years to compile a technical document many hundreds of pages long, however, the communities impacted by the project, stretching from the Parramatta area, along an old pipeline to Gore Bay is expected to be understood and then responded to in a four week timeframe - the exhibition period should be extended to the end of February 2014 to give people living along the pipeline a chance to learn about and respond, if they see fit, to the proposal.
2. On reading the document there is little time spent examining the possible alternatives to Clyde's conversion from refinery to a terminal considering the risk of pumping gasoline through old pipeline underneath Sydney suburbia.
3. For Shell to propose that Clyde, the pipeline and Gore Bay are separate operations and not address the entire project as one project cannot be viewed with credibility. It is one large project that Shell has already started implementing without public accountability.
4. On viewing the pipeline feeding product from Gore Bay into Clyde it is understood that the signage of the change from crude to petrol has not been made? Has this changed after being brought to Shell's attention?
5. The exhibition period for SSD 5147 should be extended until the end of February 2014 to allow people newly notified opportunity to learn about and then have opportunity to from a view on the Shell proposal.

We object to the progress of this SSD5147 on the following basis ;the Shell Clyde Terminal was originally a refinery and can operate only together with the Shell Gore Bay operation and the pipeline between them.The entire Shell process provides product import, storage and distribution. Any assessment made of the Clyde proposal cannot be completed in isolation of what needs to happen at the Gore Bay Terminal.If the Clyde SSD is approved in isolation of Gore Bay SSD it will limit the authorities doing a thorough and complete assessment of the entire operation. As the operation is a hazardous industry ,full and thorough consultation on all critical matters especially related to the safety risks associated with gasolene is essential. We propose that the consultation period for Clyde is extended such that it can be assessed together with the Gore Bay SSD.
Tom Gervay

As a resident of Greenwich I have read the SSD 5147 for Clyde Terminal with great interest. I must take this opportunity to express my surprise that the SSD has excluded the pipeline which carries product to the terminal. As Shell has not submitted a DA for the pipeline and it has not covered the pipeline in the scope of works for Gore Bay this should be seriously assessed and communicated to the communities affected.

I would have expected that Shell should have engaged the residents of Greenwich in a consultation process for SSD 5147 as the changes made at Clyde have had a serious impact on the operations of Gore Bay.

I formally request that the Department review Clyde as a PART OF one complete operation, including Gore Bay and the pipeline. I look forward to your response and in addition, full exposure of the health and safety risks associated with gasoline import and handling for the Clyde operations.

I object to the project proceeding until further consideration has been given to the impact on the endangered Green and Golden Bell Frog (GGBF). The Shell Refinery site is well known for hosting an important population of GGBF but the project proposal includes no attempt to avoid or minimise impacts and their only mitigation strategy is the physical removal of frogs from one area of the site to another.

The Environmental Assessment (EA) notes that GGBF have been recorded on the site since 1999, meaning the site has consistently provided habitat for 14 years. Anecdotally, the site is known to have provided suitable habitat for even longer, despite the site's use as a heavy industrial facility. This long occupation period highlights the importance of the site in maintaining the local GGBF population. The EA attempts to suggest that changes to the management of the site have reduced the suitability of the habitat on site, implying that the importance of this breeding area is therefore reduced. The ongoing residence of a breeding population demonstrates that this is simply not the case.

The EA states that it is not possible to avoid impact on the non-wetland habitat areas. Given the nature of the site, this is reasonable. However, the fact that none of the impact can be avoided increases the importance of appropriate mitigation actions. Simply moving the frogs from one area of the overall site to another, in no way compensates for the loss of habitat. The assumption that animals can be moved without impacting their reproductive success is fundamentally flawed and fails to consider the fact that if the existing wetland area provided sufficient habitat (in either size or quality) or was sufficiently attractive to the animals, the area would already be being utilised by the frogs at or near the population limit of the habitat.

It is therefore incumbent on Shell Refinery to attempt to provide alternative habitat in the near vicinity by dedicating additional areas to GGBF habitat and by constructing artificial habitat in areas of the site away from the existing wetland. This habitat should be designed by appropriately qualified experts and be monitored and managed in the long term (including adapting the constructed habitat should it not be found to be utilised by GGBF). As the EA notes, a similar strategy has been applied successfully to GGBF populations at Olympic Park.

It is also appropriate that this stage of the development should require the in perpetuity dedication of areas that will be retained as natural areas, including the riparian zone and the wetland area.

Major Projects Assessments
22-33 Bridge Street,
Sydney NSW 2000

Dear Sir

Re: Shell Clyde Refinery Conversion Project (SSD 5147)

In response to your invitation dated 19 November 2013, we make the following submission regarding the above proposal.

The Australian Turf Club Limited has developed a masterplan for Rosehill Gardens (which also contemplates the potential to rezone adjacent landholdings in keeping with the ATC's vision for the Camellia Peninsula) which has been presented to Parramatta Council (Council) in 2013. The brief that underpins the ATC's masterplan is that it should maximise development opportunity for the Club's non-core land by capitalising upon the strategic position of the site located within Sydney's geographic heart and on a major gateway into the Parramatta CBD.

The key objectives of this Masterplan are to:

* Provide the flexibility to construct the Parramatta to Epping Rail link or a derivative thereof,
* Cater for the introduction of light rail,
* Re-route heavy vehicles from the peninsula to M4 and Silverwater Road via an integrated infrastructure improvement program to be funded by a Contributions Plan, works in kind and government contributions,
* Provide a new and iconic Gateway, Boulevard and Public Square,
* Develop the highest and best uses for non-core racecourse land,
* Promote Rosehill Gardens as a 7 day a week operation,
* Provide a new high quality address to the racecourse, Parramatta CBD and the peninsula off James Ruse Drive,
* Progress the nomination of the Camellia Peninsula as an Urban Activation Precinct.

The opportunity to regenerate the urban landscape of East Parramatta and the Camellia Peninsula via its inclusion in an Urban Activation Precinct (UAP) is being pursued by Council and a group of local landowners, including the ATC. A Camellia UAP working group (consisting of Council and volunteering major landowners) is to be established early in 2014. It is proposed the working group will develop the approach and assist Council with the necessary investigations/studies, culminating in an application by Council to Department of Planning and Infrastructure (DPI) for the area to be declared an UAP. Indications from DPI are that the precinct is suited to a UAP solution and that an application would be welcomed. To assist in progressing the UAP process, the ATC has developed an indicative structure plan (refer attached) which we believe provides a logical vision and starting point for the development of a detailed land use and infrastructure plan for this area, supported by an economically viable contributions plan.

In context with the current and ongoing operations of the racecourse, the Rosehill Gardens Masterplan and the potential land uses envisaged in an UAP, and changing land use controls and development activity in Parramatta East, we note the following:

* In principle we support the Shell proposal as it de-intensifies the heavy industry in proximity to the racecourse and surrounding and proposed more sensitive employment generating land uses, and will reduce the visual impacts, noise and airborne pollutants, that the refining aspects of the Shell operations generate,
* However, we are of the view that in granting any consent to the application, the following matters should be considered and form appropriate conditions of consent:
o The James Ruse Drive/Grand Avenue intersection is at capacity. We note that there is no anticipated reduction in heavy vehicle movements associated with the proposal. In context with the likelihood of an increase in traffic as the peninsula is redeveloped for light industrial and business uses (see attached UAP Structure Plan), existing road infrastructure is considered grossly inadequate,
o Heavy truck movements into and out of the peninsula would also be best directed away from the James Ruse Drive/Grand Avenue junction which would improve the operation of the James Ruse Drive/Grand Ave intersection and eliminate heavy vehicle conflicts between the mixed uses proposed at James Ruse Drive and along Grand Avenue as it enters the Camellia peninsula,
o Residual landholding(s) of Shell, created by the reduction in activities/required footprint, should require a Masterplan to be developed and agreed to by Council that aligns with the potential UAP solution and general change in land uses/infrastructure proposed in the area,
o The above principle should also apply to Shell's retained landholding,
o Specifically, plans for Shell's residual and retained landholdings should recognise the need for additional road linkages to Silverwater Road and the M4, and future light rail corridor, as illustrated in the attached UAP Structure Plan,
o Forward planning for additional road entries/light rail corridor and Duck River crossings through the peninsula is seen as critical to the successful future re-development of the area,
o In addition, the masterplan for the site should include foreshore public access to parklands, pedestrian cycle ways and the potential for ferry services,
o We believe the Shell landholding's footprint dictates that Shell's co-operation in future proofing for additional infrastructure such as road/transport access solutions and public access to the foreshore of the peninsula is paramount.

We thank you for the opportunity to address this proposal. Should any aspect of our submission require clarification, please contact me on 0417 205 247.

Yours sincerely,
Australian Turf Club Limited




Mark Flanagan
Executive General Manager, Property Development

Major Projects Assessments
22-33 Bridge Street,
Sydney NSW 2000

Dear Sir

Re: Shell Clyde Refinery Conversion Project (SSD 5147)

In response to your invitation dated 19 November 2013, we make the following submission regarding the above proposal.

The Australian Turf Club Limited has developed a masterplan for Rosehill Gardens (which also contemplates the potential to rezone adjacent landholdings in keeping with the ATC's vision for the Camellia Peninsula) which has been presented to Parramatta Council (Council) in 2013. The brief that underpins the ATC's masterplan is that it should maximise development opportunity for the Club's non-core land by capitalising upon the strategic position of the site located within Sydney's geographic heart and on a major gateway into the Parramatta CBD.

The key objectives of this Masterplan are to:

* Provide the flexibility to construct the Parramatta to Epping Rail link or a derivative thereof,
* Cater for the introduction of light rail,
* Re-route heavy vehicles from the peninsula to M4 and Silverwater Road via an integrated infrastructure improvement program to be funded by a Contributions Plan, works in kind and government contributions,
* Provide a new and iconic Gateway, Boulevard and Public Square,
* Develop the highest and best uses for non-core racecourse land,
* Promote Rosehill Gardens as a 7 day a week operation,
* Provide a new high quality address to the racecourse, Parramatta CBD and the peninsula off James Ruse Drive,
* Progress the nomination of the Camellia Peninsula as an Urban Activation Precinct.

The opportunity to regenerate the urban landscape of East Parramatta and the Camellia Peninsula via its inclusion in an Urban Activation Precinct (UAP) is being pursued by Council and a group of local landowners, including the ATC. A Camellia UAP working group (consisting of Council and volunteering major landowners) is to be established early in 2014. It is proposed the working group will develop the approach and assist Council with the necessary investigations/studies, culminating in an application by Council to Department of Planning and Infrastructure (DPI) for the area to be declared an UAP. Indications from DPI are that the precinct is suited to a UAP solution and that an application would be welcomed. To assist in progressing the UAP process, the ATC has developed an indicative structure plan (refer attached) which we believe provides a logical vision and starting point for the development of a detailed land use and infrastructure plan for this area, supported by an economically viable contributions plan.

In context with the current and ongoing operations of the racecourse, the Rosehill Gardens Masterplan and the potential land uses envisaged in an UAP, and changing land use controls and development activity in Parramatta East, we note the following:

* In principle we support the Shell proposal as it de-intensifies the heavy industry in proximity to the racecourse and surrounding and proposed more sensitive employment generating land uses, and will reduce the visual impacts, noise and airborne pollutants, that the refining aspects of the Shell operations generate,
* However, we are of the view that in granting any consent to the application, the following matters should be considered and form appropriate conditions of consent:
o The James Ruse Drive/Grand Avenue intersection is at capacity. We note that there is no anticipated reduction in heavy vehicle movements associated with the proposal. In context with the likelihood of an increase in traffic as the peninsula is redeveloped for light industrial and business uses (see attached UAP Structure Plan), existing road infrastructure is considered grossly inadequate,
o Heavy truck movements into and out of the peninsula would also be best directed away from the James Ruse Drive/Grand Avenue junction which would improve the operation of the James Ruse Drive/Grand Ave intersection and eliminate heavy vehicle conflicts between the mixed uses proposed at James Ruse Drive and along Grand Avenue as it enters the Camellia peninsula,
o Residual landholding(s) of Shell, created by the reduction in activities/required footprint, should require a Masterplan to be developed and agreed to by Council that aligns with the potential UAP solution and general change in land uses/infrastructure proposed in the area,
o The above principle should also apply to Shell's retained landholding,
o Specifically, plans for Shell's residual and retained landholdings should recognise the need for additional road linkages to Silverwater Road and the M4, and future light rail corridor, as illustrated in the attached UAP Structure Plan,
o Forward planning for additional road entries/light rail corridor and Duck River crossings through the peninsula is seen as critical to the successful future re-development of the area,
o In addition, the masterplan for the site should include foreshore public access to parklands, pedestrian cycle ways and the potential for ferry services,
o We believe the Shell landholding's footprint dictates that Shell's co-operation in future proofing for additional infrastructure such as road/transport access solutions and public access to the foreshore of the peninsula is paramount.

We thank you for the opportunity to address this proposal. Should any aspect of our submission require clarification, please contact me on 0417 205 247.

Yours sincerely,
Australian Turf Club Limited




Mark Flanagan
Executive General Manager, Property Development

Please see attached submission.

Please see attached submission.

Please see the attached document containing our submission

Re: Submission to the proposed Shell Clyde Refinery Conversion

I am writing to make a submission to the proposed Shell Clyde Refinery Conversion public exhibition of the Environmental Impact Assessment.

I have received many concerns from the community regarding the changes and proposed changes at the Shell Clyde facilities, as well as at the Shell Gore Bay facility.

The recent notable changes to the Clyde facility poses many significant environmental and health implications for nearby residents. I understand that the facility was originally designed to pump crude oil but now exclusively pumps refined petrol. I also understand that the facility now pumps petrol twenty four hours a day.

It is my understanding that it is the intention of the Minister for Planning and Infrastructure to consider development planning submissions regarding the two sites under the same development application process, as advised to the Legislative Council on 21 February, 2013 (Paper Number 125).

However, it appears that Shell is undertaking the proposed Clyde Refinery Conversion planning process in isolation of the Gore Bay facility, to which it is connected by a 19 kilometre pipeline.

If Shell has any plans to make modifications to the Gore Bay Facility, I believe they should be submitted concurrently with the Clyde plan to enable a holistic view of the whole system.