Berry
,
New South Wales
Message
I wish to make a brief submission in relation to the proposed CO₂ Processing Plant at the Shoalhaven Starches site.
I have recently lodged a detailed submission regarding the separate Modification 26 application for additional grain storage and handling facilities. While reviewing planning documents for that proposal, I became aware of this separate State Significant Development application. Rather than repeating the detailed matters raised in my earlier submission, I wish to highlight that this proposal significantly strengthens its central recommendation.
The CO₂ Processing Plant is another major industrial development proposed within the same Bomaderry industrial complex. Together with Modification 26 and other recent modifications and expansion projects at the site, it demonstrates that the scale and pace of industrial intensification is increasing substantially.
These proposals are individually significant. Collectively, they represent an ongoing transformation of one of the Shoalhaven's largest industrial precincts.
The Department is now assessing multiple major developments that collectively involve:
-significant new industrial infrastructure;
-expanded storage and processing capacity;
-new hazardous process plant;
-additional heavy vehicle movements;
-increased rail and logistics activity with impacts on public rail services;
-additional energy and utility infrastructure; and
-further long-term industrial investment on the site.
-increasing risks and impacts on the fragile environment of the Shoalhaven River
Each proposal may be capable of satisfying statutory assessment requirements on its own. It is not for me to judge. However, the community is never presented with a clear picture of what the overall industrial precinct will ultimately become, how quickly it is changing, or what the cumulative environmental, transport, visual, safety and strategic planning implications are.
This is particularly important because the surrounding area is also undergoing so much significant and conflicting change.
Bomaderry is experiencing substantial residential growth, including transport-oriented development around Bomaderry Station, urban renewal, and increasing investment in improving access to and enjoyment of the Shoalhaven River. The community is being asked to consider housing growth, improved public transport, environmental outcomes and place-making, while at the same time one of the region's largest industrial sites is expanding and intensifying bit-by-bit through a series of separate planning approvals and amendments. Meaningful community engagement becomes increasingly difficult when these developments are considered in isolation.
A comprehensive master plan for the entire Manildra industrial precinct would allow the Department, Council, government agencies and the community to properly understand:
-the long-term vision for the site;
-the cumulative scale of industrial expansion;
-future freight and transport requirements;
-cumulative environmental and river impacts;
-changing risk profiles associated with hazardous industries in a changing climate in a flood prone area;
-interactions and impacts on amenity and public health with adjacent residential growth and transport-oriented development;
-opportunities for improved rail freight and reduced road freight;
-strategic infrastructure requirements; and
-how these competing public interests should be balanced over coming decades.
This submission is not intended to oppose the proposed CO₂ facility in isolation. Indeed, the proposal appears to offer potential benefits, including improved utilisation of a waste product, increased resilience of Australia's food-grade CO₂ supply, and regional employment. Rather, the proposal illustrates why an integrated planning framework is now warranted.
As multiple significant developments continue to emerge on the same industrial estate, the public interest would be better served by preparing a whole-of-site master plan and cumulative impact assessment that allows future proposals to be considered within a transparent long-term strategic context, rather than as a succession of separate applications.
My request is that the Department give consideration to requiring, or facilitating, such a strategic planning framework before further major expansion of the precinct proceeds.