Inland Rail - Narromine to Narrabri

I object to the proposed route for the Inland Rail because it will destroy a significant area of native vegetation in the Pilliga and seriously fragment the remaining forest and woodland ecosystems and change their hydrology.

I have lived most of my life in the New England North West region, first visited the Pilliga in 1976 and have visited the area a number of times since. As I have training in ecology and natural resource management I have taken an interest in the growing body of information that describes the unusually high values of this area.

The Pilliga has been declared as a National Biodiversity hotspot but many of its species are being threatened by various existing developments or land uses as well as ongoing impacts of past disturbance. Each new disturbance compromises the area’s values more. The cumulative impact of the proposed railway will be very significant.

It impacts on threatened species and ecological communities, on unusual species and also on the more common species that are equally essential as core components of ecosystems. All of the Pilliga’s native vegetation and fauna habitats are important

The relatively intact and continuous condition and great extent of native vegetation in the Pilliga are key elements of the area’s unusually high natural value. The size and continuity make the whole more valuable than it will be if split into parts. While existing roads and logging cause some fragmentation this is minor compared to the fragmentation effect of the proposed new railway which will be a major barrier to movement of many animal species (it will also be a barrier to people, making management of the forest more difficult but I appreciate that similar issues for land managers occur where the route goes through farmland).

The high values of native vegetation have gained increasing recognition such that the previous and current Commonwealth Governments have adopted a target of managing 30% of all land and sea for biodiversity protection by 2030. NSW is currently far short of its fair share of this target. All of the State Forests in the Pilliga should be changed to protected areas. While it is good that the route does not go through the middle of Pilliga Nature Reserve, this does not make the proposed route OK. The State Forests are also important and contribute greatly to the values of the whole. They should not be reduced and fragmented by a railway that can be routed to substantially avoid them.

Please change to a route that minimises clearing of native vegetation should be selected, going close to Gwabigar then northeast through the broad gaps between woodland/forest areas then east through farmland towards Narrabri.

Thank you for considering this submission.

Kate Boyd

I am a member of the N2N Narromine CCC. The past 4 years have been a complete waste of my time and effort. The only achievement has been to allow ARTC to tick another box.
ARTC’s definition of “consultation” is vastly different from most other people. They tell you what they have decided to do without taking any notice of community members wishes, suggestions, concerns, or anything else. With one definite and one possible exception which would be the sudden decision to change the rail alignment from passing west of Narromine to passing east of Narromine. ARTC’s documented reason for this sudden change was because of the supposedly major flood issues on the western side. This is the exact opposite of the very detailed original study done, and included in their historical documents, that an eastern alignment around Narromine was not economical due to flooding from both the run off from the Sapper Bulger Ranges and the Macquarie River’s brake out point at Webs Siding.
ARTC have recently announced that they are now going to build a 2 Km. loop on the western side of Narromine to eliminate the right angle join on the Parkes- Narromine¬- Cobar rail line. This loop will be where the original eastern alignment was proposed to go and amazingly there are no culverts provided in its detailed plans where it crosses this supposed flood problem. Narromine will now have rail lines passing North -West. plus, South – East and South -west of its township. If I was a sceptical person, I could easily think that someone had some influence in the eastern alignment decision. But I am not a sceptical person.
The one definite exception to ARTC taking any notice of community concerns was when a member of the Narromine CCC, at one of our meetings, disclosed, that after studying in detail the EIS document ARTC submitted to the Federal Government for its approval, the falsification of the amount of culvert and bridging that was required for the N2 N project. The lengths stated in the EIS are many, many, many times shorter than the total lengths required in their own documented plans.
Within 48 hours of ARTC realising that this deliberate deception has been discovered, the leader of the National Party announced that the budget for Inland Rail has been increased by 50% from 10 billion dollars to 15 billion dollars.
ARTC needs to be made to go back and do it properly and relook at alternatives especially the direct route from Tomingley, Dubbo, existing line to Coonamble, across to Narrabri via Pilliga Nation Park which is the same distance as N2N but doesn’t go through 300Km of properties
AD Channell

Please see attached for comments.

Please find attached an objection on behalf of members of NSW Farmers.

The ecological impact of a whole new transport corridor through the Pilliga, one of the last great woodlands of eastern Australia is way too severe! If we need this project at all, which is very doubtful, it should have an alignment close to those of existing highway corridors as much as possible. There are completely inadequate to conserve biodiversity. It must not proceed and contribute to the cumulative fragmentation and destruction of the Pilliga!

Please find attached a submission of objection from Australian Plants Society - NSW.

I strongly object to the Inland Rail project entering any of the the Pilliga Forest which is so significant it has been declared as a National Biodiversity Hotspot, one of only two in NSW and fifteen across Australia.
It needs to be realised that only 1% of the bioregion is currently protected in declared conservation reserves or subject to private conservation agreements which is far below the IUCN target of declaring 17% of each nation’s lands as Protected Areas, let alone the recent 30% target announced by the Commonwealth seeking to follow the IUCN 30 by 30 initiative. Conservation of the Pilliga Forest is paramount.
It is strongly recommended that the proposal be refused and pathways to the west or east of the Pilliga Forest be considered.

The enclosed document outlines my objections to the proposal.

Please see attached submission.

I wish to bring attention to the need for particular attention to protect considerable biodiversity values in a community and government funded wetland restoration project undertaken on the property “DAPPO” at the head of the Backwater Cowal. This project extends from the north east corner of the property at the intersection of Dappo Road and Wallaby Road to the western boundary of the property and can be viewed on google earth maps. Sustained community effort was invested in the project as well as considerable government and private finance which enabled remarkable success of this extensive restoration work. The restored landscape, which some have described as a biodiversity oasis in a sea of heavily cleared agricultural land, attracts numerous wetland birds, many of which breed on the site.
Attached photographs Wetland 1-4 including 2a provide a snapshot of progression of the wetland from before planting through planting and a sample of the restored wetland habitat. Numerous additional photographs are available illustrating the development of the wetland restoration project.
This project is described online at https://www.dpi.nsw.gov.au/__data/assets/pdf_file/0003/633756/Appendix-6-Wetland-management-stories_Webb_Dappo.pdf Webland Management Stories viewed 23/09/22
The following is an extract from the pdf referenced above:
ROBERT WEBB - “DAPPO”
What they did
• Reinstated a near-natural flow regime to the wetland after past drainage works by constructing a flow control structure (licensed small concrete weir)
• Undertook earthworks to create habitat for example by installing islands
• Carried out an extensive re-vegetation program
• Fenced out the wetland to enable the control of stock access
• Planted old man saltbush (Atriplex nummularia) along one boundary (outside the fence).
Why they did it
• To improve the health of the wetland that had clearly been adversely affected by past drainage works, e.g. there was no natural regeneration of wetland vegetation.
• To encourage bird life back to both the wetland and the property in general
• In the hope that the re-planted wetland would act as a windbreak (stock shelter and wildlife habitat).
Cost
• Approximately $50,000 spread over thirteen years with government funding assistance totalling about $12,000.
Assistance
• Initial funding support for re-vegetation works came from the former Department of Water Resource’s “Green River Banks” scheme
• Later assistance for the construction of the flow control structure came from the former Catchment Management Committee.
Benefits
• The overall effect has been to produce an extremely attractive wetland that provides considerable aesthetic enhancement to the property
• There has been a noticeable increase in the birdlife in and around the wetland, including regular breeding of black swans and brolgas. The owners feel that the value of the property has increased as a result of the successful rehabilitation of the wetland.
• Integrated the wetland into their primary production with opportunistic grazing.
Monitoring & evaluation
• Long term photo points have been established that clearly record the improved condition of the wetland vegetation.

Threats from the Inland Rail Route
The Inland Rail Route runs directly across the inflow to this wetland. Likely threats to the area include:
a. Sedimentation and burial of plants and soil erosion
Considerable sedimentation during construction works and soil erosion due to constriction of flow into culverts will inevitably occur unless there are rigorous measures put in place to prevent these impacts.
Due to constriction of inflow to the wetland the risk of sedimentation and erosion would be severe in the event of an extreme flood event, particularly if parts of the infrastructure failed and sections of embankment were washed away. This risk also applies to agricultural land adjacent to the inland rail development
b. Biosecurity issues, including in particular weed invasion. The weed tiger pear (Opuntia aurantiaca), which is classified as a weed of national significance, is of particular concern - see https://weeds.dpi.nsw.gov.au/Weeds/Tigerpear for description and status of this nasty spreading weed. Tiger pear was not present in the area in the 1950s but has been inexorably spreading across the landscape in intervening years. To my knowledge there is a significant infestation of the weed in Webbs Reserve, and small foci of tiger pear are spreading along Webb Siding Road.
The DPI description is as follows:
Tiger pear has sharp, barbed spines up to 5 cm long that:
• cause painful injuries to people, livestock, working dogs and pets
• injure and sometimes kill wildlife that get trapped in the spines
• devalue wool and hides and prevent shearing
• get stuck around the mouth of lambs or calves and prevent them from feeding.
Tiger pear forms dense thickets that prevent movement of animals and people. This means that:
• livestock may not be able to access feed
• mustering is difficult
• access to watering points is reduced
• recreational activities such as bushwalking and camping are restricted.
Tiger pear propagules are easily spread by vehicles as well as stock and water movement and are likely to be transported by vehicles moving between these zones as well as washed downstream through the Backwater Cowal during periods of natural inflow. With nearby infestations already spreading, extension of weed invasion is inevitable without rigorous measures to prevent it doing so.occur unless there are rigorous measures put in place to prevent these impacts.
Conclusion:
The development proponents should conduct a detailed study of the wetland area and potential threats and develop a plan to mitigate adverse impacts.

My residential property and business 150mt away from railway will be greatly impacted by this project. For my family and Town of Narrabri, please consider alternate routes that have been submitted.

Gilgandra Shire Council Submission

I object to the PIR related to the ARTC Inland Rail project Narromine to Narrabri project (N2N). The N2N section must not be approved.
It should be noted in this submission that I support the Inland Rail as a worthy national project that is likely to result in long term opportunity for the nation and the region that it serves.
This outcome is unlikely to occur along the N2N section because its PIR proposal is seriously flawed on many levels, thus at the outset, the precautionary principle should be applied by NSW Government and the responsible Minister, noting:
The Australian Government and other world governments signed an agreement stating: Where there are threats of serious or irreversible environmental damage lack of full scientific certainty should not be used as a reason for postponing measures to prevent environmental degradation.
In the application of the Precautionary Principle, public and private decisions should be guided by: (i) careful evaluation to avoid wherever practicable, serious or irreversible damage to the environment; and (ii) an assessment of the risk-weighted consequences of various options.
The Precautionary Principle is an established principle and practice following case law handed down from the NSW Land and Environment Court when determining development in sensitive areas.

• I support the Narrabri Shire Council response to the PIR and confirm support that the “route does not provide an optimum outcome for Narrabri Shire.
• I support the NSW Farmers submission
• I support the Alternative Alignment and its conclusions that are provided by Concerned Citizens of Narrabri
The bases for my objection are summarised:
1. The proposed route does not provide the best or optimal outcome for the Narrabri town and the Narrabri Shire with many unknown and non-articulated impacts on council infrastructure during construction.
2. The town of Narrabri is unnecessarily impacted in terms of flood, amenity, economic and environmental considerations.
3. The N2N alignment will result in the destruction of 1792 hectares of forest and threatened habitats, some very rare and unlikely to ever have developed offset areas available or supported, and the long-term impacts on the natural environment that is impacted are unknown, and untested in any suitable rigour.
4. An alternative route has been studied and evaluated by professionals engaged by the community.
a. This study suggests over $200m of rail construction cost can be saved in an alignment that solves most of the negative impacts that the current alignment would permanently impose on the town of Narrabri.
b. The Alternative Alignment proposed by the community would allow Narrabri to construct and operate an Inland Port and an efficient Special Activation Precinct that has rail connectivity north south east and west to Australia’s main ports, whereas the existing alignment shown in the PIR would prevent those outcomes.

As a proponent, ARTC and Inland Rail has failed to present a case to support the PIR in the following ways.
a. Consultation: ARTC Inland Rail has failed the people and the Council of Narrabri by continually refusing to consult over its proposed route. This failure to consult, as ARCT is required to under the Commonwealth Government Corporations Act, has cased significant and long-term harm to the people of Narrabri Shire and many others along the N2N alignment.
b. Flood:
i. Narrabri is the state’s third most impacted town in NSW in respect of flooding.
ii. The proponent has not addressed the community’s well-founded concerns over additional flood impacts arising from the proposed alignment and those serious potential impacts are conclusively demonstrated by independent studies which ARTC Inland Rail refuses to have properly evaluated
iii. ARTC Inland Rail’s 1% flood study identifies the route results increased flooding impacts in the town of Narrabri. Given the catastrophic flooding that NSW has seen over the past, I believe a 0.5% flood (1 in 200 year) should be the benchmark for flood impacts.
c.
i. An alternative route downstream of Narrabri has identified a route from which there would be zero impacts due to flood in a 0.5 flood event
d. Amenity:
i. The proposed route in the PIR has permanent impacts on the town of Narrabri due to a) Noise that will strongly impact on every resident in the town from an elevated rail way on the edge of town b) Values of land and assets of the most impacted residents is permanent c) the elevated noisy railway reduces the town’s capacity to offer a great place to live
ii. Noise and vibration assessments for both the construction and operation of the N2N Project are flawed in a significant way.
1. Failures on these impacts avoid discussion of actual impacts by reference to existing
2. All of Narrabri town is impacted by the noise of N2N. This does not adequately consider the impacts on sleep disturbance, and it fails to commit to appropriate attenuation such as acoustic barriers and overcoming sensitive receiver locations
iii. PIR fails with any quantitative assessment of the air quality impacts arising from the operation of the N2N
iv. PIR fails provide a genuine visual impact assessment for better understanding by the community
v. Failures to address negative impacts on amenity unreasonably restricts the scope of the assessment and continues to arrive at conclusions related to amenity impacts based on unfounded assertions and absence of data
e. Economy
i. The proposed route cuts off the town from future development – industrial and residential, permanently cutting the town in two
ii. The route is not connected with the Walgett to Newcastle rail line and any connection related to the PIR would require an investment from NSW government of at least $45m
iii. PIR cuts the Shire of Narrabri off from the proposed SAP industrial and employment lands
iv. PIR cuts the Shire of Narrabri and the State from accessing the proposed Inland Port
v. Fragmentation and severance issues and their avoidance is neglected in PIR. Opportunities to avoid these impacts are ignored, thereby causing significant adverse impacts to existing township and farming operations, rendering some businesses unviable owing to stranded private assets
f. Environment:
i. The PIR has not provided a comprehensive plan to offset the 1792 hectares of land that will be permanently razed to construct and operate the Inland Rail.
ii. Over 1m tonnes of wood will be felled. The PIR provides no information on what happens to this timber, how it will be treated, where it will be treated and what environmental impacts this extraction has on the regional environment
iii. The PIR does not reveal or discuss the additional impacts of CO2 and methane emissions results from the clearing of 1792 hectares of vegetation
1. Fears exist that rare woodland habitats will be permanently eliminated owing to the non-availability of suitable offsets
2. PIR does not identify the financial costs of creating and maintaining offsets for the 1792hecares destroyed.
iv. The Pilliga forest is effectively cut in two, and the PIR does not address the permanent impact of this to the largest temperate woodland in eastern Australia
v. It is implausible that artifacts and places of significance to first nations people will not be permanently erased and I would question fully the voracity of any study that suggests otherwise.
vi. The ecological assessment is deficient and does not adequately identify the scope of the impacts of N2N on biodiversity, this is despite the huge amounts of clearing of native vegetation, as above, that is proposed.

g. The PIR does not provide any details of how compensation would be paid for infrastructure damage to the shires along this route for inward construction materials, transport of personnel and equipment, maintenance and removal of timber.

I object to the project.

I am lodging this submission for Mr. Tom Lyons of "Parmedman" Gulargambone 2828. I received an email a little while ago to say he had to take his wife down to Sydney to Royal North Shore Hospital, (from Dubbo) as she was unwell, and asked me if I could lodge it on his behalf. I don't know if I can, but I hope it works!

Mr. Mick Fallon
Team Leader, Transport Assessments
NSW Department of Planning, Industry and Environment

Email: [email protected]

Thursday, 22 September 2022

Re: Inland Rail – Narromine to Narrabri Project – Combined Preferred Infrastructure and Amendment Report Submission

I am writing to express my concern about and opposition to the current proposed Inland Rail route around Narrabri. I am a resident of Narrabri and have been so for 24 years. My husband and I have a young family, work locally and have chosen to make Narrabri our hometown. There are many aspects of the project which I am concerned about, the most significant of which are outlined below.
• The close proximity to the Narrabri township and residential areas: the proposed route runs through and very close to residential areas which has implications not only for noise, which has not been properly assessed, but also visually will be in eyesore. The speed, frequency and height of the trains is also of significant concern.
• Disruption to traffic flows and residential streets: if the traffic estimations are correct or even close to, there will be significant disruption to Gibbons Street during the construction phase. The turning traffic into Gibbons Street would also disrupt the traffic flow along the Newell Highway. Of particular concern to me is the disruption and safety risk to the services along Gibbons Street, including the Narrabri Hospital, aged care facilities and Nurruby Childcare Services. My children attend Nurruby and given the lack of off-street parking, any increase in traffic, particularly heavy vehicle traffic, poses a huge safety risk. There is also a lack of turning lane for traffic going into the hospital which increases the collision risk with heavy vehicles.
• Disruption to existing services: one of the features of Nurruby is the ability for the children to spend time outside both for learning and play. With a heavy vehicle movement every 2-3 minutes every day, this time will be severely affected and disrupted. Noise and air pollution from the increased traffic will also result and the impacts of this have not been measured or estimated. This will similarly affect the Narrabri Hospital and aged care facilities.

While these are my concerns in regards to the Narrabri town, there are many other construction- and flood-related benefits to moving the rail line to the alternate route proposed by the Narrabri Inland Rail Concerned Residents Group, which they are best suited to outline in detail. Put simply, given the trains won’t be stopping at Narrabri, there is simply no need for the close proximity to town.
The effect of the proposed route on the Narrabri community will be negative and long lasting. There are many other features of Narrabri which are worthy of recognition and have a positive association, however a high-speed rail line isn’t one of them.

Please note, this is a resubmission (amended) of my concerns previously expressed to then Deputy Prime Minister and Minister for Infrastructure, Transport and Regional Development, Minister Joyce, on 25th November, 2021, to which no direct response was received.

Kind Regards,
Laurie Sharp

I have already made a submission. But I have an additional protest. Today 23-09-2022 I received an email titled Narramone to Narrabri Project Land Surveying and Conclusion of Public Exhibition so clearly you have the addresses of many concerned residents along the N2N route. In this email you say "We appreciate the reports are large and contain highly technical information that readers may have found difficult to understand and navigate".
Why then have you given so little time on exhibition (frightfully short for Council employees and Councillors who are working full time on other things)?
Why did you not send an email to interested parties like me to say there was a Public Exhibition at the outset. I do not take the local paper as I am just out of town. I only heard about the public exhibition a week or two ago and not from Inland Rail. In so important a matter you should take every means to publicise the exhibition to any and all.

See attached detailed reply

See enclosed.