Cricket NSW CoE - MOD 4: Lighting modification

The proposal says "The proposed modifications are of a minor nature, relating to sports lighting only”
The sports lighting of 50m towers is not insignificant or minor. The 50m towers will tower above any structure in the area for kilometres. The 50m towers will be twice as high as any trees or other buildings or anything in the area. The apartments 200m away are maximum 30m. The 50m towers are at least double or triple the height of Cricket centre itself. They will be seen from kilometres in almost every direction, from Rydalmere wharf to George Kendall reserve, to the top of River road near Ermington town centre, to Blaxland Riverside Park and possibly even Newington, whereas the Cricket centre itself does not stand out from any of those viewpoints. Those viewpoints are completely absent from any view impact assessment in this modification.
The recent apartment developments on the northern side of the river (River Road, Bundarra Street, Allambie Street, Koorine street, Arista way are all low-rise developments of maximum 5 storeys). This was obviously a part of planning restrictions. Why then should Cricket NSW be allowed to construct 4 x 50m towers which are twice the height of any of these buildings, or any other structure in the area, constructed or natural just a few years later?
In some places the proposal says the towers will be 50m, others approximately 50m, and elsewhere minimum 50m. This is not consistent nor worth of approval.
It is claimed in this modification that “Visual impacts” are unchanged to the originally approved SSD EIS. A reasonable person would not consider, 4 by 50m extremely bright light towers which are twice as high as any feature or structure in the area to have visual impacts unchanged from the original.
It is nonesense to say the “The proposed lighting towers will sit behind the approved Cricket Central and will be partially obscured by the existing buildings and vegetation, particularly at the lower portion of the structures.”
You can see from Cricket NSW own visual impact pictures that ONLY the VERY lowest part of the lighting structures are obscured by existing buildings and vegetation. 100% of the lights themselves are not obscured, and will be 100% visible from many distant vantage points as previously mentioned.
Another of the omissions of the visual impact assessments is the assessment that the lights will only be viewed briefly by people walking on the path 200m away along the River. This completely omits that there are at least 200-300 apartments within 200-500m away that will have PERMANENT direct views of the proposed 50m light towers. What to speak of all the houses on the hill rising towards Ermington shopping precinct that will have permanent views of the light towers.
Another inaccurate view assessment is in figure 14, where it is stated the “purpose of being at the viewpoint” is “staff/facility users at Cricket Central”. The impact assessment completely ignores the other significant numbers of people that cycle or walk along the footpath past the cricket centre to Newington Armoury, or Blaxland Riverside Park.
In the visual impact imagery you can not even see the existing electronic scoreboard. Yet if you walk on the path across the river from the Cricket centre when the electronic scoreboard is on, particularly at night, it is jarringly noticeable amongst the gentle but sufficient path lighting. The impact imagery does not provide any indication whatsoever of the type of impact the 50m light towers will have at night.
The letter drop did not include an imagery of what the towers would look like. Many residents of the area will not have the language capability to understand the letter drop or what an 80m or 50m light tower looks like.
The original proposal and this modification claims the main purpose of the facility is a training facility.
Yet it is hard to believe that a pristine international standard cricket oval with 50m light towers is going to be used primarily for training.
My understanding is that the main oval has already been used to host televised matches, yet this has not been declared as a purpose in either this modification proposal or the original.
What guarantees do the public have that adding 50m lights to the main oval is not for the purpose of hosting high-level cricket matches (even internationals) for the purpose of television broadcasting, during the prime sports viewing time slot of 6pm to 10pm and gaining revenue from broadcast rights? The fact is there is no such guarantee in this modification proposal or the original proposal, nor even that this is one of the uses of the facility.
Approving this modification, particularly the 50m light towers, will provide Cricket NSW with no limits on how many such financially lucrative matches they can host at the centre, because there is no mention of any such limits in this proposal or the original one.
Not approving the 50m light towers will at least restrict that undeclared purpose to daylight hours.
If that is one of the uses, and it should be easy to verify, then this purpose has not been stated in the original proposal or this modification, and therefore this modification should not be approved because the public has not been adequately informed.
Cricket NSW references to the intensity of lighting in this modification, state that variable intensity is used depending on the level of cricket being played.
Yet the lighting specification documents state increased intensities required for Television broadcast.
If it is the case that increased lighting intensity is needed for Television broadcast - this could easily be established as a fact - and Cricket NSW would be well aware of that fact, yet it has not been mentioned in this modification that the centre will host Television broadcasts under 50m lights on the main oval and that it will require increased lighting intensity (for Television, not the “level” of cricket being played). If this is the case, and there are significant financial incentives to do so (from Television broadcast fees), then there would be significant incentive to have frequent high intensity lighting, to the detriment of local residents.
In no way shape of form could such a situation be considered unchanged from the original proposal, and stating that the centre is primarily for training would be a gross misrepresentation.
In the very least the main oval with 50m lights could not possibly be primarily for training. Therefore the 50m lights should not be approved because they are not in keeping with the basis of the original proposal.

In summary, there are glaring omissions and misrepresentations of the visual impacts, particularly of the 50m light towers. Approving them would certainly not be, in a reasonable person’s mind, nor on objective consideration, be considered as having no change to the visual impact from the original proposal.
If Cricket NSW is selling Television broadcasts of matches at the Centre, and will do so under the 50m light towers, and increased intensity lighting is needed for such broadcasts then these are omissions that Cricket NSW will be well aware of when making this proposal yet there is no mention of it. This would amount to misleading the public.
It behooves any approving body to investigate these possibilities and not approve the 50m light towers without having guarantees that they will not be used for such purposes or implement restrictions that they will not be used for such purposes, because if they are used for such purposes the public will have knowingly been misled by Cricket NSW with the planning authority being negligent at best, and at worst knowing enablers in misleading the public.

I object to the proposed lighting due to the following reasons.
1. The lights are totally unnecessary for the original stated purpose and use of the cricket centre
2. The lights were not included in the original planning application for the cricket centre. This seems underhanded as this 'scope change' would have been known to the developers all along. It seems like a dishonest way of getting an application for unpopular and unwanted lighting across the line.
3. Negative effects on health and quality of life and reduced value of properties.
The area across the river from the cricket centre is residential zoning and the proposed lighting will affect all residents by forced exposure to bright lights. It will change the atmosphere and enjoyment of the area along the river. I bought my property at Ermington by the river because it is away from major roads and close to parks and bush land and relatively free from light pollution. I would never choose to buy a property near a sporting complex with bright lights. The proposed lighting will reduce the value of properties in the area as it is not attractive to live near such lights. Should these lights be installed it's something that will be forced upon me, and it will negatively affect me and the enjoyment of my property and the natural environment around the property.
4. Negative effect on wildlife
The proposed lighting will have a negative effect on wildlife in is in direct contravention of national light pollution guidelines https://www.dcceew.gov.au/environment/biodiversity/publications/national-light-pollution-guidelines-wildlife When bright lights are introduced into the environment, it can disrupt the behaviours of wildlife and negatively affect their health. This has the potential to stall the recovery of threatened species and negatively affect ecosystems. Sydney Olympic Park provides habitat for over 250 native animal species, including over 200 species of native birds, including a pair of resident Sea Eagles. Intelligent environmental policy should aim to reduce environmental light pollution, and not add more lights to park lands and residential areas.

I object to the proposed project. The reasons are:
1. The 50-meter lighting tower will spill significant amount of light into the nearby areas. This will irreversibly damage the biodiversity of the nearby wetlands and Parramatta river habitats. Nocturnal patterns of the floral and fauna in these areas will be severely impacted which will cause migration or extinction of some animals in the areas such as various frogs including the endangered Green and Golden Bell Frog. This is noted in the BDAR. The submission blindly stated that with louvres and orientation the spills can be avoid or limited. The submission and the engineering reports do not provide any design and lighting computer modelling to demonstrate the illuminance increase as a result of these lights operating during the night.
2. As lighting towers situate close to Silver Water road, light spills will cause visual glares to the road users during dry and wet roads conditions. This will make the already problematic Silver water bridge even more dangerous to drive with these lights on.
3. Lighting towers will raise the lux levels significantly in the cricket ground. The contrast to the adjacent site will be increased which results in a decreased perceived illuminance level of the surrounding roads, water ways and areas with the existing streetlighting. This will increase the probability of crimes and traffic accidents. This is particularly impacting the nearby correction center.
4. Light Tower 4 and Light Tower 5 are within 50 meters of the NSW transport roads.
5. The submission fails to demonstrate how community other than cricket players will benefit from the project.
6. The submission and the lighting model only consider the area within the development site. No assessment or lighting models are generated to cover adjacent areas and sensitive receivers nearby including the residents living along River Rd and Seamist Ave Ermington.
7. The impact of the improved facility will generate more traffic into the area. The project fails to demonstrate how the increased traffic can be managed on the bridge and the intersections in and out this facility.
8. The residents living directly across the river will receive harmful glares from the proposed lighting. This will adversely affect resident's circadian rhythm when they want to sleep during nights.

Regards,

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