Gazcorp Industrial Estate

I object to the proposed breach of the offset methodology chosen to address the ecological impacts of this development.

The discounting proposed for the required ecological offsets (Appendix F2 - 5.3.3 Proposed Offset for the Project) is not justified. The proponent proposes an offset comprising 50% of the ecosystem credits indicated in the BioBanking Assessment.

The reasons presented for offering just half of the required offsets are:
1) The vegetation to be destroyed is degraded
2) Net-Loss offsets are permitted in principle
3) Some Forest Red Gum woodland will be retained and restored on site
4) Restoration of Reedy creek will redress impacts on Southern Myotis

Each of the reasons presented are unfounded. To respond to each in turn:
1) The degraded nature of the site has already been automatically factored into the BioBanking offset calculations. If the site were intact the offset requirements from the BioBanking Calculator would be greater than the 259 credits currently required.
2) The BioBanking scheme already provides a net-loss scenario in practice; in fact it requires net-loss at a landscape scale in order to operate although the level of loss is mitigated to a minor degree through restoration works.
3) The woodland retained on site is irrelevant to offset requirements. The offsets calculated are for the woodland proposed for destruction and are not discounted by vegetation retained. On the contrary, even with proposed restoration works the vegetation retained will substantially deteriorate as an inevitable result of the nature of the proposed development. Rather than discounting the offset required, the applicant should be required to offset the damage to the vegetation retained as well.
4) The site in the context of the proposed development will not even approach the habitat requirements for Southern Myotis. Irrespectively it is not valid to consider the vegetation retained (which will have little to no ecological value in its industrial context) as in any way mitigating the vegetation destroyed.

I strongly urge NSW Planning & Infrastructure to maintain the integrity of the BioBanking assessment and require a full offset. Breaching the offset methodology would constitute a serious precedent and compromise any future ability to maintain any standards in this regard. The BioBanking scheme is already the compromise - we cannot provide endless concessions to environmental standards in what is now a Critically Endangered ecosystem.
Regards,

Pete Ridgeway
BSc MECA MESA

Gazcorp, a developer alleged in the ICAC to be a regular contributor to a secretive fund designed to avoid disclosure of developer donations to members of the government elected in 2011, seeks here to approval from that government for a development on a 52.2ha site at 813-819 Wallgrove Road, Horsley Park.

Such a method of behaviour,if proved, leaves little to the imagination as to intent.

Here we have a development proposal and accompanying documentation seeking the highest monetary gain with minimum environmental consideration.

This matter also demonstrates the farce that is community consultation to preserve a weighting toward development interest in a sorry generation of public administration.
"Hired Gun" consultants exist and are sought out by development proponents who have greater regard for quick and maximum financial return at cost to the environment. Those "Hired Guns" are given full access to a site and produce a report favourable to a development proponent's intention and the public have no means to affirm or deny what the consultant claims to have seen on site. The community is obliged to trust the consultant's assertions because the 'system' assumes integrity. That is a serious failing! All is well in the confected 'fairy dairy' land of government administration where, for the sake of expediency and serving of development interests, everyone is 'good' and no valid means exists to question whether consultants operate independently or in-step with unscrupulous developers. In such an environment no means exists to weed such consultants from the industry.

Peculiar assistance seems to have been afforded the proponent in the months leading up to preparation of the development proposal by way of Fairfield City Council failing to continue the Biodiversity Corridor that is Reedy Creek as it flows through and behind the Gazcorp development property. The Biodiversity Corridor zoning ends immediately south of the Gazcorp property boundary and resumes just beyond. What a boon for Gazcorp! How did that come about? It is odious to the senses.

The proposed development footprint, large as it is, necessitates destruction of remnant stands of Cumberland Plain Woodland (CPW) and a portion of River Flat Eucalypt Forest (RFEF). The former, in both Commonwealth and State environmental protection legislation is listed as a Critically Endangered Ecological Community. The latter is listed only in State environmental protection legislation. EPBC Act listed and TSC Act listed fauna species are said to have been observed on site.

Of 52.2ha of area, we estimate that only 33% is tree canopy yet the proponent intends retention of only about 7% of that tree canopy. This is a very poor environmental outcome.
Further, EPBC Act consideration is eliminated by the environmental consultant making an assertion we cannot test that Cumberland Plain Woodland (or Cumberland Plain Shale Woodlands) on site does not meet threshold criteria for consideration. We are expected to accept that minimisation assertion without being able to inspect the site.
In further minimising the value of remnant stands of Cumberland Plain Woodland on site the environmental consultant asserts the stands are highly degraded and we are expected to accept this as well. Exposing a fault in methodology and a leaning to the development proponent's wishes, the environmental consultant inappropriately uses the "degraded" woodland in the Biobank assessment calculator to determine offset credits at 50%.

Further, little consideration is given to the future of fauna said to be detected by the environmental consultant. Even to accept the findings of the environmental consultant it is clear that a high number of fauna inhabit or forage on the site. High in that figure is the number of fauna species likely to inhabit or forage around the rural dams on site. Seven species of frogs on site and more than a dozen water birds will be significantly impacted by the removal of existing rural dams in addition to the invertebrate species which have been established in population during the life of the rural dams. These species obviously exist in number because of the popularity of the site demonstrated by the quantity of water birds identified in the fauna survey, some of which show up in the photo on page 3-21 of the report. However, no consideration has been given to identifying the species of invertebrates inhabiting the dams and only scant regard is given in the flora and fauna survey to what humane measures will be demanded and overseen in the proposed draining and bulldozing of rural dams on site and the removal of trees and understorey from the site.

Should sustainability be ignored and the larger rural dam be approved for removed we urge humane procedures, overseen by an independent body such as WIRES and not a 'Hired Gun" for the developer.

We urge the reduction in size of the warehouse proposed in the western part of the site to enable retention of the large rural dam in that area. It obviously attracts a high presence of water birds and frogs including EPBC Act listed bird species and a TSC Act listed species which would likely prey on some of those species.

Rural dams are identified in the NSW Urban Bushland Biodiversity Strategy (1997) as affording value for biodiversity conservation. Development pursuits across Western Sydney have introduced measures to ensure fast escape of stormwater along creeks the consequence has been less water retention outside of rain events. It has been rural dams which have played a vital role in sustaining water bird population and invertebrates in Western Sydney.

We question whether the removal of the larger rural dam is wise on another front - it undoubtedly has played a function in trapping water on site in events of flooding of Reedy Creek. The course of Reedy Creek immediately south of the Gazcorp property makes a near 90° deviation to the west before resuming a south to north flow along the western boundary of the site. It defies commonsense to believe that extreme flood events have not, in the past, caused the breaking of the bank of Reedy Creek at that point rather than make the 90° deviation to the west. Such events in future will result in the inundation of the proposed warehouse. The Hydrology Report seems silent on this.
Once again we urge denial of the warehouse size proposed in the western part of the site, retention of the rural dam and denial of any attempt to alter the bank of Reedy Creek or anything near the bank of Reedy Creek in the way of earthworks or levee to prevent or minimise flood flows of Reedy Creek into the proposed development site.

Summary

Blacktown & District Environment Group Inc opposes the development proposal in its present form. Inadequate means exists to test the assertions of the environmental consultant, errant formulation of biobank credits, excess loss of Cumberland Plain Woodland, unwarranted removal of the larger rural dam and associated fauna, potential flood risk with size and alignment of warehouse in western part of the site underline our concerns and ruging for rejection of this proposal.

I am writing this submission on behalf of myself, my wife and her 89 y.o. War Service pensioner father who all live at our home at the address given in my details.

I would like to advise four key concerns (and one observation) we have about this proposal which will have a severe impact on adjoining residents such as ourselves and other residential neighbours living in Burley Rd, backing onto this proposed project.

1) Traffic congestion on Wallgrove Rd.
Our family has lived here for 30 years and most recently over the past few years our travel to work along Wallgrove Rd has been greatly affected by developments fronting Wallgrove Rd. The killer is traffic lights slowing traffic causing drivers to be impatient.
If you start at the first set of traffic lights at Old Wallgrove Rd heading South along Wallgrove Rd you come to a second set of lights after only 300 mtrs at the entry for Northbound traffic onto the M7. Then 200 mtrs later is a third set of traffic lights at the entry to the Tip. A further 300 mtrs on there is the fourth set at Roussell Street accessing that section of Industrial Estate on the RHS. A further 500 mtrs and the proposed new fifth set for the proposed new Southern Link Rd opposite the current entry to the brickworks will be located. Then to this new development proposes a 6th set of lights for entry into Gazcorp's new estate again on the RHS in what I estimate to be another 300 to 500 mtrs. Thus we have SIX sets of lights in a maximum of 1,800 mtrs, it would be faster to walk that distance than it will be to drive it with so many lights.

I have read the "requirements" of the RTA who supposedly would not allow access to this estate of the proposed Southern Link Rd. But realistically that will be the better option to alleviate traffic flow on Wallgrove Rd. I am sure you will agree that as further development occurs along the Southern Link Rd, estates will of course have access off that Rd just as there are lights now on the new Lenore Rd extending from the existing (still incomplete single laned) Old Wallgove. It seems to me that this estate should be the first allowed off the newly proposed Southern Link Rd for this reason. This development should not therefore be allowed to commence until the new Southern Link road is constructed and access to the Gazcorp site is given. This decision will at least alleviate another set of lights so close to 5 other sets in such a short 1,800 meter distance.

2) If it were deemed that the access must be from Wallgrove Rd (despite my justification in pt 1 above) then certainly this development MUST not be allowed to occur until the section of Wallgrove Rd which fronts this development is upgraded to the two lanes and traffic lightsinstalled with turning lane depicted in the Gazcorp traffic plan is first constructed. If this development were allowed to even start Stage 1 construction, there will be traffic nightmares as there is only one lane running either way in front of this site on Wallgrove Rd. If the development were to commence before the new dual laneway is constructed with traffic lights I believe there would be many accidents with heavy vehicles accessing the site and probably because of the size of trucks entering, deaths. More so accidents with heavy vehicles heading South along Wallgrove Rd and trying to turn right into the site, crossing traffic heading in a northerly direction.

3) Site noise from Gazcorp's estate affecting the existing properties adjacent - i.e. Burley Rd.

I was involved in another community group objecting to the proposed Jacfin Warehouse and Light Industrial facilities site over near Capitol Hills. I have exactly the same concerns that residents in Greenway Pl had about intrusive noise onto their properties that back onto that estate and the BUFFERS they requested to alleviate such noise.

Looking at the construction plan submitted by Gazcorp the various Industrial units walls will be very close to our rear boundaries and many others backing onto this estate.
To help alleviate noise (despite the noise tests done for this proposal on land in Flavex Ln) I submit that there should be two noise buffers created to help residential occupiers in Burley Rd. Firstly the rear walls of any building should be at least 20 mtrs off our rear southern boundaries not the minimal 5 meters proposed. Most occupants in properties that front Burley Rd have livestock in paddocks behind their houses and these livestock will be greatly disrupted by noise if the buildings are too close to rear boundaries.

Secondly there should be erected by the developer buffer fences at least 3 mtrs high all the way along the rear boundaries of properties in Burley Rd. I note in the construction plans lodged, that Gazcorp proposes a 3 meter high buffer running the length of the Southern side of Unit 10 only. The 3 meter high buffer would offer the same protection offered to residents below unit 10 to all other occupants behind units 3 - 9 along our rear boundaries. We believe that if these two precautions were inbuilt our quality of life through noise abatement would be more likely to be tolerable.

4) Affect of Storm water from the site onto lower lying land again fronting Burley Rd.

We are not knowledgeable in such confusing matters as stormwater but we do know from experience the difficulties we face during extaordinary heavy rain periods causing flooding onto our land. The Dept MUST ensure that the plans submitted make allowane so that our properties do not become bogs when heavy runoffs flow from this new development onto our lands.

Now the one observation which of course is not as serious an issue as is the above 4 points.

I note that the Political Donations Disclaimer lodged by both Gazcorp and Mr Nicholas Gazal, does not include the hundreds of thousands of dollars found by ICAC to have been illegally donated to the Liberal Party through the Eight by Five fund. I see in the Daily Telegraph on both Saturday 17th May Page 9 and again on Tues 20th May page 2, continual reference is made to donations by Gazcorp. Why is it that these donations are not shown on the donation disclosure shown in this lodgement.

As these donations are not listed, is the missing donations a factor serious enough to delay the approval of this site. I am sure that the donations were not shown here for the serious reason of not recording assistance given to the Liberal party in return for construction favours such as this project.

I thank you for enabling us to express these concerns.

please refer to attachment

Please find attached signed submissions/objection letters from neighbours surrounding the proposed industrial estate.

Please find attached Submission & Objection documents regarding the DA proposal for Gazcorp Pty Ltd at Horsley Park.