DigiCo SYD1 Data Centre Expansion

Refer to attachment.

I do not support the application and my reasons are outlined below:
• misrepresented community consultations - no notifications so no consultations
• siting of 3 main noise monitors to establish ambient background sound + set a maximum noise level 5decibels higher - was not representative of the WHOLE area:
1 next to Western Distributor,1 on cnr of Pyrmont + Quarry sts1 on Ada place facing towards Harris st
• some diagram oversights identifying affected residences as commercial properties: ie R12 is Goldsbrough Apartment block contains 538 apartments + some office spaces R13 is part residential R10 - whole block is residential Jones st bet William Henry + Harbour Mill apartments is mainly residential
• conclusions drawn by White Pulse Noise assessment re generator noise from the site suggest that 198hrs per year that the generators will be operating for testing will be below the 200hr per year threshold + therefore Environment Protection Authority licence (POEO act 97)will be unnecessary. However they also identify the possibility that generators could run for an upto 30 hrs per year in certain circumstances
• same criteria apply to generator emissions - nitrogen dioxide + nitric oxide. If the plant runs less than 200 hrs per year it is exempt from an Environment Protection Licence.
A worst case is described + dismissed but not measured:
ie EMERGENCY SCENARIO 10pm-7am 32 cooling towers running 14 chiller units 66 generators not represented this situation is deemed unlikely so no statitics supplied. (Note this report’s measures are calculated for an indicative generator - not final selection.) Increase in generator capacity + associated plant + the estimated extra 30 hrs indicate it is not exempt from an EPA licence.
• NORTHSTAR AIR QUALITY IMPACT STATEMENT assesses the construction period should have no negative impacts as long as “appropriate implementation of recommended mitigating measures” is followed. p75
• Northstar’s operational phase impacts are modelled on 10-15 minutes of emissions even in the worst case scenario + generators are reduced by a 15% redundancy factor - it doesn’t seem a fair worst case scenario model. In 2024 during a serious heatwave AUSGRID directed Global Switch to run on their generator power to take strain off Sydney’s power grid.
(DigiCo will be the biggest user of electricity in the state if not the country).

• there are only 3 solar access diagrams provided in the Environment Impact Statement with testing hours starting at 9am. There is no diagram showing impact to the west where the heart of Ultimo is + particularly Quarry Green.
The document’s focus is largely on solar + overshadow impacts for Darling Harbour.
• a number of sustainability enhancing measures are mentioned but dismissed
• Green Travel Plan (GTP) DigiCo will? collaborate w Council + Transport for NSW to identify opportunities to improve pedestrian connectivity. Pyrmont Action have suggested that the developer contributions could go towards reinstating the continuation of the pedestrian walkway to city over Darling Harbour.
North face of the site at ground level is barren + forbidding for pedestrians particularly at night. It deserves a better connection between Harris st + Pyrmont st. A great example of pedestrianizing an alienated space is the forest of internally lit trees under the Western Distributor on opp side of Harris st. A new group of these could be introduced, visually continuing the forest towards Pyrmont st.
• the indigenous references are mentioned in passing + undeveloped + vague
• landscaping is covered extensively but not clearly - will this be a Council responsibilty? Or carried out by private landscape contractors on council paths?
• overall this EIS seems to favour DigiCo growth over fair + safe planning choices.

submission attached

There are several critical issues with this Development Application (DA) that need to be addressed:
Health Concerns – Plant running 24x7
The proposed acoustic solution is inadequate, lacking proper monitoring, attenuation, and treatment for mechanical rooftop plant.
There is no comprehensive modelling of operational loading, raising concerns about long-term noise impact.
Economic Impact
The development provides no tangible benefits to the community or the city.
Industrial buildings and investments of this nature should be located in the appropriate regions of Sydney.
IT and application loads can be efficiently serviced by existing partners and operational data centres in designated industrial zones across Sydney and NSW.
Environmental Risks
Dangerous goods & fire safety: The site plans include massive fuel storage and the potential for uncontrolled lithium installations, posing significant risks.
Health concerns: Toxic generator exhaust could directly impact residential air quality.
Power & water consumption: These essential city resources should be allocated towards sustainable urban growth, rather than unnecessary IT infrastructure.
Operational Disruptions
The development would cause a major impact during construction and ongoing operations.
Even routine plant replacement would have significant logistical challenges, given the site's location in a tourist, residential, and city district.

This rooftop development has no place in an expanding residential and tourist area. Such a development with its potential environmental, health and noise risk should never be considered in an area with a growing population. If Digico need such a development to continue their business they should undertake redevelopment in a no residential or industrial area.

Further comments below.



Health Concerns – Plant running 24x7
The proposed acoustic solution is inadequate, lacking proper monitoring, attenuation, and treatment for mechanical rooftop plant.
There is no comprehensive modelling of operational loading, raising concerns about long-term noise impact.
Economic Impact
The development provides no tangible benefits to the community or the city.
Industrial buildings and investments of this nature should be located in the appropriate regions of Sydney.
IT and application loads can be efficiently serviced by existing partners and operational data centres in designated industrial zones across Sydney and NSW.
Environmental Risks
Dangerous goods & fire safety: The site plans include massive fuel storage and the potential for uncontrolled lithium installations, posing significant risks.
Health concerns: Toxic generator exhaust could directly impact residential air quality.
Power & water consumption: These essential city resources should be allocated towards sustainable urban growth, rather than unnecessary IT infrastructure.
Operational Disruptions
The development would cause a major impact during construction and ongoing operations.
Even routine plant replacement would have significant logistical challenges, given the site's location in a tourist, residential, and city district.

There are several critical issues with this Development Application (DA) that need to be addressed:
Health Concerns – Plant running 24x7
The proposed acoustic solution is inadequate, lacking proper monitoring, attenuation, and treatment for mechanical rooftop plant.
There is no comprehensive modelling of operational loading, raising concerns about long-term noise impact.
Economic Impact
The development provides no tangible benefits to the community or the city.
Industrial buildings and investments of this nature should be located in the appropriate regions of Sydney.
IT and application loads can be efficiently serviced by existing partners and operational data centres in designated industrial zones across Sydney and NSW.
Environmental Risks
Dangerous goods & fire safety: The site plans include massive fuel storage and the potential for uncontrolled lithium installations, posing significant risks.
Health concerns: Toxic generator exhaust could directly impact residential air quality.
Power & water consumption: These essential city resources should be allocated towards sustainable urban growth, rather than unnecessary IT infrastructure.
Operational Disruptions
The development would cause a major impact during construction and ongoing operations.
Even routine plant replacement would have significant logistical challenges, given the site's location in a tourist, residential, and city district.

Please follow the instructions in the link provided if you would like to make a submission to Council in regard to this proposal. It should be noted that Council will hold in higher regard a larger volume of submissions.
There are several critical issues with this Development Application (DA) that need to be addressed:
Health Concerns – Plant running 24x7
The proposed acoustic solution is inadequate, lacking proper monitoring, attenuation, and treatment for mechanical rooftop plant.
There is no comprehensive modelling of operational loading, raising concerns about long-term noise impact.
Economic Impact
The development provides no tangible benefits to the community or the city.
Industrial buildings and investments of this nature should be located in the appropriate regions of Sydney.
IT and application loads can be efficiently serviced by existing partners and operational data centres in designated industrial zones across Sydney and NSW.
Environmental Risks
Dangerous goods & fire safety: The site plans include massive fuel storage and the potential for uncontrolled lithium installations, posing significant risks.
Health concerns: Toxic generator exhaust could directly impact residential air quality.
Power & water consumption: These essential city resources should be allocated towards sustainable urban growth, rather than unnecessary IT infrastructure.
Operational Disruptions
The development would cause a major impact during construction and ongoing operations.
Even routine plant replacement would have significant logistical challenges, given the site's location in a tourist, residential, and city

I object to this proposal for many reasons, which I will list below. But my my principal concern is for the safety of the residents, works and visitors in Ultimo, Pyrmont, Darling Harbour and beyond. The proposal is for a massive building, filled with fuel, lithium batteries, and who knows what else? It is a massive beacon and should it accidentally catch fire, or worse, be deliberately targeted by a terrorist organisation or home-grown nutter, disaster would follow. It’s not simply data that is at risk.
We live in a world where we cannot simply assume that we are safe, particularly if we live close to the centre of a big city. This proposal is entirely unsuitable and unsafe.
Other points:
Zero consultation with a community that is massively affected by this project. We all received the notification about the project yet somehow your consultants were unable to find a letterbox, or a community group, to arrange consultation. I received nothing, nor did my neighbours in Bulwara Rd, Ada Place, Harris St, Jones St, Fig St, Quarry St, William Henry St, Allen St….
Genuine, public consultation must be undertaken.
Environmental Factors: The current building is already massive. If this proposal is approved it will loom like a malignant giant, dominating the area to the west, reducing sunlight and access to sky, and creating a feeling of ‘living in the shadow’ of a building that has no interaction or interface with the surrounding area. It will particularly affect residents in Harris St opposite (yes, people do live in these terraces) and in Ada Place, which also has a pocket park. Ultimo is a Heritage Conservation Area. This proposal makes a mockery of conservation and community.
Energy Use: Will this project use solar power or is it relying on the use of fossil fuel? It is already a massive user of energy (and in 2024 during a heatwave, was directed to run on their generator power to take strain off Sydney’s power grid). New projects of this size must have their own environmentally appropriate power source.
Noise and Pollution: Unsurprisingly, the models done by White Pulse Noise suggest that the generators will operate just below the 200hr per year threshold, and thus not require an Environment Protection Authority licence. They do say that possibility the generators could run more, but that would be in exceptional circumstances. And if this happened, who would be monitoring it, and who would tell the community. It is a joke. The same joke is being played on us about the toxic emissions. Without an EPA licence, who will monitor, and who will tell the neighbours if they don’t do the right thing?
These are my concerns in a nutshell. This feels like an already outdated, inappropriate project , being pushed through regardless because whoever bought it wants to make money. It must not be approved.

There are several critical issues with this Development Application (DA) that need to be addressed:

1. Health Concerns – Plant running 24x7
- The proposed acoustic solution is inadequate, lacking proper monitoring, attenuation, and treatment for mechanical rooftop plant.
- There is no comprehensive modelling of operational loading, raising concerns about long-term noise impact.

2. Economic Impact
- The development provides no tangible benefits to the community or the city.
- Industrial buildings and investments of this nature should be located in the appropriate regions of Sydney.
- IT and application loads can be efficiently serviced by existing partners and operational data centres in designated industrial zones across Sydney and NSW.

3. Environmental Risks
- Dangerous goods & fire safety: The site plans include massive fuel storage and the potential for uncontrolled lithium installations, posing significant risks.
- Health concerns: Toxic generator exhaust could directly impact residential air quality.
- Power & water consumption: These essential city resources should be allocated towards sustainable urban growth, rather than unnecessary IT infrastructure.

4. Operational Disruptions
- The development would cause a major impact during construction and ongoing operations.
- Even routine plant replacement would have significant logistical challenges, given the site's location in a tourist, residential, and city district.

As a resident impacted by this project I object because:
1. Inaccuracies in the EIS e.g. some diagram oversights identifying affected residences as commercial properties: ie R12 is Goldsbrough Apartment block contains 538 apartments + some office spaces, R13 is part residential, R10 - whole block is residential, Jones st bet William Henry + Harbour Mill apartments is mainly residential
2. Exemption from a Environment Protection Authority licence is based on projected base line generator noise with an acknowledgement in the submission that this may well be exceeded on occasions - this project SHOULD be subject to a Environment Protection Authority licence
2. Visual impact and solar access impact on neighbourhoods to the west of the site have not been sufficiently investigated or presented
3. Limited consideration of strategies (e.g. solar) to mitigate the huge impact on power usage

This EIS appears to favour DigiCo growth over fair and safe planning processes including addressing concerns of near neighbours.

The proposed increase in height of the building will increase overshadowing of the residential houses along the west side of Harris Street, and of houses in Ada Place, Quarry Lane, Fig St, Bulwara Road and Jones St. Residents in these areas will also be impacted by noise and emissions during construction, and increased noise and emissions during operation of the data centre.

I still object to this expansion for the additional reason below:
Noise from road traffic
Buildings amplify traffic noise due to the way sound waves reflect off their surfaces. This phenomenon, often referred to as the "urban canyon effect," can significantly increase noise levels in areas with dense buildings, especially along streets where buildings line both sides.
Buildings act like hard surfaces, reflecting sound waves instead of adsorbing them. The traffic noise that initially heads upward away from the ground is eventually turned back toward the ground, focusing the noise over a small area located approximately 3/8 of a mile (550 -600 metres) from the roadway.
Increasing the height of buildings can result in an increase in road noise level. Studies have shown that traffic noise can increase by a few decibels (e.g., 3.5 to 6.32 dB(A)) for every 10-15 metres of building height.
In summary, there is a general trend of increased road noise with building height.
ACTION: The above demonstrates that if the height of the Digi Co building is increased the residents living close by will be inflicted with increased traffic noise levels for example Harris Street and Ada Place.

Pyrmont Action is a community group focussed on the health safety and amenity of our community and our neighbours of Ultimo and Glebe.

We consider this proposal needs material change

There does not appear clarity around demolition / construction and conditions imposed to protect near by and local residents. There should also be regular updates and consultations to enable improvements if /when required.

I would ask that dust and noise monitors be used and reported upon.

To safeguard urban biodiversity, the NSW Government needs to include ecological noise assessments and strict emission standards for the Ultimo data centre and all NSW data centres in all planning.

Solar should be considered

Finally we are advised the AEMO has requested some changes to data centres rules due to their rapid and ongoing growth and would ask that the Market Operator be involved in any changes.

Ken Louden Deputy Convenor

Pyrmont Action m- 0414997089

I am attaching a few pages in the hope that should this expansion succeed, the promises to monitor all forms of pollution whether in the construction phase, the day to day running and the unexpected rare of occurrence of a power outage like way back in year 2024, are taken seriously and also the assurance that the HCA will not lose the one power source that we really need, solar. I have panels and will be monitoring any difference to the solar plane vigilantly.

My submission is in the attached document

Please find attached the Friends of Ultimo's submission to the referenced project to which we OBJECT

Please see attachment for explanation

Please see attachment for my submission.

In my submission there are three points raised that are issues.