Julius Avenue Data Centre

I am a local resident and interested in the protection of Lane Cove National Park. I frequently visit Lane Cove National Park for recreational purposes (walking on the Great North Walk). I also actively do volunteer bush regeneration in the Lane Cove National Park.
On my frequent walks in the Lane Cove National Park I pass near the new data centre located on Apollo Place the other side of the Lane Cove River at Lane Cove West. I am of the impression that the proposed data centre at Julius Avenue has similarities to the Apollo Pace data centre including numerous cooling towers and generators. I am dismayed by the continuous hum from the Lane Cove West data centre clearly audible from the Great North Walk. If this is replicated at Julius Avenue it will impact mine and others enjoyment of the natural area. Goodness knows the impact of noise on native fauna including bats and Powerful Owls. The EIS information does not provide any tangible details of noise mitigation that will be installed for the cooling towers. Approval should be subject to mandated low-noise design specifications, including fan speed modulation, acoustic louvres, and enclosure performance ratings. I am also disappointed that the EIS does not consider the National Park as a sensitive receiver in terms of noise.
The proposed data center requires the permanent clearing of native forest. The scale is not one or two trees; it calls for the clearing of over one hectare of valuable bushland. I do not believe that there has been adequate assessment of the bushland proposed to be cleared. There is a complex ecosytem established over millennia, even more than the hundreds of trees that will be removed. The EIS should include consideration of alternative sites on land that have already been cleared.

I have seen firsthand the resilience of our native bush. Areas that contained invasive weeds have with appropriate bush regeneration techniques transformed into high functioning habitat for a range of native flora and fauna. The EIS does not appear to recognize the value of the remanent bushland. A more detailed biodiversity study should be conducted with professionals experienced in this unique and complex bushland.
There is no apparent link between constructing the data centre and caring for Lane Cove National Park. At a minimum, with all the storm water runoff from the data centre into the National Park and disturbance from running electrical supply, the proponent should be required to provide annual funding to Lane Cove National Park so they can engage and manage professional bush regenerators into perpetuity to care for the downstream disturbance.

The attached submission is on behalf of Friends of Lane Cove National Park. While not having an in-principle objection to a Data centre development on this site we believe that the current proposal is a major over development of the site and note that the proponent is asking for almost double the height allowed in the Ryde LEP for developments in this area, which will have serious over shadowing effects on important native habitat in the Laner Cove National Park.
The submission details our concerns and details suggestions to make this development compatible with its location adjacent to a National Park.

I am a local resident and frequent user of the Great North Walk and Lane Cove National Park. I strongly object to the proposed data centre near the Julius Avenue entrance in North Ryde.
Key concerns:
Loss of critically endangered ecosystem: The proposal involves clearing 509 trees and impacting 1.2 hectares of Sydney Coastal Enriched Sandstone Forest—a critically endangered ecological community. The proponent’s own Biodiversity Development Assessment Report (BDAR) flags potential serious and irreversible impacts on biodiversity.
Threatened species at risk: The site is known habitat for three threatened animal species and four threatened plant species, which would be further jeopardised by clearing and ongoing industrial activity.
Noise and amenity impacts: Continuous mechanical noise from cooling systems and backup generators would degrade the tranquility of Lane Cove National Park, disturb native wildlife, and diminish the experience for bushwalkers and the broader community who value this natural setting.
Inconsistency with planning and climate policy: The area sits within a designated landscape setback under the Macquarie Park Design Guide, intended to retain mature vegetation and reinforce the green character. Extensive tree clearing in this setback appears to contradict the NSW Government’s stated objectives for rezoning, amenity, biodiversity conservation, and climate change policy.
Better land use options: The Macquarie Park/North Ryde rezoning seeks improved housing and amenity outcomes. A high-impact, noise‑generating facility in a sensitive, vegetated setback undermines those aims and sets a poor precedent.
Requests:
Refuse the development application in its current form on the basis of unacceptable, potentially irreversible biodiversity impacts and conflict with established planning controls and policy intent.
If not refused, require a fundamentally redesigned proposal that:
Avoids clearing of the critically endangered ecological community and maintains the full landscape setback with no net loss of canopy;
Demonstrates no serious and irreversible impacts consistent with the BDAR and Biodiversity Conservation Act principles;
Implements enforceable noise limits that protect national park values and wildlife;
Provides genuine like‑for‑like biodiversity offsets only after exhausting avoidance and minimisation, with independent ecological peer review.
North Ryde’s bushland is irreplaceable. Please prioritise biodiversity, community amenity, and climate-aligned planning over an inappropriate land use at this location.

I support technology advancement, AI and the need for additional data centres across Australia and in Sydney. I am a civil engineer and have worked in project mangement of major SSD developments for both the NSW Government and the private sector over the past 25 years.
The site is presently heavily treed with both regrowth and original established tree canopy, possiblycovered by as much as 75% mature trees and is ossentibly part of the Lane Cove River foreshore and animal habitat corridor.

The design and landscape plans shows that nearly all exisitng tree cover on the site are to be removed but does not show any detail on this matter. The landscape plan shows extensive replanting of trees around carparks, new internal roads and the buildings.

The Applicant , ISPT on their website via an AI SUMMARY states a strong commitment to ESG compliance and principles:
"ISPT has strong green credentials, achieving 100% carbon neutral certification for its corporate offices and base building operations on owned and operated properties. This certification, awarded by Climate Active, is part of a broader ESG strategy focused on climate change, resource efficiency, and social impact. ISPT's efforts include reducing emissions, increasing renewable energy usage, and prioritizing circular economy principles. This proposed design shows that ISPT has complete disregard for the impacts and risks of this development on the environment now and for the life of this data centre and is contrary to their corporate motherhood statements.

In the EIS page 22/23 section 2.7.2 reference is made to the North District Plan and that the Greater Sydney Commission's strategic aim includes at bullit point 9 "Enhancing the quality and improving access to open space, and increasing urban tree
canopy;" The design does just the OPPOSITE. The design shows the removal of the tree canopy over the steeply sloping site abutting the Lane Cove River.
At section 6.1.13.2 Water management commentary is provided referencing TTW's OSD and stormwater management calculations but the sensitity of this location immediatly adjacent to the Lane Cove rRver is lost in this application. All that is stated is that the modelling is in compliance with "Stormwater has been designed in accordance with the RDCP 2014 and the Stormwater Management Technical Manual 2014. RDCP 2014" and DRAINS modelling.

Futher the applicant seeks approval for 1,272,000 litres of diesel to be held onsite presumably to run the diesel back up generators and 35,280 kilograms of Lithium ion backup baTteries. These are huge numbers and totally out of proportion with any exisitng commerical use in the Macquarie Park precinct. Each has these has the potential to create immense environmental damage and runoff both during construction and once the data centre goes into operation. The risk to the habitat in and adjacent to the Lane Cove River and then downstream to the Parramatta River and Sydney Harbour cannot be overstated. There is no risk management plan and the applicant does not seem to be aware of the risks this project whll create.

The proposed site seems totally inappropirate for use as a data centre AND THIS APPLICATION SHOULD BE REJECTED ON THIS SITE IN FULL.

I am objecting to the proposed Julius Ave Data Centre adjoining Land Cove National Park.
It is a gross over development of the site and will result in massive damage to the adjoining Land Cove National Park:
• The removal of over 500 trees
• The loss of the important habitat corridor adjacent to the Park
• Visual damage to the international tourist attraction, Great North Walk which stretches from Sydney to Newcastle
• Loss of habitat for threatened fauna species:
o Large-eared Pied Bat Chalinolobus dwyeri
o Large Bent-winged Bat Miniopterus orianae oceanensis
o Little Bent-winged Bat Miniopterus australis
• Loss of habitat for threatened plant species:
o Darwinia biflora
o Rhizanthella slateri
o Hibbertia spanantha
o Deyeuxia appressa
I also gather that data centres are huge consumers of water and huge producers of heat. This is totally inappropriate in this location.
The Application must be rejected.

Dear DPHI,
The project is objected to because the Land Use System needs urgently to be updated with new protection zones, new concepts for landuse and new planning controls in the Age of Environmental Breakdown. The planning system needs to consider cumulative environmental impact. I would like to submit a Planning Proposal which will itself be a State Significant Proposal - in order to achieve the Update in the Planning & Development System. I am happy to assist the system. Thanks, Janet.

I object to this project due to the significant loss of urban bushland which will occur if this development is to go ahead. These areas of bushland, particularly those adjacent to national parks are critical for providing habitat for wildlife and build biodiversity, particularly in an area which contains critically endangered the turpentine ironbark forest ecological community. This community is endangered for this very reason, urban development has continually cleared land. Once land is lost is takes decades to recover, if there is even the chance for this to occur. The proposal to plant trees at another site to replace the trees lost is insufficient as, firstly where will these trees go, there is no guarantee that site will be protected and similar environmental credit based schemes have proven to ineffective. The governments environmental credits for the building of the M7 motorway two decades ago are still yet to be realised. The data centre will have to find another location elsewhere where there is not the destruction of key habitat.

1. Executive Summary

This submission is lodged as a formal objection to the proposed development of a large-scale data centre on Julius Avenue, situated on land that currently functions as an environmental buffer between a suburban area and the adjacent Lane Cove National Park. The proposal, which involves the clearing of over 500 mature trees, represents an unacceptable environmental, social, and economic impact on the local community, the regional environment, and the integrity of planning principles that are designed to protect areas of high ecological and amenity value.

The proponent claims that the loss of over 500 established trees will be offset by the planting of 750 saplings elsewhere. However, such a proposal demonstrates a fundamental misunderstanding of ecological equivalence. A mature tree cannot be simply replaced with a seedling, either in ecological function, carbon storage, or habitat provision. This development threatens to irreparably damage local ecosystems, undermine the ecological connectivity of the national park, diminish the suburb’s liveability, and significantly devalue the surrounding area.

For the reasons outlined in detail below, the development is inconsistent with local, state, and federal planning principles, conflicts with environmental protection laws, and fails to meet the public interest test. It is therefore submitted that the application should be refused.

2. Description of Proposal

The proposed development seeks to construct a large-scale data centre complex on Julius Avenue, within land currently functioning as a buffer between residential areas and Lane Cove National Park. The key elements of the proposal include:

Clearing of over 500 mature trees, many of which are native and form part of a continuous ecological corridor.

Construction of industrial-scale data storage buildings, including significant hardstand areas, cooling infrastructure, and associated access roads.

Provision of an offset strategy, involving the planting of 750 trees at unspecified alternative sites, rather than on or adjacent to the subject site.

Ongoing 24/7 operations, including cooling systems and energy supply infrastructure with significant noise and heat outputs.

This site is wholly unsuited to such a development due to its proximity to sensitive natural areas, its current ecological value, and its role as a transition zone between suburb and national park.

3. Context of the Site

Julius Avenue sits on land that provides an important buffer zone between urban development and Lane Cove National Park. Buffer zones perform essential ecological and social functions, including:

Protecting the integrity of natural areas from urban edge effects (noise, light, invasive species, pollution).

Providing critical habitat and wildlife movement corridors for species that rely on transitional vegetation.

Offering the community access to green space, visual amenity, and a sense of separation from industrial development.

Acting as part of the climate adaptation strategy of urban areas by mitigating heat island effects and sequestering carbon.

The proposal to remove over 500 trees in this buffer directly undermines its purpose and risks creating long-term ecological fragmentation, loss of amenity, and devaluation of the suburb.

4. Environmental Impacts
4.1 Loss of Mature Trees

The removal of 500+ mature trees cannot be equated with the planting of saplings elsewhere. Mature trees:

Provide exponentially greater carbon sequestration than young trees.

Offer essential habitat for birds, bats, insects, and arboreal mammals.

Regulate microclimate and reduce localised heat.

Intercept stormwater, reducing flooding risk.

This loss represents decades, if not centuries, of ecological capital being erased. Planting new trees will not compensate for the immediate and sustained loss of function.

4.2 Impact on Biodiversity and Ecosystems

The site lies adjacent to [National Park name], which contains sensitive ecosystems and protected species. Removing the buffer will:

Expose the park to invasive weeds and edge effects.

Disrupt wildlife corridors used by species for feeding, nesting, and migration.

Cause noise, light, and air pollution spillover into the park.

Increase vulnerability of local fauna to vehicle strikes, predation, and displacement.

4.3 Heat Island Effect

Large-scale hardstand and building construction will increase localised temperatures, intensifying heat island effects. In an era of climate change, removing 500+ mature shade trees in favour of concrete is contrary to both state and local climate resilience strategies.

4.4 Carbon Storage Loss

The 500+ trees slated for removal currently store significant carbon. Their destruction will release carbon dioxide into the atmosphere, worsening emissions. Replacement planting elsewhere will take decades to re-absorb equivalent amounts, by which time the climate crisis will have further intensified.

5. Community and Social Impacts
5.1 Loss of Buffer Zone

Residents and business rely on the vegetated buffer for amenity, mental health, and sense of place. Its removal erodes community identity and reduces quality of life.

5.2 Amenity and Visual Character

A large, industrial-scale data centre will be visually incongruous with the natural surrounds, replacing greenery with bulk built form. The loss of green outlook will significantly degrade residential amenity.

5.3 Noise and Light Pollution

Data centres operate 24/7, with constant noise from cooling systems and significant light pollution for security. These impacts will extend into the night, degrading local liveability.

5.4 Traffic and Safety

Construction and operational traffic will increase congestion on local roads, raising safety risks for pedestrians and residents.

5.5 Property Devaluation

The removal of natural buffer areas and insertion of an industrial-scale development will inevitably reduce property values in surrounding suburbs. The perception of degraded amenity and increased noise, heat, and traffic will make the area less desirable.

6. Strategic and Planning Inconsistencies
6.1 Local Environmental Plan (LEP) and Development Control Plan (DCP)

The proposal conflicts with the objectives of the LEP and DCP, which seek to:

Protect and enhance environmental values.

Maintain amenity and character of residential and natural areas.

Prevent development that is incompatible with surrounding land use.

6.2 State and Federal Protections

The removal of 500+ trees adjacent to a national park may trigger obligations under:

The Environmental Protection and Biodiversity Conservation (EPBC) Act, if threatened species or ecological communities are impacted.

NSW Biodiversity Conservation Act, where biodiversity offset obligations apply.

6.3 Public Interest Test

The proposal fails the public interest test under planning legislation. It delivers private benefit for a corporation while imposing public costs through environmental loss, community amenity degradation, and devaluation of property.

7. Alternatives and the Precautionary Principle

The proponent has failed to adequately consider alternatives, such as:

Redeveloping brownfield or industrial sites already cleared of vegetation. One such site is currently located in Macquarie Park inbetween Epping Road, Wicks Road, Waterloo Road.

Retrofitting existing commercial/industrial buildings.

Dispersed smaller-scale facilities across less sensitive areas.

Under the precautionary principle, where serious or irreversible environmental damage is possible, lack of full scientific certainty must not be used to justify approval. This principle strongly applies here.

8. Conclusion

The Julius Avenue proposal is fundamentally inappropriate. It would destroy more than 500 mature trees, erode a vital buffer to a national park, damage biodiversity, diminish amenity, increase heat island effects, and devalue the surrounding community.

The offset proposal of planting 750 trees elsewhere is wholly inadequate, failing to replace lost ecological value or community amenity.

The development is inconsistent with local planning controls, state biodiversity protections, and the broader public interest. Alternatives exist that could meet the proponent’s needs without sacrificing irreplaceable environmental and community assets.

For these reasons, this submission formally requests that the development application be refused in its entirety.

Objection to SSD-80018208 Julius Avenue Data Centre development, North Ryde

I am very concerned about the proposed construction of a data centre and new road through the bushland site in Julius Avenue, North Ryde. The site sits within Lane Cove National Park, and as such must be protected. The proposed removal of ~500 mature habitat trees is unfathomable, given the state of nature in NSW. Excavation of the site and construction will result in a high likelihood of damage to surrounding bushland and pollution of the Lane Cove River. I also have concerns about the impact of ongoing data centre operations on native species living and moving through this critical wildlife corridor.
I urge the NSW Government to consider the extensive environmental harm that will result from this project and refuse the application. An alternative location should be investigated, distancing the data centre away from sensitive native bushland that our government has a responsibility to protect.
Fundamental problems inherent in this proposal include–
1. Inadequate assessment by the developer
A demonstration of avoidance of negative biodiversity impacts is the fundamental first step in the project approval process, under the Biodiversity Conservation Act 2016. Before considering offsets, developers must demonstrate that they have taken all reasonable steps to avoid harm to biodiversity values and identify conservation measures. The Biodiversity Development Assessment Report (BDAR) provided by SLR Consulting does not indicate any attempt by the developer to avoid impacts to native vegetation and threatened species.
2. Destruction of tree canopy & biodiversity
The proposed removal of ~500 mature trees from a Threatened Ecological Community is unacceptable. It would result in a significant loss of habitat for protected native species. The considerable narrowing of a vital wildlife corridor along the river foreshore presents a real threat to wildlife safety. The high number of tree removals also adds to the broader environmental burden by increasing the urban heat load, impacting human and wildlife health.
The NSW Government has committed to increase Greater Sydney’s tree canopy to 40% by 2036. State Government mapping by ArborCarbon in 2022 indicates that it currently sits at just 21.7%. Importantly, Northern suburbs surrounding the site experienced the greatest loss of coverage. The Ryde LGA lost almost 8% compared to 2019, Lane Cove -6% and Willoughby -5%. Apart from the critical role tree cover provides for wildlife and biodiversity, there are also numerous human health benefits delivered through cooler temperatures and clean air. High-value urban tree cover like that on this site must be protected.
Loss the critical protective foreshore habitat corridor is unacceptable, as is the loss of established tree hollows and mature trees that will provide hollows in the near future - these take many years to form and are essential for nesting and species survival. In addition the destruction of significant rocky outcrop and cave formations. These are known to provide critical habitat for three threatened species of microbats, including the endangered Large-eared Pied Bat and vulnerable species: Large Bent-wing Bat and Little Bent-winged Bat.
A biodiversity offset system that permit adverse impacts to sensitive ecological areas and threatened species, is problematic for many reasons, including the fact that recent inquiries found these to be facilitating a state of decline for NSW biodiversity and a net loss to nature. The NSW Government must adhere to their commitment and ensure the protection of these species by safeguarding habitat critical to their survival.
3. Operational impacts
Beyond the building process, which presents a high pollution risk to surrounding bushland, streams and the Lane Cove River, consideration must be given to the fact that data centre operations create ongoing forms of pollution. Locating a data centre in close proximity to sensitive wildlife habitat should not occur for numerous ecological reasons, including -
• The Urban heat island effect will be intensified. Ongoing data centre operations will add to the increased heat caused by the canopy reduction. Recognised expert in urban heat Professor Sebastian Pfautsch recently conducted a heat study across the Willoughby LGA, including the site of one of Sydney’s most significant tree vandalism events at HD Robb Reserve in Castle Cove, where 260 trees were killed in bushland reserve in 2023. Pfautsch warned of the detrimental ripple effects of temperature shifts on surrounding bushland, impacting insect life and biodiversity due to hotter days and cooler nights in the affected area. The additional heat generated by data centre operations will exacerbate the risk to wildlife, and human health.
• Harmful artificial light generated by the 24/7 operation will have a negative impact on wildlife. Unnatural light spilling into the surrounding bushland will be detrimental to native wildlife. Natural habitats become unsuitable, and species exhibit numerous physiological and behavioural changes, impacting feeding, breeding, immunity, flowering, and spawning. Night light is beneficial to invasive predators like foxes and cats and, when combined with a diminished foreshore corridor and connectivity, will further increase the risk to wildlife. These effects can threaten biodiversity and reverberate through ecosystems. In addition to excessive light, wildlife will be disturbed by noise pollution created by generators, coolers, server halls and other operational aspects of the 24/7 facility.
• Wildlife risk of injury and death through car movements and diminished habitat corridor. This 24/7 facility, which includes parking for 115 cars, raises concerns over the impact of increased car movements in a wildlife-rich zone. It is likely to result in wildlife strikes, injuries, and fatalities. Swamp wallaby, short-beaked echidna, long-nosed bandicoot, lace monitor lizards and python are among the protected species that reside within LCNP and will be vulnerable to cars. This threat is increased by a reduction in the protective corridor available to wildlife.
4. Negative impact on the amenity and experience of recreational users of Sydney’s iconic Great North Walking Track
This facility will be encroaching on one of Sydney’s most popular shared public recreation spaces. As Sydney’s population grows and high-density housing increases, it is critical that the State Government preserves existing outdoor recreation spaces in Sydney, particularly those that provide an opportunity to connect with nature. The Great North Walking Track is a prized public asset, affording invaluable physical and emotional wellbeing benefits to residents and visitors.

The proposed development, "Julius Avenue Data Centre City of Ryde" 6-8 Julius Avenue, North Ryde, Lot 89 in DP1082131, is unacceptable. I strongly OPPOSE/OBJECT to this development. The proposed data centre is not appropriate for this location in either construction or ongoing operation.

PUBLIC COMMENT PERIOD SHOULD BE EXTENDED, SINCE DEVELOPER HAS INTENTIONALLY DECEIVED ABOUT AND PREVENTED COMMUNITY CONSULTATION ON THE ACTUAL DEVELOPMENT PROPOSAL. EIS Appendix 28 - Social Impact Assessment WAS DELIBERATELY CORRUPTED, TO ENSURE THAT ONLY 5 PEOPLE WERE SURVEYED AT ALL, AND THESE WERE JUST ASKING IF THEY AGREED WITH PRE-WRITTEN MARKETING STATEMENTS THAT WILL NOT REALLY BE ACHIEVED BY THE SPECIFIC PROPOSAL.

I am aware the Mayor of Ryde, Trenton Brown, has written to NSW State Government requesting an extension to this extremely brief public consultation process and this too should be granted. The developer has INTENTIONALLY deceived the general public as to the actual nature of this proposed development, (in, for example, EIS Appendix 28 - Social Impact Assessment.pdf) ensuring they do not think to make a submission opposing its actual nature until it is too late.

The developer provides the following misleading claimed 'summary' of their project in numerous different documents in this proposal, evidently hoping that nobody reads any more details about the actual proposal. This exact same table is repeated in many of the developer's documents, including but not limited to EIS Appendix 28 - Social Impact Assessment.pdf p. 6, "Table 1: Development Proposal Summary" and SEARs Request - Julius Avenue Data Centre.pdf. SEARs Request - Julius Avenue Data Centre.pdf is addressed to "NSW Department of Planning, Housing and Infrastructure " implying the developer has also previously tried to deceive the state government over the nature of its proposal, as on p. 20:.

"Part 6 - Environmental Management & Sustainability

Canopy Coverage and Biodiversity
The Proposal achieves the objectives of this Part of the Design Guide in the following manner:

a) Recreates environmental values across the precinct consistent
with Country.
b) Maximises the future mature tree canopy and vegetation
coverage across the Precinct, providing a green and healthy
environment that supports active lifestyles.
c) Ensures no net loss of tree canopy coverage within development
lots.
d) Achieves a Net Positive Impact on biodiversity. "

Thus the developer is actively trying to deceive even Department of Planning, Housing and Infrastructure that if they make empty untrue claims then the development will be mindlessly ticked off without anyone checking that these are inaccurate, deceptive mistruths. In actuality, the proposed development results in a substantial net LOSS of trees and net LOSS of "tree canopy coverage within development lots" and a substantial net NEGATIVE "IMPACT on biodiversity". It also, of course, does not "Recreates environmental values" merely destroys the ones that are already there. It does not "provide a green and healthy environment and support active lifestyles" either, it just creates pollution (in general and from light, heat, noise, blinding reflection during the day and 24 hour light pollution at night, toxic diesel fumes and non-renewable greenhouse gas emissions), noise and a dangerous heat island effect and extreme fire risk. This is compounded by the negative environmental impact from removing the current forest, even before the ongoing operation of the proposed data centre. Although all these statements are untrue, it is additional impunity that they make claims of a quantitative nature that are so obviously incorrect, like "no net loss of tree canopy coverage" and/or "a net positive impact on biodiversity" ! And later the developer makes even more extreme claims, that there will be a "doubling" of tree canopy on the site, (EIS - Julius Avenue Data Centre 240625.pdf p. 81/94 ) when this is both untrue and impossible.

These misleading statements are repeated in the supposed "summary" the developer uses to mislead the public about its development, with statements like "No net loss of trees" [sic] (EIS Appendix 28 - Social Impact Assessment.pdf p. 6, "Table 1: Development Proposal Summary").
Yet elsewhere in the developers' proposals, we see that so many trees and plants will be removed that nobody has counted them, but as the developer elsewhere admits (EIS Appendix 12 - Landscape Design Report.pdf P. 25; p. 27)) a MINIMUM of "509" mature trees, most of them in a functioning forest ecosystem, will be destroyed, and the 'landscaping' then only proposes "133" replacement plants, most of which are shrubs that are not trees at all, and anyone who can count can see that this is a net LOSS of trees, and the removal of the forest is a net LOSS to biodiversity, and this empty marketing slogan that their development instead is somehow a "a net positive impact on biodiversity" is a blatant LIE.

EIS Appendix 12 - Landscape Design Report.pdf P. 25 "TOTAL INDIVIDUAL TREES BEING REMOVED 509"

EIS Appendix 12 - Landscape Design Report.pdf P. 27:
"For area within minimum APZ area:
67 Existing trees
37 Proposed trees
For area outside of minimum APZ area:
22 Existing trees
106 Proposed trees"

SOCIAL IMPACT ASSESSMENT REPORT - SSD-80018208 p. 81 "No net-loss of trees"
Therefore instead of simply admitting the obvious, that the clearance of a forest, wetland and more than 509 trees has a negative impact on biodiversity and the environment, the developer simply LIES to both the public and the NSW Government that their development instead somehow increases tree cover and biodiversity, simply because they said so and nobody will think to check! This repugnant attitude of the developer and their assumption that all residents of the area are complete idiots is even more offensive than proposing a destructive development and then simply admitting it.

Not only is this 'summary' (EIS Appendix 28 - Social Impact Assessment.pdf p. 6, "Table 1: Development Proposal Summary") itself intentionally misleading, including statements that are blatantly untrue such as "No net loss of trees" [sic], and others that conflict, such as the building here claimed to be "48m" but elsewhere confirmed to be "greater than 50m" (all in a zone with maximum permitted height 30m), but the supposed 'survey' of only 4-5 people was of even more intentional misleading of the general public, as further detailed shortly. It is likely similar inaccurate information was provided in EIS Appendix 26 - ACHAR (Redacted) copy.pdf for the supposed consultation of Aboriginal people, in spite of the 2+ Aboriginal Heritage Sites less than 20m from the development boundary, and many more which will be disrupted even on the other side of the Lane Cove River from the unnatural view of the lit-up data centre reflected in even the river water 24 hours a day.

As this report EIS Appendix 28 - Social Impact Assessment.pdf confirms, the developer conducted an intentionally useless and misleading survey from which they received only four responses. "The survey generated only four (4) responses from over 1200 Newsletters distributed through the local business and residential areas (refer Appendix B)." (p. 42). With such a poor response rate, it is almost as if the developer is TRYING to make sure the community is not 'consulted'. In spite of this, the so-called "Social Impact Assessment" concludes, on the basis of FOUR responses, that "there is little opposition to the proposal" (p. 42). The developer further lies about the results, such as that "One respondent expressed a concern around chemical storage and noise pollution from the resulting Data centre" but then claims this is not of significance because 'it is the opinion of only one person', their survey itself being of only four people. It seems that 3/4 respondents wanted "preservation of greenspaces" (p. 43) but this stated desire is ignored of course in the subsequent proposal to clear most the remaining forest from the site. The developer regardless concludes that all 4 respondents support their project anyway, when clearly they do not since the actual proposed development does not correspond with the statements the respondents were giving their opinions about.

Thus the findings are only thought representative when it is statements the developer wants to hear in straightforward confirmation bias. The developer intentionally did not consult the local community, but instead misrepresents this as a lack of opposition to the specific project.
" 4.3 RESPONSE TO ENGAGEMENT
Overall, the community interest in providing feedback on the proposal was low, with fewer than five Social Impact Community Survey responses made following community Newsletters and direct communication with two of the ten local community/interest groups. The limited responses to community engagement including direct approaches and the survey suggest a low level of concern relating to the proposal and key themes relating to natural environmental, design of the development being key concerns."

In fact, this represents that the developer has not only ensured that those who were interested did not hear about the development at all, but any who did hear about it were intentionally deceived as to the nature of the development. For example (EIS Appendix 28 - Social Impact Assessment.pdf P. 44 : "Wild walks:
- Doesn’t see any negative impacts on walking trail "
It is unclear which 'walking trail' is even being considered here, but the proposed development is creating EXTREME changes to the current walking track on the site stretching from Richardson Place entry, that will be replaced with a road and concrete path past the electrical substation, and almost the entire forest it currently passes through will also be cleared, so clearly this respondent didn't even know what the proposed development was when they gave this response. It seems likely the developer intentionally sought out 5 people who would claim their project has no impact on them, since it is nowhere near them to start with. "Wild walks", it turns out, is not a 'community' organisation AT ALL, it is a website wildwalks.com showing bushwalks found Australia wide, and whoever responded to the developer's request probably doesn't even live in NSW, let alone Macquarie Park. Thus the 'community' has not been consulted at all.

Thus not only have only about 5 people been consulted about the project, at least one of them living elsewhere in Australia and probably never have even been to Macquarie Park, but in all consultations, the respondents have been fed misinformation and unaware of what the new proposal for the site is to start with.

As mentioned earlier, a completely different development ("Modified Determination No. 1395/1999, dated 11 September 2005") was approved in 2005 MORE THAN 20 YEARS AGO and an excavation of the front half of the site was done in 2009, leaving a hole in the ground, and many people would be fine with the assumed idea of a developer putting an ordinary <30m office building only in the front part of the site that is currently a recessed hole in the ground. Since the developer intentionally did not provide further details, instead only providing empty intentionally misleading marketing slogans about its project, most people would have simply assumed a building would be put in the existing hole in the ground, and would be unaware that most of the remaining natural vegetation outside this 2009 hole only taking up less than half of the site, is going to be cleared, AND that an illegal 50.93m+ high monstrosity, power substation, diesel generator and dangerous diesel fuel storage creating extreme fire risk, pollution and heat island effect is being put there instead. Since the developer's site borders the Lane Cove National Park, many people would have also incorrectly assumed the forest was inside the national park, when this is not true at all and it will instead be destroyed.

As stated earlier, the claim that the development will result in a "Positive Impact on Biodiversity" [sic] is blatantly FALSE along with its blatantly untrue claim that it will result in an "INCREASE" of trees in either canopy cover or number by clearing '509'+ mature trees and then only planting '133' plants. As the EIS Appendix 15 - BDAR.pdf claims, the negative impact on "biodiversity" even from just the proposed clearing of the site for construction includes but is not limited to:
"Impacts on Biodiversity Values
The Projects development footprint proposes to remove 1.33 hectares of native vegetation on the Subject Land, of which 1.2 hectares is PCT 3592 (vegetation zones; 3592_Regrowth 0.58 hectares and 3592_ModGood 0.62 hectares) and 0.13 hectares of PCT vegetation zone 3967_Regrowth."
Thus it is not even the mere removal of trees, but established old-growth forest in "good to moderate condition" including a functioning ecosystem and tree hollows, shrubs, caves, an entire rock ridge, soils etc. as well as regrowth of more than 15 years that is also valuable habitat for wildlife especially in proximity to the established forest and adjacent to the Lane Cove National Park. All of which is going to be removed. The removal of the wetland also suggests still further impending stormwater and sewage and erosion problems to be caused by the site, and the removal of the forest and the rock ridge will create still further erosion. Only a tiny area in the extreme south-west of the site is not proposed for clearance, although even this will probably not survive the actual construction process intact let alone the site's subsequent operation, and is not retained out of concern for the environment but rather that it is too steep and dangerous to touch anyway. The "Biodiversity Development Assessment Report" makes various recommendations (e.g. p. 51/66-59/74 note that the printed page numbers do not match the PDF), including but not limited to claiming that somebody should keep looking for endangered shrubs and carefully pick up and manually move all hollow logs etc. into the tiny area not intended for destruction,
("2c. Relocating habitat features (eg fallen timber, hollow logs) from the development or clearing site, to adjacent retained vegetation" p. 54/69 )

but there is no confirmation that ANY of these will actually be followed during the construction or operation process, especially when the construction workers have no training or interest in such activities. In reality the entire site will be razed and ground up as seen in the 'clearance' of every other construction site in Sydney, regardless of the presence of wildlife, endangered shrubs, hollows, hollow logs et al. As for the tiny area of vegetation proposed to be retained at the extreme south-west of the site, even after construction is finished and operation of the complex commences, it too will now be inhospitable for wildlife and natural ecosystems, due to the 24 hours a day light, heat, noise, vibration, pollution, rubbish, increased stormwater and flooding, erosion, danger from the electrical substation, and other disturbances. The ACTUAL amount of destroyed habitat is thus far greater than the "1.33 ha" admitted by the EIS Appendix 15 - BDAR.pdf since a far larger surrounding area will become permanently inhospitable to wildlife and natural ecosystems from the negative impacts of the 50.98m+ high data centre's ongoing and indefinite operation 24 hours a day 7 days a week 365 days a year. These impacts are so extensive that they potentially extend to the other side of the Lane Cove River as well, due to the development's elevated position, more than 50m height and the fact that any unnatural lighting reflect into the Lane Cove River itself 24 hours a day. Thus biodiversity, Aboriginal Heritage Sites and the enjoyment by humans is destroyed not only on the site itself and in the adjacent section of Lane Cove National Park, but even in the reserves on the other side of the Lane Cove River such as Mobray Park and the other side of Lane Cove National Park as well. Add to this the catastrophic fire risk posed by the complex itself and any fires it creates or greatly exacerbates, and the net LOSS to biodiversity is generated not only from the clearance of the forest itself, but to a vast surrounding area in a permanent basis during the data centre's proposed operation. It is impossible to quantify such an extreme and extensive negative effect on biodiversity created both by the construction but also ongoing and indefinite 24/7/365 operation of this proposed data centre, but it is obvious that in spite of the developer blatantly pretending otherwise, it has an extreme and unacceptable NEGATIVE impact on biodiversity that extends far beyond even the boundaries of the land owned by the developer but to both sides of the Lane Cove River including but not limited to Lane Cove National Park, Mobray Park, Lane Cove, North Ryde, Macquarie Park, and even further, and this data centre should NOT be approved at this location under any circumstance!


INTENTIONALLY MISLEADING 'SOCIAL IMPACT REPORT' SHOULD BE REJECTED AND OFFICIAL CONSULTATION PERIOD EXTENDED

Not only does this four person survey in EIS Appendix 28 - Social Impact Assessment.pdf not include any actual current residents of Ryde/Macquarie Park/Lane Cove, it also includes none of the thousands of proposed residents that are intended to be moved into Macquarie Park in its recent rezoning to High Density Residential areas. This is particularly significant in that they intentionally surveyed an area which has been REZONED as residential but most of the residents are not even there yet, and the other businesses are being moved out anyway. The survey itself, however, and all other promotional materials by the developer, have been INTENTIONALLY misleading, consisting of empty marketing slogans with blatant untruths such as "I would like to improve the quality of the building environment" or "I would like to promote sustainable development" or "I would like two new roads built in Macquarie Park (without any mention as to what context these would occur).

The 'social impact survey' is a typical example of a pre-biased marketing campaign, where (as shown on p. 43) the developer makes up some positive sounding statements, asks whether the respondents think these statements sound desirable, and then subsequently openly lies that the development will provide these and thus instead of the response indicating support for an empty marketing statement, incorrectly reframe the response as instead support for this specific development when this is not the case. The survey is not getting accurate information and this is intentional. It is, as just, mentioned, the invention of disconnected positive statements that are not actually true of the proposed development, most people will "agree' that these positive statements sound desirable, and then the developer lies and claims that support for this irrelevant marketing slogans instead are support for the developer's specific project, which will in actuality provide none of these (or, in the case of the two roads, could and would have been provided anyway).

So for example the pre-written statement:
"I would like to improve the quality of the built environment in Macquarie Park"
The survey then asks if the respondent supports this isolated statement.

If someone saw this innocuous sounding statement, they would probably say, yes I would like this. Then the developer misrepresents the survey, and lies that this means the four respondents instead support this specific inappropriate development, which arguably does NOT "improve the built environment" of Macquarie Park at all. It is the same for every other isolated, positive sounding statement in the fake 'social impact' survey. Obviously the respondents will say that yes they approve of the provided empty isolated statements like "I would like to promote sustainable development" and "I would like to provide land uses that meet the needs of the local community" and then the developer LIES and claims that this is instead the four survey respondents indicating support for the specific inappropriate proposed development.

Although some of the statements in the fake survey/promotional materials are unquantifiable, some of the statements make direct numeric claims that can be disproven as matters of fact. These include, but are not limited to, the environmental impacts of this inappropriate development. The developer has repeatedly openly lied in its promotional materials and supposed surveys about this development, making blatantly untrue claims like "there will be No net-loss of trees" and "No negative impact on biodiversity", not only to the public but even to the "NSW Department of Planning, Housing and Infrastructure" in SEARs Request - Julius Avenue Data Centre.pdf on p. 20 and probably elsewhere as well. There are, it seems, no laws against lying when trying to get a development ticked off and mindlessly approved by the NSW State Government.

Thus the submission period for the general public should be extended, as requested by Mayor of Ryde Council. After this extended submission period, the proposal should be rejected entirely.

IMPUNITY OF CLAIMING THAT AN UNRELATED COMPLETELY DIFFERENT PROPOSAL FROM 2005 HAS ALREADY GIVEN THEM PERMISSION TO REMOVE ALL VEGETATION FROM THE SITE

The developer (e.g. SEARs Request - Julius Avenue Data Centre.pdf) demanded that the proposal be approved on the basis of a previous development approval for the site in 2005: MORE THAN 20 YEARS AGO! In spite of the fact that the 2005 proposal ("Modified Determination No. 1395/1999, dated 11 September 2005") bore no resemblance whatsoever to the 2025 proposal, the developer has claimed that the fact they could, hypothetically speaking, clear some vegetation from the site for the 2005 proposal Modified Determination No. 1395/1999, has already given them permission to clear ALL vegetation from the site for the 2025 proposal, in spite of more than 20 years passing and the proposals being completely different facilities. "Given the significant vegetation clearing already approved on the Site as part of Modified Determination No. 1395/1999 ..." (SEARs Request - Julius Avenue Data Centre.pdf p. 9). Permission for anything in the 2005 proposal is thus incorrectly assumed to already be granted automatically. This means that the developer has misrepresented the proposal in this aspect as well, since, for example, if a tree was 'approved' to be cleared in 2005, they assume they do not have to request permission to do so again, and even if a tree really was cleared in 2009 for the 2005 proposal and a different tree is still there, nobody will know or care if it is one from the '2005' proposal or not.


DEVELOPER REPEATEDLY LIES THAT THE PROPOSAL WILL SOMEHOW LEAD TO "providing double the existing canopy coverage" COMPARED TO THE SITE'S PRESENT CONDITION WHEN THIS IS IMPOSSIBLE AND AN EMPTY, LYING DECEPTION.

The nonsensical claims the developer makes seem to be related to the never built 2005 proposal, since this is the only explanation for such statements other than outright deception. So, for example, the constantly repeated statement that there is "no net-loss of tree canopy coverage from lot/s". This marketing slogan is also repeated in EIS - Julius Avenue Data Centre 240625.pdf.
EIS Appendix 15 - BDAR.pdf has elsewhere confirmed that a huge amount of forest ecosystem is going to be completely removed from the site.
"Impacts on Biodiversity Values
The Projects development footprint proposes to remove 1.33 hectares of native vegetation on the Subject Land, of which 1.2 hectares is PCT 3592 (vegetation zones; 3592_Regrowth 0.58 hectares and 3592_ModGood 0.62 hectares) and 0.13 hectares of PCT vegetation zone 3967_Regrowth."

This forest ecosystem contains so many trees and plants that the exact amount that will be destroyed is uncountable, but elsewhere (EIS Appendix 12 - Landscape Design Report.pdf P. 25; p. 27) admits that a minimum of "509" mature trees will be removed from the site. EIS - Julius Avenue Data Centre 240625.pdf confirms that from this area, only "38" trees will be attempted to be retained and then "143" plants subsequently planted in total in the entire development site. Yet EIS - Julius Avenue Data Centre 240625.pdf on p. 81/94 then also makes the thoroughly nonsensical claim that this somehow leads to an INCREASE of tree canopy coverage on the site! "The Landscape design of the Julius Avenue Data Centre responds to the growing impacts of the urban heat island effect by providing double the existing canopy coverage and the minimising of unshaded hard surfaces. " So the developer lies and claims that the site now has "double" the tree canopy cover after the proposed development, compared to before. When it so obviously does not. I will repeat the numeric quantities provided elsewhere by the developer themselves:

"509+" mature trees proposed to be removed. Only "133" replacement plants to be planted. (EIS Appendix 12 - Landscape Design Report.pdf P. 25; p. 27)
"38" trees retained and the rest of them cleared. 38 trees out of more than 509 removed, most of which were part of a forest of both trees and shrubs. This quotes a different figure, but equally small, that "143" plants will then be replanted. (EIS - Julius Avenue Data Centre 240625.pdf p. 127/140)
After the project, a maximum of 133+38 or 143+38 plants will thus remain. In addition to this, a tiny corner of natural vegetation will be retained in the south-west corner of the site (the exact dimensions of this do not seem to be disclosed but it is marked on the maps). But this is NOT any sort of increase in vegetation or canopy cover, since it is just the tiny patch of natural vegetation that has been there before the development ever started, and so retaining it the same as it has been all along is not any sort of increase in trees or canopy cover, let alone it 'doubling'. All that has happened is that at least "509" mature trees and at least "1.33 hectares' of native forest that was still there in 2025, will be completely removed. The 133 or 143 plants that will be replanted not only do not compensate for the trees and forest lost, they are even less a "double" of the tree canopy prior to the development. The report EIS - Julius Avenue Data Centre 240625.pdf is simply lying to the reader. The declaration "does not contain information that is false or misleading" is untrue. It is possible whoever wrote EIS - Julius Avenue Data Centre 240625.pdf was also fed misinformation by the developer and got confused and made an honest mistake, but it seems this laxity in not seeing whether the figures could possibly correspond to each other is intentional.

A total of 143 new plants and 38 retained trees, when a minimum of 509+ trees were removed. This is a loss of at least 328 trees.

Yet not only does the developer repeatedly and incorrectly claim there is "no net loss of trees". By EIS - Julius Avenue Data Centre 240625.pdf the claim has become even more ridiculous. After a LOSS of at least 328 trees compared to before, the developer LIES and quite literally claims the development site will have DOUBLE the tree canopy it did before the development (as in, its state now, assuming the develop has not gone and cleared it since the EIS Appendix 15 - BDAR.pdf in early 2025). "EIS - Julius Avenue Data Centre 240625.pdf on p. p. 81/94 "The Landscape design of the Julius Avenue Data Centre responds to the growing impacts of the urban heat island effect by providing double the existing canopy coverage and the minimising of unshaded hard surfaces." It can be seen it is impossible it will ever have 'double' the tree coverage even if more than 143 plants were replanted, since the proposed buildings, roads, concrete and electrical substation that will then be taking up most of the site that was formerly forest make this impossible. The developer in all its reports therefore just makes up statements and claims out of thin air and lies with impunity. In fact, I believe that all that occurs is after their 4 person survey that found out 3/4 people surveyed were worried about the loss of native vegetation, they decided that a better marketing slogan than simply pretending that their project has 'no net loss of trees', is to amend it to an even greater marketing slogan, lying that it actually 'DOUBLES the tree canopy cover' so the environmentally concerned residents will be even better deceived by their unwanted development, and unable to oppose it until it is too late.

PRE-EMPTIVE REFUSAL OF DEVELOPER TO PROVIDE REPLACEMENT PLANTING ELSEWHERE EITHER

See "6.1.7.2 Tree replacement' in EIS - Julius Avenue Data Centre 240625.pdf p. 127/140.

"It is understood that amendments to the tree provisions contained within Part 9.5 of RDCP 2014 have undergone public exhibition. The draft DCP prescribes a replacement tree planting rate of 3:1, however this is inconsistent with the Macquarie Park Design Guide, and the controls of the Macquarie Park Design Guide prevails to the extent of any inconsistency. "

As the developer themselves admit, Ryde Council is supposed to require replacement tree plantings at a 3:1 ratio (the planting may be elsewhere in Ryde) a rule that other developers are expected to comply with. Developer contributions then pay for new street and park trees. This rule is even more important since most newly planted trees don't survive anyway, (often due to vandalism by developers) so planting 3 means it is more likely one replacement will survive to reach tree height. However, in spite of openly lying and deceiving the public that they have 'no net loss of trees' and 'doubling of tree canopy', the developer has pre-emptively stated their REFUSAL to comply with the law Ryde council expects other developers to comply with. "Laws don't apply to me" is the bad attitude of this developer, while at the same time they lie with impunity, pretending that there is "no net loss of trees" and even a "doubling" of tree canopy, while REFUSING to comply with the bare minimum contribution to replacement plantings expected by law in Ryde Council. Ryde Council is regardless expected to cope with the severe drain to infrastructure that will be caused by this parasite.

THREATS TO 7+ ENDANGERED SPECIES AND ALL OTHER WILDLIFE IN THE AREA, INCLUDING OUTSIDE SITE BOUNDARIES IN LANE COVE NATIONAL PARK AND SURROUNDS

As admitted by the EIS Appendix 15 - BDAR.pdf subsequently commissioned by the developer, The endangered shrub Darwinia biflora (growing maximum 80cm high and not included in countings of 'trees') has previously been recorded from the site, and the following threatened species:
"considered assumed present on the Subject Land":
Large-eared Pied Bat Chalinolobus dwyeri,
Little Bent-winged Bat Miniopterus australis,
Large Bent-winged Bat Miniopterus orianae oceanensis,
[plants]
Deyeuxia appressa,
Hibbertia spanantha ,
Rhizanthella slateri,
[Darwinia biflora as stated earlier].
It is also habitat for a long list of other threatened species who can no longer use the site after its proposed destruction.

The location and nature of this development means its effects extent to a vast area outside the site boundaries. This is due to development's immense height of more than 50.93m, the fact that it is brightly lit up 24 hours a day and reflects sunlight in the daytime blinding all onlookers, and its elevated position on the edge of a cliff before a steep dropoff to the Lane Cove River. The river itself reflects the building at all times of the day or night, so even when people look out at the water instead, all they see is the reflection of this inappropriate data centre. As offensive as the data centre is to all human onlookers 24 hours a day even on the other side of the Lane Cove River, it is even more harmful to wildlife and natural ecosystems. In spite of this, the consideration of the grotesque negative impacts to wildlife and ecosystems even outside the site boundaries from its horrific levels of unnatural light, heat, noise, vibration, pollution, fog/smog, increased fire and lightning risk, etc., including in the adjacent Lane Cove National Park, were not considered at any point. This was a mistake. A development of this kind should simply NOT be at this particular location!

UNACCEPTABLE HARMFUL IMPACTS OF PROPOSED LIGHTING ON ECOLOGICAL COMMUNITY, NATIONAL PARK AND ENDANGERED SPECIES

The harm to the forest and river ecosystems extends beyond even just the forest immediately cleared by the development, and to the entire surrounding area, including but not limited to Lane Cove River National Park, Mobray Park and both sides of the Lane Cove River. One reason for this is the extreme and excessive amount of artificial lighting provided 24 hours a day by this 50m+ high blatantly visible cliff-top complex. The proposed development has as many artificial lights as possible, even including additional completely unnecessary "decorative lighting" [sic] along almost the entire west and south of the complex to create as much excess light pollution as possible.

The remnant natural ecosystems, as well as any humans in the area, will be negatively impacted by the proposed lighting in three categories:

1. - The ecosystem will be harmed by the extreme number and magnitude of artificial lighting in the immediately adjacent area, creating both light and heat pollution impacts.
2. - The ecosystem will be harmed by light spill DIRECTLY. This includes reflections on the Lane Cove River which means the impacts of any light spill extent to a vast area 24 hours a day. this location on top of a cliff before the steep dropoff to the Lane Cove River as well as the reflection in the river itself means that the effects of the 24 hours a day lighting creates as much light pollution as possible to as vast an area as possible. During the day, people and animals will be blinded and harmed by sunlight reflecting off the building as well.
3. - The parts of the ecosystems not receiving light pollution directly will still be harmed due to the biodiversity loss created by the lights as species no longer use or pollinate the area.

No consideration has been made about the harm to ecosystems or humans by light pollution. Indeed as much light pollution as possible is INTENTIONALLY crated by the complex, which even has the offensive and unnecessary addition of "decorative lighting" [sic] proposed along most of the Western and Southern edge of the site. Since data centres must by necessity run 24 hours a day, all the lights of the complex are NEVER turned off. This 24 hour a day light pollution causes extreme harm to wildlife and ecosystems, and permanently destroys any capacity for humans to enjoy the natural environment of Lane Cove National Park, Mobray Park and other formerly natural areas.


HARMFUL EFFECTS TO NATURAL ECOSYSTEMS FROM ARTIFICIAL LIGHTING

The harm to the natural environment by artificial light pollution is well documented.
Such as in:
Irwin, A. (2018) The dark side of light: how artificial lighting is harming the natural world. Nature 553, 268-270 (2018) doi: https://doi.org/10.1038/d41586-018-00665-7
https://www.nature.com/articles/d41586-018-00665-7/

and the edited book:
"Rich, C., & Longcore, T. (2006). Ecological Consequences of Artificial Night Lighting. Island Press, Washington."

https://www.nature.com/articles/d41586-018-00665-7/
provides a useful summary of science in the area of the damaging effects of artificial lighting on natural ecosystems.

- The article confirms that different sorts of light are even more damaging to animals, plants and ecosystems and that the LED lights with their broad spectrum of white light that are more recently used are even more disruptive to natural processes than other lights.

"The widespread installation of LIGHT EMITTING DIODES (LEDS), which are growing in popularity because they are more energy efficient than other bulbs [..] tend to emit a BROAD-SPECTRUM WHITE LIGHT THAT INCLUDES MOST OF THE FREQUENCIES IMPORTANT TO THE NATURAL WORLD. The trend has had profound impacts on some species."

All lights, even including far weaker streetlights, have been discovered by researchers to have a profound impact on natural ecosystems: plants, animals, insects, and the ecosystem as a whole due to the reduction in pollinators and food sources.

The negative effect of the lights will be compounded by the additonal extreme amount of heat generated by the complex. Plants and animals associate heat with the sun: both it being daytime, or it being summer. The plants and animals will become disrupted from their natural seasonal or day/night cycles by the constant light and heat generated by this artificial complex.

Thus the complex will cause two separate yet related effects; an increase in light, and an increase in heat generated and a change in the micro-climate. This increase in heat will also have a catastrophic effect on the ecosystem/s. The lights' emissions can also be guaranteed to emit signals not perceived by humans but disturbing to wildlife. And, in a separate but also exacerbating issue, the incredible amount of noise, vibration and magnetic fields ALSO emitted by the artificial complex will further disrupt and disturb all wildlife.

https://www.nature.com/articles/d41586-018-00665-7/ reviews some studies of the effect of artificial lights on natural ecosystems, the same impacts that can be predicted to occur to these nearby ecological communities.

ARTIFICIAL LIGHTING IS LETHAL TO INSECTS, AND DESTRUCTION OF INSECTS THREATENS ENTIRE ECOSYSTEM

- Artificial lights are lethal to insects which are "vital food sources and pollinators in many ecosystems. An estimate of the effects of street lamps in Germany [that are much less bright than the lighting in proposed development] suggested that the light could wipe out more than 60 billion insects over a single summer. Some insects fly straight into lamps and sizzle; some collapse after circling them for hours" (Irwin, 2018).

Therefore the lighting in the proposed development will disturb and destroy insects, attract them out of the remaining natural vegetation and kill them, leading to a loss of biodiversity, pollinators and food sources. Ecosystem will be degraded and collapse.

The fact that lights attract insects, and that some insect-eating wildlife has learned to tolerate and capture insects in the artifical lighting provided by humans, means that further risk will be posed by this complex, as obviously both the data centre and the electrical substation are not compatible with wildlife. Insects will have to be poisoned, and any bats or birds that come into the area to try to eat insects will be poisoned, electrocuted, or crash into a window of the 50m+ high complex and die.

- ARTIFICIAL LIGHTING IS LETHAL TO AQUATIC INSECTS WHO ARE LURED OUT OF THEIR HABITATS AND KILLED, AND DESTRUCTION OF INSECTS THREATENS ENTIRE ECOSYSTEM, INCLUDING ADJACENT ECOSYSTEMS NOT IN LIGHTED AREAS.

- The negative effects of artificial light pollution on aquatic insects has been studied specifically.

A study of aquatic insects (as described in Irwin, (2018)) found they were lured out of their habitats by the artificial light and died, either from exhausting themselves or from being eaten.

"Street lamps erected near water-filled ditches lure aquatic insects out of the water [..] The insects flock to the lamps, exhaust themselves and become food for nearby predators. Meanwhile, the [adjacent ecosystem], which might otherwise have received insect visits, is deprived of an important source of food" (Irwin, 2018)

Since insects are integral to the entire ecosystem both as pollinators and as food sources, the entire ecosystem will be degraded from this biodiversity loss. There will probably also be an increase in the few pests able to tolerate artificial human-built conditions such as mosquitoes, due to the reduction of competitors or predators.

"[There is] 'evidence of a strong, bottom-up effect of exposure to artificial light,' says Gaston. [their research] reveals further effects, cascading onto the predators in the systems."

Another experiment, "has shown that these cascade effects can spill over into neighbouring ecosystems. Street lamps erected near water-filled ditches lure aquatic insects out of the water, says Franz Hölker, an ecohydrologist at the Leibniz Institute of Freshwater Ecology and Inland Fisheries in Berlin. The insects flock to the lamps, exhaust themselves and become food for nearby predators.
Meanwhile, the hinterland [adjacent ecosystem], which might otherwise have received insect visits, is deprived of an important source of food, he says.
Studies such as these, which lay such relationships bare in well-controlled, small-scale studies, mean that 'those impacts are more likely to be taken seriously in the field and by regulators considering impacts from lighting', says Longcore." (Irwin, 2018).

- DIRECT NEGATIVE EFFECTS OF ARTIFICIAL LIGHTING ON PLANTS

Although plants are negatively affected indirectly from lights when their pollinators no longer use the area, the plants are negatively affected directly by artificial lighting as well, since they will incorrectly interpret the artificial lighting as sunlight and thus day length and time of year. (Rich & Longcore, 2006).

As mentioned, this complex will generate massive amounts of heat as well, so the confusing effects of artificial light will be exacerbated by the increased amount of heat, meaning that plants and animals will be even more likely to confuse the complex with the endless onset of daytime and summer.

- ARTIFICIAL LIGHTING IS INTERPRETED AS SUNLIGHT AND DAY LENGTH AND MAKES PLANTS FLOWER AT WRONG TIME OF YEAR, THREATENING THEIR SURVIVAL

- Artificial lighting disrupts plants' timing of flowering.
Disruption to plants' timing of flowering by artificial light is confirmed by the edited book "Rich, C., & Longcore, T. (2006). Ecological Consequences of Artificial Night Lighting. Island Press, Washington."
This is because plants usually confuse artificial lighting with sunlight and an increase in day length, and therefore what season it is. Since the building is over 50m high and is also at the highest point on the edge of a cliff before the steep dropoff into the Lane Cove River will be above the height of most of the plants even the trees and definitely confused as sunlight by all species even trees. Plants both near and far will thus be confused by the excessive artificial lighting overhead, and even reflected off the Lane Cove River itself 24 hours a day 365 days a year.

The plant uses day length as a guide to what time of year it thinks it is and when to flower. Since the length of daylight is shorter in winter and longer in summer, the plant may incorrectly detect that winter has ended before it has due to artificial lighting and start flowing at the 'wrong' time of year.

If plants flower in the 'wrong' season, it means that their pollinators will not be available, or IF it manages to successfully reproduce, the weather conditions at that time of year will not be suitable for its offspring who will die.

Natural ecosystems worldwide are already being impacted by changed climate conditions due to global warming. The increased stress from artificial lighting as well means that the ecosystem is even more likely to collapse from not being able to reproduce in favourable weather conditions.

"A study in the United Kingdom over 13-years timing of bud opening in trees, found that artificial lighting was linked with trees bursting their buds on average more than a week earlier — a magnitude similar to that predicted for 2 °C of global warming." Since this is an average, it means that some species had their flowering timing disrupted by far more than a week.
(Irwin, 2018).

"A study of soya-bean farms in Illinois found that the light from adjacent roads and passing cars could be delaying the maturation of crops by up to seven weeks, as well as reducing yield." (Irwin, 2018)

If the plant flowers at the 'wrong' time of year due to the artificial lights, not only may weather conditions be inhospitable to the survival of its offspring but the animals that pollinate it not have arrived yet either, and therefore the plant will fail to reproduce at all. As well as some pollinating birds migrating, insects and spiders may not have hatched yet or be in hibernation. If the plant does manage to reproduce, its seedlings may then die due to unfavourable weather conditions or pests that eat it that are more abundant at certain times of year. So, for example, many Australian plant species start flowering in Winter in around beginning of August since they want their seedlings established BEFORE summer, and other plants species worldwide and in Australia flower in Spring. If the plant is confused by the artificial lights and starts flowering too early, such as the start of winter, the seedlings will not survive or the flowers not be pollinated at all.

- The change in the micro-climate from the heat generated by the complex itself and also the lighting may make it too inhospitable for many species to survive at all especially in summer, but it may also lead plants and animals to incorrectly detect that it is now a different, hotter time of year. The now-permanent heat generation by this artificial complex exacerbates the problems already caused by the lighting, as the former cooler conditions associated with winter never again occur. Many native plants may no longer survive at all, and some species may experience an explosion of numbers, probably a select few (and often introduced) insect pests and weeds that are promoted by the artificial newly-heated microclimate. These will eat or otherwise kill off the few remaining natural plants in the area. The artificial heat combined with humidity could also ensure the increase in other pathologies such as fungal diseases to kill off the remaining natural plants. The EIS claims that the heat will also be emitted out of pipes creating large clouds of condensation near the complex, which cause an unnatural fog and smog, even when there is no fog elsewhere. It will become even more toxic when it mixes with pollution from the diesel generators or from elsewhere. Humans, animals and plants will all be harmed.

- ARTIFICIAL LIGHT POLLUTION HAS NEGATIVE EFFECTS ON BIRDS AND BATS. NOT ONLY ON NOCTURNAL BIRDS BUT DAYTIME BIRDS AS WELL.

- Researchers have "found physiological evidence of the detrimental effects of light pollution on the health of wild animals. Songbirds roosting around the white light were restless through the night, slept less and had metabolic changes that could indicate poorer health".
"Several urban studies had found that artificial light at night triggers [daytime] songbirds to sing earlier in the day." [i.e. wake up earlier].
- Artificial illumination affects bats and many "have lost habitat and have disappeared from some places."

This would include but is not limited to the endangered species of bats that live in the area:

Large-eared Pied Bat Chalinolobus dwyeri
Little Bent-winged Bat Miniopterus australis
Large Bent-winged Bat Miniopterus orianae oceanensis
(EIS Appendix 15 - BDAR.pdf p. 5)

The impact on the endangered bat species is further exacerbated by the proposed complete removal of a rock shelf and 2+ caves from the site.

- ARTIFICIAL LIGHTING NEGATIVELY AFFECTS ADJACENT ECOSYSTEMS EVEN IF THESE AREAS THEMSELVES ARE NOT LIT UP. THE NEGATIVE IMPACTS THE LIGHTING WILL HAVE ON THE ADJACENT NATURAL AREAS WILL BE IMMENSE.

Ecosystems are always reliant on insects and other animals coming in from adjacent areas, especially in a tiny fragment. So, for example, on pollinators to arrive when a plant flowers.

Therefore even if the lighting is not within the remaining forest or river area itself, lighting up the adjacent area harms the ecosystem in two ways:
- Insects will be lured out of the natural area by the lights and kill themselves.
- Since the natural areas in the vicinity are already fragmented, many animals do not live in it permanently but travel between habitat fragments. Once the development is built and operating, the animals (such as insects) will now be killed in the adjacent floodlit areas, or (in the case of birds, bats etc.) simply start avoiding the area entirely. Since the ecosystem no longer has these species it will degrade and in the smaller areas, collapse.


- NEGATIVE EFFECTS OF LIGHT POLLUTION AFFECT DAYTIME SPECIES IN ECOSYSTEM AS WELL. THIS IS DUE TO THE REDUCTION OF INSECTS AS FOOD SOURCES OR POLLINATORS, SINCE THE INSECTS DECLINE FROM LIGHT POLLUTION. WHEN INSECTS NO LONGER POLLINATE FLOWERS, FLOWING PLANTS CANNOT REPRODUCE AND DECLINE AS WELL.

"‘Cascade effects’ [mean] the influences of light on one species have knock-on effects on the ecosystem."
As described in Irwin, (2018), a study on boxes of grassland given 54 different lighting conditions found that white and amber light suppressed flowering altogether in some plant species. Numbers of some insects fell, supposedly because the flowers they ate were also less abundant due tot he artificial lighting. Since there were less insects they were ALSO unable to pollinate ADJACENT AREAS OUTSIDE THE ARTIFICIAL LIGHTING.

Therefore the negative effects of artificial lighting are NOT restricted to the areas directly lit, since the reduction of insects and other animals due to the artificial lighting mean they can no longer fly or travel in from adjacent areas, even if these ecosystems themselves are not lit up.

- "Artificial light can also have impacts on ecosystem services — the benefits that ecosystems provide to humans. A study published in Nature last year found that illuminating a set of Swiss meadows STOPPED NOCTURNAL INSECTS POLLINATING PLANTS [..] found that INSECT VISITS TO THE PLANTS DROPPED BY NEARLY TWO-THIRDS UNDER ARTIFICIAL LIGHT and that daytime pollination couldn’t compensate: the plants produced 13% less fruit. Knop’s team forecast that these changes had the potential to cascade to the daytime pollinator community by REDUCING THE AMOUNT OF FOOD AVAILABLE [to daytime animals as well]. 'This is a very important study, which clearly demonstrates that
artificial light at night is a threat to pollination,' says Hölker" (Irwin, 2018).


VULNERABLE SPECIES Darwinia biflora ON SITE

An endangered species of shrub (Darwinia biflora ) growing "to 80cm high" has also been recorded from this site, as well as other endangered shrubs assumed to exist there and these endangered species of shrub being removed are not, of course, included in the number of trees being removed, since shrubs do not meet the height criteria of a 'tree'. This shrub Darwinia biflora is particularly endangered since its natural range was from a small area of Sydney including the Ryde area ("Ku-ring-gai, Hornsby, Baulkham Hills and Ryde local government areas"), most examples of which have been similarly cleared for over-development, and so "biodiversity credit offsets" do nothing when there are no remaining fragments of habitat left to spend the supposed offsets on.
https://threatenedspecies.bionet.nsw.gov.au/PasSearchSpecies?speciesName=Darwinia+biflora&generalType=Shrubs
recommends the following conservation activities for Darwinia biflora, all of which are being ignored:

"Identify sites that are a high priority to protect."
This site is not being protected. It should be a high priority, given the proximately to the National Park and other mass vegetation clearance in Macquarie Park and elsewhere in its limited range.

"Negotiate with public authorities to increase legislative protection for high priority sites on public land."
Unfortunately this is not public land, although the developer has NOT offered to dedicate part of the site to the public/national park instead.

"Liaise with private landholders to protect sites on private land."
NSW Government should do this but is not.

"Threat and habitat management programs will be implemented by public authorities on public lands."
N/A. since it is unfortunately not public land

"Ensure easement maintenance activities will not affect survival of populations."
Most of the ecosystem will be destroyed during construction, although the small amount of vegetation that survives construction will then be destroyed by the ongoing operation and mismanagement by the private complex.

"Advice will be provided to consent and planning authorities so that informed environmental assessment and planning decisions can be made."
I am giving advice and the "consent and planning authorities" should reject this proposed development

"Investigate aspects of the ecology of the species."
N/A when it will be destroyed to start with. However, the changed conditions will probably mean that this and the other threatened species can no longer survive even in the tiny amount of proposed retained vegetation in the extreme south-west corner of the site.

"Identify and survey potential habitat."
The habitat wad identified, yet it is being permanently destroyed by this inappropriate development

"Encourage community involvement, particularly in the implementation of threat and habitat management programs and monitoring programs."
As part of the community, I encourage this threat of the proposed development to be rejected.

"Provide advice and assistance to private landholders, to identify actual and potential threats and negotiate the implementation of on-ground works to address threats."
This is not being done and the habitat is being intentionally and permanently destroyed

"DEC advised of any consents or approvals which affect species."
This will affect this and numerous other threatened species.

"Re-assess conservation status of species. Darwinia biflora"
The shrub was already Vulnerable, and the permanent removal of a site where it is confirmed recorded will threaten it further.

The permanent harm to the endangered bat species, and indeed all other forms of nocturnal and even daytime species by the abnormal level of 24/7/365 light, heat and noise and vibration generation by the proposed development is perhaps even more extensive. This includes but is not limited to, bats, owls, frogmouths, possums, insects, plants, and daytime animals and plants whose sleep and seasonal cycles will be disrupted by the excessive artificial light, heat, noise and vibration that affects far beyond the boundary of the actual development site. Even if someone is not looking at the building direction at all there is no escape, since this unnatural lighting will be reflected 24 hours a day by the Lane Cove River as well, so the only thing humans or animals ever see any more is this offensive inappropriate "data centre". The proposed development tries to exacerbate these negative impacts, by not only making the 24 hour a day lit-up complex more than 50m high, but even ensuring there is as much additional unnatural lighting as possible by lighting up the south and west side of the complex with thousands of additional, completely unnecessary "decorative lighting" [sic].


PROPOSED ELECTRICITY GENERATING WORKS ARE NOT PERMITTED IN E3 ZONE

"E3 zone pursuant to RLEP 2014" prohibits, among other things, "Electricity generating works;"
Yet as can be seen in the proposal, there is an electrical substation in this proposal, as well as a diesel generator and the dangerous fire-prone storage of "840kL 12 x 70kL tanks" of diesel fuel. ("Dangerous Goods 840kL diesel storage capacity (12 x 70kL tanks)") Thus there will be "Electricity generating works" in spite of it being prohibited in E3 zone. Data centres are also an "extractive industry" in spite of these also being prohibited.

DEVELOPMENT EXCEEDS MAXIMUM HEIGHT OF BUILDINGS, 50.93m vs 30m/45m 'for recreational buildings only'

The maximum permitted height of buildings is 30m, meanwhile this proposal exceeds this by more than 20m at 50.93+m. As confirmed by EIS - Julius Avenue Data Centre 240625.pdf p. 48:

"3.3.3.5 Building Height
The maximum height of the main data hall building in the centre of the Site is 50.93m,
which constitutes the mesh screening to the rooftop plant in the north-eastern corner of the building. [..] The Site is subject to a 30m base maximum building height development standard pursuant to Clause 4.3 of RLEP 2014 and an incentive maximum building height development standard of 45m pursuant
to Clause 7.7 of RLEP 2014.

The Proposal seeks a maximum building height of 50.93m, which exceeds the 45m incentive maximum building height development standard by 5.93m or 13.1%."

The report cites a 'bonus' height of 45m subject to conditions (the Macquarie Park Corridor Precinct Incentive Height of Buildings). However, at 50.93m, the development still exceeds the 'incentive' height of 45m by 5.93m+. I also argue that the development does NOT meet the criteria to be granted the 'bonus' height' of 45m. However at 50.93m+, it illegally exceeds the maximum 'incentive' height of 45m by 5.93m+ and should be rejected. The illegal extra height of the building has additional extreme negative impact when viewed from the other sides where the cliff then steeply drops off to the Lane Cove River below, so all that is seen from a vast surrounding area is the unnatural lit-up eyesore of this illegally 50.93m+ data centre. As well as being lit up 24 hours including all night every night, the proposed reflective metal finishes mean it will blind onlookers with reflected sunlight during the day as well. The extreme height of the building also exacerbates its other risks such as being hit by lightning, being the tallest object on the highest point before the steep dropoff.

This development is illegal even under the maximum "incentive height" of 45m. However it should not qualify for the Macquarie Park Corridor Precinct Incentive Height of Buildings anyway.
"only if the consent authority is satisfied that the development includes adequate provision for one or both of the following—
(a) recreation areas that are configured and located in a way that is appropriate for the recreational purposes of the Precinct,
(b) an access network that is configured and located in a way that will allow a suitable level of connectivity within the Precinct."

The proposed development dismally fails both these criteria.
a) The site is not and is not suitable as a 'recreational area'. It is an unpleasant expanse of bare concrete next to a private, noisy, heating, polluting, dangerous, data centre and diesel generator, as well as a dangerous electrical substation. Nobody will hang around next to such a complex for 'recreation' and if anyone loiters, they will surely be told to move on by security guards. In reality the grounds may be used by employees of the data centre and nobody else.
b) Including a concrete path along one edge of the complex does not count as "(b) an access network that is configured and located in a way that will allow a suitable level of connectivity within the Precinct.". By contrast, it would be illegal to block access entirely to the existing roads and walking paths, and illegal to block access to the fire trail. The development has lead to a liability and decrease in the current level of 'connectivity' and does not deserve an 'incentive' height on this basis either, it thus dismally fails both criteria a) and b).
It should also be noted that there is effectively nowhere for pedestrians to go, since they are blocked by a steep cliff and the fact that pedestrians are not allowed on the M2. Instead of expanding connectivity, the development is just degrading the walking track that is already passing through the site, removing the pleasant forest it formerly passed through and replacing the walking track itself with a dead-end road and an electrical substation, and adding a boring and unpleasant concrete path at the west edge directly adjacent to the building that effectively leads nowhere. The proposed internal road is a dead end and does not expand "connectivity" either. As a decrease in both connectivity and recreation, the incentive height should not be granted.

The development thus dismally fails both criteria a) and b) and should not be granted an 'incentive height' of 45m. However, the proposal at 50m+ already exceeds the maximum permitted 'incentive height' of 45m and should be rejected. I am unclear if it also violates the additionally required incentive criteria of "Maximum Incentive FSR: 1.5:1 " but it probably fails this as well. The proposal should be rejected.

VIOLATES REQUIRED LANDSCAPING SETBACKS

As the developer's own report (SEARs Request - Julius Avenue Data Centre.pdf p. 18) states, Macquarie Park Precinct requires:

"Building Line Setbacks
The Building Setbacks Map provided at Figure 11 below prescribes the following building setbacks for the Site.

• 6m setback to all existing and new streets unless otherwise
specified;
• Minimum side and rear boundary setbacks of 9m;
• For the Site, the portion to the south-east of Street 1 is required to
be retained as a landscape setback. "

However as the proposal admits, it violates the required "minimum side and rear boundary setbacks of 9m". To compound this violation, it violates this setback directly adjacent to Lane Cove National Park and this violation should NOT be permitted.


NOT SUITABLE ADJACENT TO LANE COVE RIVER NATIONAL PARK, AND THIS HAS NOT BEEN CONSIDERED DURING DEVELOPMENT PROPOSAL, FOR EXAMPLE, NONE OF "Developments adjacent to National Parks and Wildlife
Service lands" publication requirements ARE MENTIONED, CONSIDERED OR ADHERED TO.

https://www.environment.nsw.gov.au/publications/developments-adjacent-national-parks-and-wildlife-service-lands

The proposed development site is DIRECTLY bordering the lane Cove River National Park. This fact is barely mentioned in the reports, intentionally not marked on the maps, and not taken into consideration at any point during this inappropriate development proposal.

The "consent and planning authorities" should thus assess this development proposal as to how it passes, or rather, fails, the guidelines in this report about developments next to National Parks, which are the estate of the NSW government and all NSW residents and taxpayers. They will quickly see that the proposed development fails almost all these requirements and thus should be rejected.

"2. Issues to be considered when assessing proposals adjacent
to NPWS parks 4
2.1 Erosion and sediment control 4 "
FAIL!
"2.2 Stormwater runoff 5 "
FAIL!
"2.3 Wastewater 8 "
FAIL!
"2.4 Pests, weeds and edge effects 8 "
FAIL!
"2.5 Fire and the location of asset protection zones 10 "
FAIL!
"2.6 Boundary encroachments and access through NPWS land 11 "
FAIL!
"2.7 Visual, odour, noise, vibration, air quality and amenity impacts 12" FAIL!
"2.8 Threats to ecological connectivity and groundwater-dependent
ecosystems 13 "
FAIL!
"2.9 Cultural heritage 14 "
FAIL!
"2.10 Access to parks 15 "
FAIL!

The proposal dismally fails ALL of these, and thus should be REJECTED by "consent and planning authorities" . It may seem superficially to fulfill 2.10 Access to parks' by the fact that hypothetically speaking, an unnatural paved path with unnatural "decorative lighting" [sic] can be used to access the national park, but in reality, park users will be confused by the unnatural access that looks nothing like a national park, the unpleasant light, heat and noise generation, and the fear caused by the round the clock operation and security fencing and guards, probably unsure as to whether it is 'really' a public access path at all. the security guards themselves will probably treat anyone walking past as 'suspicious', and employees may be unaware that the general public is permitted to access the site. During operation, since the complex is privately owned, they can also 'temporarily' close access to the park with impunity, leaving people trapped, especially if they walked from another direction to find the exit 'closed'. In the case of an emergency like a fire, flood, or landslide, this could even lead to the death of people trying to walk through the park, since in these cases, the private paths to exit the park would unambiguously be 'closed' at the first sign of issues, similar to the closure of a shopping centre toilet for 'cleaning' or 'maintenance'.

PEOPLE ARE INTENTIONALLY LED TO BELIEVE IT IS NOT A NATIONAL PARK WHEN THEY DO CROSS THE BORDER INTO THE ADJACENT STRIPS RESERVED AS NATIONAL PARK. INSTEAD THE INTERFACE IS VAST STRETCHES OF CONCRETE AND THOUSANDS OF UNNECE+

STOP CLEARING NATIVE BUSHLAND! We don't need more harmful projects like this one especially if it's going to be used to run AI! Also planting trees to make up for the ones that will be cut down is not nearly good enough. Cutting down the trees will release CO2 and the newly planted trees will need decades to grow and there's no guarantee they will be taken care of either. WE NEED TO PROTECT OUR BUSHLAND ESPECIALLY AS WE ARE IN A CLIMATE CRISIS! We need to STOP this data centre from being built! I am sick of my future being gambled with because some people want to make money at the cost of our environment, health, and safety!

I object to the building of a data centre on Julius Avenue. I believe it will have a negative effect on the local ecosystem. Due to its close proximity to Lane Cove national park, this area is likely highly populated by wildlife. The area currently acts as a buffer zone between urban development and Lane Cove National Park, which I believe to be significant. I believe that removing or chopping down trees to make way for this data centre will have a negative impact both on the local wildlife and the environment itself. The trees that are currently on the lot have been there for likely decades, and have provided homes for local wildlife and helped stabilise the ecosystem.

Please, don’t continue allowing our precious remnants of indigenous bush land to be further eroded by development. The area in question provides protection, habitat and night roosting sites for a population of native birds, including satin bower birds and scarlet honeyeaters. Powerful Owls are under great stress already, and have been sighted in this area.
New plantings do not prevent the permanent damage from destruction of mature habitat.
The area is in constant use by walkers, runners and families seeking recreation and a break from the city life.
Please don’t allow short sighted development to further impact one of the dwindling pockets of natural resource in our beautiful city.

Thank you.

I first acknowledge that some concerns of a technical variety have been addressed. It is quite possible for risks around flood and fire to be effectively mitigated. However, there are other substantial issues that have not been addressed.

Community concerns have not been given the same attention as agency concerns - the response to agency concerns is much more comprehensive and detailed, with material being explicitly covered in the table, while for community concerns, references are made to the appendixes, showing the relative priority given to community as compared to agency concerns. But, needless to say, it is the locals who will be directly affected by the development, with the so-called community consultations looking more like a box-ticking exercise than anything else.

While there are already data centres on the riverbank, already making the environment less pleasant, another one makes things even worse, regardless of its scale. The impact of data centres is cumulative, and while it is sad that the existing data centres have been built, if we could at least ensure no more data centres are built in the area, that would be progress.

There is a definite problem in the noise analysis made for the structure, in that the noise is considered in isolation, rather than in the context of the noise made by other existing data centres, with whole noise situation not being manageable, but rather becoming incrementally worse.

It is problematic that any data centres are built at all, because we could get by with the current data centres - it is the mindless pursuit of economic growth without consideration for the consequences that is a problem in itself.

One community recommendation was that alternative sites be found for the data centre, with the response being that the data centre fits in with existing zoning. However, there are multiple problems with this response.

The first is that the zoning of "light industry" hardly fits with the operational reality of a data centre making continuous noise 24 hours a day, with more during testing. Light industry would normally mean a warehouse which shuts down for about half the day at least, with only a moderate amount of noise from forklifts and the loading / unloading of trucks. The zoning definition and expectations about what "light industry" means is clearly being abused here.

The second is that we in the area are already putting up with several data centres making noise in a natural environment, and it is clear that new data centres in existing industrial areas removed from nature would be far less contentious. If the critique is made about "our backyard", well, needless to say, we're already even now dealing with a lot in our own backyard.

The third is that the history of the area, while originally owned by the CSIRO, was owned in the expectation its continued existence as a nature reserve, and the sale violated the existing understandings about the property and its future. Its natural status is much appreciated by bushwalkers such as myself.

A further problem with the noise - both in itself and in accumulation with that of other data centres - is its impact on wildlife in the area, something that has not been adequately addressed. There are no references to "wildlife" or "fauna", let alone wildlife such as the "powerful owl" in the Noise and Vibration Impact Assessment. While there is some attempt to address the impact on people - while in isolation, and not in the context of other data centre developments - the total prioritisation of the impact of humans flies in the face of the numerous concerns put forward by the community about this.

Ideas about "biodiversity offsets" have been much criticised, as wildlife present in one area, particularly that which is scarce and endangered, does not magically move to another area which has been set aside as an offset.

Even after the modifications, the development is one which should not be completed, it has too many problems and impacts which have been ignored, and it is pretty much impossible they could be.

Dear Department of Planning, Housing and Infrastructure
Re: Julius Avenue Data Centre – Amended Application (SSD-80018208)
I frequently visit Lane Cove National Park to walk the various trails including the Great North Walk and marvel at the flora and fauna.
I regularly sight wallabies, birds and turtles. Many of these creatures are nocturnal and are already struggling in this urban national park with the impacts of the urban development surrounding them.
I would hope we would strive to protect such a unique oasis within the urban environment rather than put more pressure by allowing a development that is at odds with the environment surrounding it.
There are much more appropriate sites for datacentres, far away from national parks and bushland.
I object to this development, on the following grounds.
- The location of a massive warehouse-like facility with 24-7 lighting and the sound of air conditioners continuously running, will negatively impact the adjacent national park and the iconic Great North Walk. Flora and fauna willdie off and never recover.
- Backup generators, thousands of litres of stored diesel, fluorescent lighting illuminating it every hour of the day and air conditioners humming does not match a bushland setting.
- Right near this development is a narrow yet crucial wildlife corridor that if disrupted will have devastating impacts on wildlife and flora. The removal of mature trees will compound this effect.
- The potential pollution in the river from the construction and ongoing running of the data centre.
- The bushfire risk right next to bushland is extremely worrying.
- These nondescript buildings are often built in clusters, (says Dr Bronwyn Cumbo, a transdisciplinary social researcher at the University of Technology Sydney). Often “it’s an industrial hub” rather than one datacentre, she says.
- It is inappropriate in this location to have one datacentre, let alone many.
- I am concerned to hear what has happened overseas and fear this will happen at this site if allowed to go ahead. In some places where many data centres have been built, such as Northern Virginia in the United States and Dublin in Ireland, communities have reported rising energy and water prices. They have also reported water shortages and the degradation of valued natural and historical sites.
- The eight public interest principles for datacentres are not met.
- The plan to implement these principles has been endorsed by the Clean Energy Council, Electrical Trades Union, Australian Conservation Foundation, Climate Energy Finance, WWF-Australia, Smart Energy Council, Nature Conservation Council of NSW, RE-Alliance, Queensland Conservation Council, Carbon Zero Initiative and Environment Victoria.

The eight principles include:
1. Be powered by 100% additional renewable energy
2. Strengthen grid stability
3. Be appropriately sites to minimise impacts on nature and land use
4. Minimise embodied emissions and maximise efficiency and circularity
5. Use water resources responsibly
6. Operate with transparency
7. Commit to earning and delivering ongoing social license
8. Support the training and upskilling of the workforce
I agree with these principles and request that they are applied to this development.
Thank you for considering my submission.
Jen Barling

Re: Julius Avenue Data Centre

This is in addition to my previous submission (SUB-92136956 27/08/25) OBJECTING to the project.
Although the amended proposal (SSD-80018208 - Amendment Report and associated documents) has made some improvements that are better than nothing, I still strongly OBJECT to the proposed Julius Avenue Data Centre. The amended proposal has NOT addressed most of the issues I raised in my previous submission. I do not have time to repeat them all here but most of the issues in my previous submission have NOT been adequately addressed. There is no reason that a data centre has to be built at this specific location, which is very undesirable especially given that it is in a high risk fire and flood zone and the facility could be built literally ANYWHERE else, including in a regional area with more space and less job opportunities.

I also note that the proponent did not respond to the previous submissions within the required timeframe. Meanwhile the general public is not allowed to make submissions months later than required! When the project had its very short pubic comment period again was thus seemingly random so many people would be simply unaware they are now required to comment on the Julius Avenue Data Centre again.

DATA CENTRE WILL EXPAND IN FUTURE ONCE INITIAL PROJECT IS BUILT

In addition the supposedly 'amended'/'revised' proposal is made with the objective that once it is built they will simply expand the facility in future, both in taking up more of the site and adding even more levels of height. This would also require expansion of the demanded Ausgrid "sub/transmission switching station" and diesel backup generators to a larger more destructive facility as well.
The amended proposal seeks to be able to expand the data centre and associated infrastructure in future and thus the remaining natural vegetation will be destroyed anyway and the buildings and infrastructure expanded in every direction, both outwards and expanding the height of the buildings, perhaps to the originally proposed 50m or worse.

FILTHY DIESEL GENERATION, VAST ELECTRICAL AND WATER REQUIREMENTS AND 0% RENEWABLE ENERGY USE IS UNACCEPTABLE! DEVELOPER ALSO ARROGANTLY EXPECTS AUSGRID TO BUILD IT A PRIVATE POWER SUBSTATION ("sub/transmission switching station") FOR ITS OWN USE AND AUSGRID AND ITS RESIDENTIAL CUSTOMERS TO BE THE ONES EXPECTED TO PAY THE EXTREME AND ONGOING COST OF BUILDING AND MAINTAINING A PRIVATE POWER SUBSTATION CONSUMED EXCLUSIVELY FOR DATA CENTRE'S OWN USE. THE POWER BILLS OF ALL AUSGRID'S OTHER CUSTOMERS MUST RISE TO SUBSIDISE THIS PARASITE AND ITS 0% RENEWABLE ENERGY GENERATION.

IT IS UNACCEPTABLE THAT THIS OFFENSIVE DATA CENTRE DOES NOT HAVE ANY RENEWABLE ENERGY GENERATION, NOT EVEN ONE SOLAR PANEL, and to make things even worse, also expects to have a vast generator of one of the filthiest kinds imaginable 'diesel', which is itself a 'fossil fuel', and fossil fuel generation is supposedly not permitted in Macquarie Park. The data centre also expects to also waste as much electricity ans possible and increase its already vast heat and light generation 24/7/365 with all its 'decorative lighting', and "decorative lighting" SHOULD NOT BE PERMITTED. The proposed 'decorative lighting' will also blind and dazzle everyone and block any view of the scenery from the few locations that have not had the view blocked by the data centre building itself.

UNNECESSARY AND WASTEFUL "DECORATIVE LIGHTING" SHOULD NOT BE PERMITTED!


REVISED PROPOSAL STILL HAS VAST NUMBERS OF UNACCEPTABLE ENERGY WASTING 'DECORATIVE LIGHTS'
There will already be lighting at the data centre 24 hours a day for its required 24/7/365 operation, and it is disgusting and offensive to make the building into even more of a lit up eyesore and parasitic electricity drain with the vast numbers of worthless 'decorative lights' retained in the revised development. The 'decorative lights' will also confuse and kill any remaining wildlife, as well as lure them to the building for an untimely death. Insects are attracted by lights and birds and bats in urban environments may catch insects near lights, these usually being the normal kind of streetlights, and birds, bats and insects will instead crash into and/or be confused by reflections in the unnatural 40+m high building. All 'decorative lights' SHOULD BE REMOVED!

Since Macquarie Park is still primarily a business park and this is at the extreme end of it, there are few people loitering around after-hours and members of the public simply will not go to or use the tiny, unpleasant area in front of the hot, offensive, noisy data centre building that has also blocked any views that were formerly at the location, so lighting up this largely deserted area with 24 hours a day 'decorative lighting' is even more useless and offensive. Although in the revised proposal some of the 'decorative lights' are no longer on the back of the building, the worthless and energy wasting 'decorative lights' are still onthe sides and front of the building and due to the exact position/angle/shape of the site and building can still be seen not only in Macquarie Park itself but even from Epping Road and the other side of the Lane Cove River!

It is also confusing for humans that do not often visit the area, since this abnormal level of lighting combined with the immense height of the building and the blocking of the view may make them assume Macquarie Park continues beyond the data centre building instead of the reality of this being where it plunges onto a steep cliff and ends. Visitors who are unfamiliar with Macquarie Park are probably trying to exit the area to the north near the train station and main roads, and tricked into going the wrong way entirely, lured by the bright lights and immense height that are usually associated with 'more built-up areas'. This is of no benefit to the data centre either, since it is not the sort of facility that wants walk-in customers.

REVISED PROPOSAL DOES NOT QUALIFY FOR "Macquarie Park Corridor Precinct Incentive Height of Buildings" AND THUS SINCE AT C. 40M IT GROSSLY EXCEEDS THE MAXIMUM PERMITTED HEIGHT OF 30M IS ILLEGAL

Macquarie Park Corridor Precinct Incentive Height of Buildings allows buildings up to 45m
"only if the consent authority is satisfied that the development includes adequate provision for one or both of the following—
(a) recreation areas that are configured and located in a way that is appropriate for the recreational purposes of the Precinct,
(b) an access network that is configured and located in a way that will allow a suitable level of connectivity within the Precinct."

The revised (and original) proposed development dismally fails both of these a) and b) and "Macquarie Park Corridor Precinct Incentive Height of Buildings" should NOT be granted.

It would also be illegal to block access to the pre-existing fire trail that is nothing to do with the development itself and no new facilities or connectivity are being created and there are no 'recreation areas' at all. In reality the small unpleasant areas crammed up against the data centre building will be used only by the staff of the data centre, and the short paved path from Richardson Pl. leading to and along the east edge of the data centre building (as well as the path on the west side) be used by the data centre';s own employees to go in and out of the data centre workplace. The vast numbers of stairs also mean that people probably will not walk up and down them unless they feel they 'have to' and thus will in reality only be used by employees of the data centre, especially since it will be unclear to outsiders that the public really are allowed to access a small part of the site outside the security fencing. .Few people will even go to this extreme end of Macquarie Park and certainly not use it as a 'recreational' or connectivity area. The project is not providing new 'connectivity', just risking a fire trail that was already there and would have been illegal to block or remove. Putting the Ausgrid power substation at the back of the site instead of the front also makes it a target for vandalism, and people do not usually go to places adjacent to dangerous power "sub/transmission switching station", diesel generators, wastewater control systems and unpleasant light, heat and sound generating data centre buildings unless they 'have to', so any areas supposedly accessible to the public will really only be used by the data centre employees.

LOCATION OF POWER SUBSTATION ("sub/transmission switching station") AT THE BACK OF THE SITE IS UNACCEPTABLE, SHOULD BE REQUIRED TO BE AT FRONT ON JULIUS AVE FOR EASIER AND CHEAPER MAINTENANCE AND SERVICING BY AUSGRID and easier emergency access/placement

The proposed location of "sub/transmission switching station" means that most of the additional trees and ecosystem 'saved' by the amended proposal will have to be cleared anyway, but by Ausgrid instead and on an ongoing basis. Developer thus just has the trees and vegetation cleared anyway, but now requires Ausgrid to take the 'blame' and responsibility for it. A few less trees and natural vegetation will have to be cleared in the amended proposal, but the 'savings' are far less than the ones claimed by the developer, so it is only marginally less destructive than before and the demanded reduction amount in biodiversity offset credits and tree planting fees are illegitimate. The amended proposal is a slight improvement but certainly NOT to the level the developer claims, and the false claim that tree canopy cover will INCREASE vs the site's current condition is both impossible and a blatant and nonsensical deception.

The proposed location of the power "sub/transmission switching station" demanded to be provided and maintained by Ausgrid, at the back of the site is also unacceptable. It also deliberately places the power substation in greater risk of either catching fire or causing a bushfire, since even though it is inside the 'APZ this is the APZ for the data centre building not the electrical "sub/transmission switching station" itself, and any bushfire or fire at the data centre can jump easily to and from the electrical substation, but it will apparently be Ausgrid who has to deal with the consequences of it being demanded to be at this location, and in reality far more vegetation and trees will be cleared than shown in the 'amended' proposals, since there cannot any trees anywhere near the "sub/transmission switching station" but the developer expects Ausgrid to have to clear them instead and thus developer not have to pay the feeble biodiversity offset or tree planting credits for these trees that WILL be cleared anyway for the initial AND ongoing maintenance of the Ausgrid substation in the developer's own demanded location.

Having the "sub/transmission switching station" at the back of the building also reinforces that the private substation is for data centre's own exclusive use instead of being located at the front at Julius Ave where it would be easier to service and maintain by Ausgrid and not require the initial and permanent and ongoing destruction of even more natural vegetation, and the arrogant shifting of the permanent burden of removal of vegetation and trees to Ausgrid and thus outsourcing of the continuous maintenance time and cost to Ausgrid as vegetation and trees has to be continually re-cleared.

Developer should instead be REQUIRED to locate the power "sub/transmission switching station" at the front of the site on Julius Ave where it can be more easily serviced by Ausgrid from the street and not require the constant and ongoing removal of so many trees and native vegetation, FOREVER, and would also be further from bushfire risk. Seeing the power substation ("sub/transmission switching station")) from the street Julius Ave is not a problem since it will be dwarfed by the ugly 40+m high data centre that is far more offensive to look at than the relatively short electrical apparatus, and it will require far less ongoing maintenance by Ausgrid at this location at the front on Julius Ave and easier to access.

MOST OF THE 'SAVED' TREES IN THE AMENDED PROPOSAL WILL IN ACTUALITY HAVE TO BE CLEARED FOR DEMANDED AUSGRID "sub/transmission switching station" AND THIS WILL ALSO ELECTROCUTE WILDLIFE

Worst of all, developer has misled about the impact of the electrical substation. It is not possible to have trees anywhere near a "sub/transmission switching station", as well as trees growing it would be too much of a risk for tree branches or trees themselves to be able to fall on the power substation, and all trees will have to be removed entire and/or lopped on a regular basis. Thus most of the trees that were going to be removed in the original proposal and will supposedly not be cleared in the revised proposal will be removed anyway, but this will be outsourced to Ausgrid to have to do it so that the developer does not have to pay the feeble biodiversity offsets or tree planting credits for them,. Thus although a few trees will be saved by the revised proposal vs the original one, it is far less than the developer claims, and the revised proposal is in many ways even worse since they have falsely claimed a reduction in the number of biodiversity credits and offset plantings they are eligible for, when the revised proposal is only minimally less damaging. Yet developer expects Ausgrid to be the ones required to do all this tree removal for the developer's private substation and therefore not be added to the tree clearance and threatened species habitat destruction totals that the developer did themselves. Trees that WILL have to be removed not only initially but on an ongoing basis by Ausgrid are not added to the total tree destruction of the 'revised' project, which in reality will thus destroy almost as many trees and native vegetation as before.

wildlife especially bats will also be electrocuted by the demanded Ausgrid "sub/transmission switching station" and in reality the endangered species will be threatened by the data centre building directly, not merely the clearance of some area of natural vegetation, and thus the biodiversity offset credits for destroying bat habitat are not really eligible for reduction in amount vs the original proposal, since especially with its location next to the forest and elevate position, bats will be electrocuted by the "sub/transmission switching station", but since they developer expects Ausgrid to build it for them, this is not factored into their falsely demanded reduction in biodiversity offset credits required of the revised proposal. And as mentioned earlier, the "sub/transmission switching station" has been located at the back of the site so that the developer can force Ausgrid to provide an even larger and more destructive transmission station in future to destroy even more habitat and electrocute more wildlife, but expect Ausgrid to be the ones dealing with the consequences.

The vast amounts of unnecessary lighting, including 'decorative lighting' will attract and confuse insects an other wildlife towards the lights. In urban areas some bats and nocturnal birds have learned to catch insects near lights, but they do these at normal streetlights and if nocturnal animals are lured toward the unnatural 'decorative lighting' as a food source, they will crash into the abnormal 40+m high building or, as we saw, be electrocuted by the "sub/transmission switching station". The location of a 40m high building right on the edge just before the steep dropoff makes the likelihood to birds and bats crashing into the building even greater, and attracting and confusing them by lighting it up with idiotic and unnecessary 'decorative lighting' will make this even more likely.

Thus in some respects the revised proposal is worse than the old one, since the developer now falsely tries to claim there is reduction in the amounts of biodiversity credit offsets and replacement planting fees they are legally required to provide. But the same amount of destruction will occur as before, it is just now required to be done at Ausgrid's cost and expense and ongoing maintenance indefinitely.

REMNANT NATURAL VEGETATION SUPPOSEDLY NOT CLEARED DURING CONSTRUCTION WILL NOT BE REHABILITATED
Although the revised development plans have changed the building footprint slightly and more of the natural vegetation will not be replaced with a building, the areas are still part of the construction site and remain privately owned land. They will be in even worse condition once the construction is finished and probably cleared and used as an illegal waste dump, even if the submitted plans do not specify this this is how construction workers operate. I note that the majority of the supposedly retained forest is not part of the 'preservation' area but instead called a 'rehabilitation area' suggesting it will be modified and trashed during construction even if no building is built there. Then after the development is completed it will not be managed or 'rehabilitated' for ecological values since it is the private grounds of the data centre and the employees wouldn't even know the different between weeds and native plants anyway. The areas in/near the APZ that have no shrubs or trees and are designated to be planted with ground level 'native ground-covers' will be immediately smothered and choked with weeds and will not survive. Since the area is still the private property of the data centre it will obviously not be appropriately weeded and maintained and any 'native groundcovers' will be killed off very quickly and not replaced. The weeds will then spread to the remaining vegetated areas of the site and again not appropriately maintained.

DEVELOPER ASSUMES THAT IT WILL BE ABLE TO DISCHARGE POLLUTED WATER AND EXTRACT WATER OUT OF THE LANE COVE RIVER FOR ITS OWN PURPOSES IN FUTURE, THIS IS WHY THE DATA CENTRE IS PROPOSED FOR THIS OTHERWISE UNSUITABLE, RISKY AND FIRE AND FLOOD PRONE LOCATION

Why the proponent has decided to site the data centre at this location, when it could have been located literally anywhere else including in an area that is not a high risk fire and flood zone, is due to another unstated reason: the proximity to Lane Cove River. The proponent assumes that now or in future data centres such as this one will be able to simply take water from the Lane Cove River for cooling and other purposes and unlike in some regional areas, although the Lane Cove River will get very shallow in a drought at least at this location it will not stop running entirely.
And much like a filthy diesel generator has been forced into this project under the claimed reasoning that it will only be used during 'emergencies' (any power outage), in future the data centre will cite 'abnormal' conditions and it 'needs' this water because otherwise there would be a safety risk.

(And of course the polluted runoff from this site goes into the Lane Cove River as well, except for the other parts that flood onto Epping Road). Thus if there is a lack of water in future, due to a drought etc. and a lack of drinking water and other restrictions for everyone else, the data centre, it assumes, can just start pumping water out of the Lane Cove river for its own use, wasteful 'cooling' and soforth while meanwhile all the residential customers suffer water restrictions. This is probably not permitted by current regulations [???], but the investors making money out of this project don't live here and neither know nor care about local conditions or laws and assume that this will be possible in future. That is why they have chosen to build a data centre in this otherwise unsuitable and dangerous fire and flood prone location, since it is next to the Lane Cove River and would be able to extract and emit water both ways from its own property. And the alternative in a drought condition is that the data centre just uses up the area's entire supply of drinking water, so we can see how out of desperation their taking of water from the river instead would be approved!

Although there are already too many other data centres in the Macquarie Park area many of them are not directly on the Lane Cove River and thus cannot discharge and extract water directly from the river like this parasitic Julius Avenue Data Centre hopes it can in future, although it is surely why some of the existing and proposed data centres have already moved into the area. This is how the destructive parasitic project is being sold to investors, the supposed long term 'security' of being right at the Lane Cove River and able to extract and discharge water in and out of it for its own selfish purposes, which would probably be 'necessary' if a drought situation arose, and especially with global warming there will be another severe drought at some point in future. The regulations at Macquarie Park probably do not prohibit this, since the types of businesses that historically were at Macquarie Park would never have required that much water use, and the laws have not been rewritten to deal with the realities of parasitic liability data centres. But the data centre cannot 'recycle' rainwater if there is no rain, and thus vast amounts of 'cooling' water will have to be drawn directly out of the Lane Cove River in future. This would not necessarily eventuate, but this supposed 'future proofing' is how they are tricking investors into pouring money into this ill-thought-out project and expecting everyone else in the region of Macquarie Park to deal with the severe, ongoing and irreversible negative externalities. Supposedly data centres have recently effectively been outlawed in suburban Melbourne and it is easy to see why.

Of course the site is already a high risk fire and flood zone even without the data centre there and the data centre itself will be a severe fire and flood risk. The site is already a flood risk zone but again with global warming floods will become more common and exactly what is supposed to occur if there is a flood at the site is unclear. this is not a normal office building and any of the infrastructure related to the data centre both inside and outside the building getting wet could lead to an extreme disaster. the sole consideration of the proposed data centre is the protection of their own asset and perhaps the evacuation of their own staff, and they have little regard for the dangers posed by a fire or flood at or caused by their site on everyone else in the area, especially on the extremely busy Epping Road that the plans never even show on the maps, to try to trick readers into thinking there is actually nothing there.

STORMWATER AND EROSION WILL FALL ONTO EPPING ROAD, CAUSING FLOODING AND OTHER BLOCKAGE OF EPPING ROAD, AS WELL AS BLOCKING EPPING ROAD DURING FIRE, CONSTRUCTION AND ONGOING MAINTENANCE

An overflow of polluted water from the site naturally goes downhill and what is located 'downhill' from the data centre is actually Epping Road. For some reason Epping Road is not usually marked on the included maps but the south/south-west edge of the site is NOT 'nothing' as depicted but Epping Road one of the busiest main roads with much of Sydney commuting through it. Even without the data centre there Epping Road floods near here from time to time. The data centre will thus lead to flooding and other erosion blocking Epping Road and causing severe traffic chaos for much of Sydney on an ongoing basis, as well as limiting the ability for others to evacuate if a disaster affected the general area.

The walking tracks both on and off site will ALSO be affected by erosion and pollution runoff and be damaged and may become unsafe and simply collapse. Yet the parasitic data centre will not pay for the maintenance of these destroyed tracks, especially if the erosion and damage caused by the Julius Ave Data Centre affects walking tracks lower down that are not on its supposed property.

I am opposed to the Julius Avenue Data Centre being built as I believe the local parkland environment and inhabitants that call it home should be protected so that future generations can appreciate, cherish the pristine parkland and its wildlife.

The proposed Data Centre being built should not go ahead as it will pollute and upset the harmony of the environment and is unwanted by most people who enjoy the peacefulness of the parklands.

As a volunteer for the Lane Cove National Parks I believe we have to think long term about protecting the environment for future generations..

Re: Julius Avenue Data Centre (SSD-80018208) Amended Application - Submission

Regarding the above Julius Avenue Data Centre (SSD-80018208) Amended Application, I hereby respectfully lodge my submission on behalf of myself and my family objecting to the proposed amended development:


The proposed development site at 6-8 Julius Avenue, North Ryde NSW (Lot 89 DP1082131) (the “Site”) is unsuitable for the development and operation of a 24 hours a day 7 days a week data centre for the following reasons:

• The amended proposed data centre is still too close to native bushland and national parks and too close to the Lane Cove River. Although the Amended Application proposes reducing the tree destruction from 509 trees to 334 trees to be chopped down, the proposed canopy cover in the Amended Application has reduced from 7,203m2 (25.16% of the Site area) to 5,512m2 (19.24% of the Site area). Accordingly, if developed, the data centre would only leave a small strip of residual native woodland between the development site and the Lane Cove River.
• The Site slopes steeply from street level at approx. 48 M AHD down towards the Lane Cove River where the southern boundary is approx. 24 AHD meaning that the total decline in height for the Site is 24 metres from street level to the southern boundary. The steepness of the Site down towards the Lane Cover River means that during construction of a proposed data centre, there is increased risk during heavy storms and prolonged rain events for site building materials, plastics and liquids to run off and spill into the Lane Cove River causing pollution and toxicity for fish and other marine species habitating the River and Sydney Harbour.
• The Amended Application proposes to install 48 × 3.2MW back-up diesel generators and 955,000 litres of diesel storage capacity plus an extensive array of lithium-ion batteries for uninterrupted power supply. Given the massive storage of diesel fuel and extensive array of lithium-ion batteries, the proposed development is really an industrial complex which is in zoning conflict with the surrounding commercial property in Julius Avenue and nearby.
• Given the close proximity of the National Park, Lane Cove River and other commercial buildings, motels and businesses including a child care centre in Julius Avenue, the proposed development combined with the abovementioned steepness of the Site is considered dangerous and unacceptably located as:
o There is too much risk of a major fire and related explosion from the lithium-ion batteries and diesel storage tanks spreading to adjoining buildings, bushland and the Lane Cove National Park which in late Spring, Summer and early Autumn would cause a major bushfire requiring evacuation of surrounding business premises and homes resulting in blockage of roads such as Epping Rd, Mowbray Rd, Delhi Rd and Lady Game Drive which would cause extensive traffic gridlock.
o The absence of any levy banks or bunker system to capture any minor or major leak of diesel or other liquid chemicals plus any major fire at the proposed data centre would leak a toxic mix of chemicals such as diesel oil, nickel, gallium, arsenic and fire retardant into the Lane Cove River and then into Sydney Harbour.
o Any major bushfire in the Lane Cove National Park risks spreading to the proposed data centre creating the explosion and river pollutant problems as outlined above.

In conclusion, I consider and recommend that the NSW Government and the NSW Independent Planning Commission reject the Amended Application for the reasons outlined above and then work with the Applicant to move the data centre development proposal to a location much more suitable elsewhere such as in the vicinity of the new Western Sydney airport provided such site is on reasonably level land and is more than 500 metres from any waterway (creek or river).

Thank you

My name is Heidi and I live in Ingleside, and I believe the building of a data centre in the heart of Lane Cove, near the North Ryde metro station, and located adjacent to the Lane Cove River would have detrimental adverse effects on the local environment, as well as implications for those living in the area. It has been determined by Semenov et. al. (2021) that data centers on average produce annual emissions which can vary from 5,168.4 to 7,008t CO2 per 1 MW of datacenter power. This implies severe release of greenhouse gases, and exacerbation of Australia’s climate crisis. Ngata et. al. (2025) additionally outlines the ‘local socio-environmental consequences—such as health impacts, water usage, noise pollution, infrastructural strain, and economic burden’ brought on by the development of data centres in urban and suburban areas. Ferreira et. al. (2019) estimates that due to the rise in prevalence and intensity of data center operations, CO2 emissions may increase between 9% and 27% by 2030. There is no doubt that this would have an extreme effect on climate change and natural disasters, as seen in Australia over the past few years. Those living next to data centres which have being established in the US have stated that they “..can't drink the water." (Fleury et. al., 2025), due to the residue present due to contamination from the data centre. The proposed date centre is approx. less than 500m away from an early learning centre, a similar distance to the reports of water contamination from the BBC. This same article outlines how local water systems such as rivers are contaminated by water run-off from data centres, which would be of extreme concern at Julius Avenue, due to its proximity the the Lane Cove River.
As a 17 year old who has watched the development of climate change in Australia, including unforeseen flooding, soaring temperatures, natural disasters etc., as well as the slow accumulation of data and research within recent years into the consequences of data centres on the environment and economy, as correlated with the rise in AI systems, I warn that the development of such infrastructure in suburban Lane Cove would have minimal to no benefits for the local community. Alongside this it would exacerbate environmental concerns through excessive water use for cooling, emission of toxic waste, and release of greenhouse gases into the local atmosphere. There would be high risk of water contamination of both local water systems and domestic groundwater systems. I would implore that the government reevaluate the necessity of this infrastructure, specifically in regards to its proposed location.