MidCoast Regional Organics Facility

Submission: Objection to SSD-84090218 – MidCoast Regional Organics Facility (Condensed Technical Version)

To: NSW Department of Planning, Housing and Infrastructure / Independent Planning Commission
Re: SSD-84090218 – MidCoast Regional Organics Facility

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1. Executive Summary

This submission objects to SSD-84090218 on the basis that the proposal fails to adequately address transport safety, infrastructure capacity, environmental risk, and site suitability under the Environmental Planning and Assessment Act 1979 (NSW).

While the strategic need for organics processing is acknowledged, the localised impacts are significant, underestimated, and disproportionately borne by the Forster–Tuncurry community.

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2. Transport and Road Safety (Critical Issue)

Inadequate Road Infrastructure

The proposal relies on The Bucketts Way and connecting rural roads, which are:

- Narrow, two-lane carriageways
- Lacking turning lanes, roundabouts, and overtaking opportunities
- Not designed for sustained heavy vehicle traffic

Deficient Traffic Modelling

The EIS relies on average daily traffic, failing to assess:

- Peak waste collection periods
- Clustered truck arrivals
- Seasonal tourism traffic

This results in underestimation of real traffic impacts.

Safety Risks and Black Spot Formation

Increased heavy vehicle movements (including night operations) will likely:

- Increase rear-end and turning collisions
- Create unsafe overtaking conditions
- Generate accident black spots at:
- Site access points
- Intersections along The Bucketts Way

No detailed crash risk modelling has been provided.

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3. Road Damage and Cost Burden (5-Year Impact)

Heavy vehicles will significantly accelerate pavement wear.

Likely impacts within 5 years:

- Pothole formation and edge failure
- Reduced pavement life
- Increased maintenance demand

The proposal lacks:

- A Pavement Impact Assessment
- Binding commitments for road upgrades or maintenance funding

This creates a cost-shifting burden to local council and ratepayers.

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4. Residential Amenity and Noise

24/7 Operations

Continuous truck movements will result in:

- Night-time noise (engine braking, gear changes)
- Sleep disturbance not captured by averaged noise metrics

Amenity Loss

The area will transition from rural/residential to a freight corridor, resulting in:

- Reduced liveability
- Increased stress and perceived safety risk

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5. Environmental and Wildlife Impacts

Odour and Operational Risk

Organic processing facilities present a known risk of:

- Odour emissions during system failure or overload
- Impacts exacerbated by local weather conditions

The EIS does not adequately assess worst-case scenarios.

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Wildlife and Ecological Impact

Increased traffic and 24/7 operations will:

- Increase wildlife vehicle strikes
- Disrupt habitat and nocturnal species
- Introduce pest species (birds, rodents)

Cumulative ecological impacts are insufficiently assessed.

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Water and Contamination Risk

Potential risks include:

- Leachate escape
- Stormwater contamination

Given proximity to sensitive coastal systems, failure events could have long-term environmental consequences.

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6. Property and Economic Impact

The EIS does not address likely impacts on:

- Property desirability
- Buyer perception

Factors include:

- Odour risk
- Heavy vehicle traffic
- Industrial proximity

These may result in reduced property values and market demand.

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7. Site Suitability and Strategic Concerns

Land Use Conflict

The proposal introduces industrial-scale infrastructure into a rural/residential interface, creating:

- Ongoing land use conflict
- Reduced compatibility with surrounding uses

Precedent for Expansion

Approval may establish a waste processing precinct, increasing likelihood of:

- Future expansion
- Additional waste-related developments

This cumulative impact is not adequately assessed.

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8. Legal and Planning Deficiencies

Under Section 4.15 of the EP&A Act, consent must consider:

- Likely impacts
- Site suitability
- Public interest

This proposal demonstrates deficiencies in:

- Traffic and safety assessment
- Environmental risk modelling
- Cumulative impact consideration

These deficiencies may expose the approval to legal challenge.

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9. Key Omissions

- No peak traffic modelling
- No detailed crash risk assessment
- No pavement impact analysis
- No binding road upgrade commitments
- Limited odour failure scenario analysis
- Inadequate ecological assessment

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10. Conclusion and Recommendation

The proposal:

- Relies on infrastructure not fit for purpose
- Underestimates safety and environmental risks
- Externalises costs to the local community

Recommendation:

The application should be refused in its current form, or deferred pending:

1. Full road upgrades prior to operation
2. Peak-based traffic and safety modelling
3. Independent environmental and odour assessment
4. Binding limits on future expansion
5. Developer-funded road maintenance framework

To: NSW Department of Planning, Housing and Infrastructure / Independent Planning Commission
Re: SSD-84090218 – MidCoast Regional Organics Facility

1. Executive Summary

This submission objects to SSD-84090218 on the basis that the proposal fails to adequately address transport safety, infrastructure capacity, environmental risk, and site suitability under the Environmental Planning and Assessment Act 1979 (NSW). While the strategic need for organics processing is acknowledged, the localised impacts are significant, underestimated, and disproportionately borne by the Forster–Tuncurry community.

2. Transport and Road Safety (Critical Issue)

The proposal relies on The Bucketts Way and connecting rural roads, which are narrow two-lane carriageways lacking turning lanes, roundabouts, and overtaking opportunities and are not designed for sustained heavy vehicle traffic. The EIS relies on average daily traffic, failing to assess peak waste collection periods, clustered truck arrivals, and seasonal tourism traffic, resulting in underestimation of real traffic impacts. Increased heavy vehicle movements, including night operations, will likely increase rear-end and turning collisions, create unsafe overtaking conditions, and generate accident black spots at site access points and intersections along The Bucketts Way. No detailed crash risk modelling has been provided.

3. Road Damage and Cost Burden (5-Year Impact)

Heavy vehicles will significantly accelerate pavement wear, likely resulting within five years in pothole formation, edge failure, reduced pavement life, and increased maintenance demand. The proposal lacks a Pavement Impact Assessment and binding commitments for road upgrades or maintenance funding, creating a cost-shifting burden to local council and ratepayers.

4. Residential Amenity and Noise

Continuous 24/7 operations will result in night-time noise from engine braking and gear changes, causing sleep disturbance not captured by averaged noise metrics. The area will effectively transition from a rural/residential environment to a freight corridor, reducing liveability and increasing stress and perceived safety risks.

5. Environmental and Wildlife Impacts

Organic processing facilities present a known risk of odour emissions during system failure or overload, which may be exacerbated by local weather conditions; however, the EIS does not adequately assess worst-case scenarios. Increased traffic and continuous operations will increase wildlife vehicle strikes, disrupt habitat and nocturnal species, and introduce pest species such as birds and rodents. Cumulative ecological impacts are insufficiently assessed. There are also risks of leachate escape and stormwater contamination, which, given proximity to sensitive coastal systems, may result in long-term environmental consequences.

6. Property and Economic Impact

The EIS does not address likely impacts on property desirability or buyer perception arising from odour risk, heavy vehicle traffic, and industrial proximity, which may result in reduced property values and market demand.

7. Site Suitability and Strategic Concerns

The proposal introduces industrial-scale infrastructure into a rural/residential interface, creating ongoing land use conflict and reduced compatibility with surrounding uses. Approval may establish a waste processing precinct, increasing the likelihood of future expansion and additional waste-related developments, with cumulative impacts not adequately assessed.

8. Legal and Planning Deficiencies

Under Section 4.15 of the Environmental Planning and Assessment Act 1979, consent authorities must consider likely impacts, site suitability, and public interest. This proposal demonstrates deficiencies in traffic and safety assessment, environmental risk modelling, and cumulative impact consideration, which may expose any approval to legal challenge.

9. Key Omissions

The EIS fails to include peak traffic modelling, detailed crash risk assessment, pavement impact analysis, binding road upgrade commitments, robust odour failure scenario analysis, and adequate ecological assessment.

10. Conclusion and Recommendation

The proposal relies on infrastructure not fit for purpose, underestimates safety and environmental risks, and externalises costs to the local community. It is recommended that the application be refused in its current form or deferred pending full road upgrades prior to operation, peak-based traffic and safety modelling, independent environmental and odour assessment, binding limits on future expansion, and a developer-funded road maintenance framework.

am writing to express my concerns regarding the proposed waste facility at Darawank.

While the proposal is described as a green waste operation, I am not convinced that this accurately reflects the likely scale and impact of the facility. Green waste processing still involves significant handling, storage, and transportation of material, and it is difficult to see how this can be considered low impact in this location.

A major concern is the effect on traffic along The Lakes Way. I am concerned that the proposal will significantly increase heavy vehicle traffic along this road. Even as a green waste facility, it will generate frequent truck movements, bringing a substantial number of additional heavy vehicles onto a route that is already heavily used. The Lakes Way is a key regional and tourist road, particularly busy during holiday periods, and the added volume of trucks will increase safety risks for local residents and visitors, including caravans, cyclists, and families. It will also contribute to congestion, noise, and road wear.

In addition, I am concerned about the environmental impacts associated with this type of operation. Green waste facilities can generate odour, particularly as organic material breaks down, which can affect nearby residents and the enjoyment of the surrounding area. Dust from processing and increased vehicle movements is another concern, especially in dry conditions. There is also the likelihood of increased fly and insect populations, which can become a nuisance and impact local amenity and health.

Water runoff is another important issue. Without careful management, runoff from stockpiled green waste can carry nutrients and contaminants into surrounding land and waterways, potentially affecting soil quality and local ecosystems. Given the nature of the area, this is a significant concern.

Beyond traffic and environmental impacts, I am concerned about the broader effect on the character of the area. This is a scenic and well-used route valued by both the local community and visitors. Introducing an industrial-style operation, even under the label of green waste, risks changing the nature of the area and diminishing its appeal.

Overall, the scale of the operation, combined with increased traffic and environmental impacts, raises serious questions about whether this is an appropriate location for such a facility.

For these reasons, I respectfully object to the proposal.

Yours sincerely,
Ann-Maree Montgomery

the project is far too big for the area, these sorts of massive trucks are already banned from this facility, as they are too big and heavy for the narrow nearby roads. there will be serious odor problems, and that many trucks 24/7 will obviously disturb residents sleep, as there is only one way in and out of the facility. we live near McIntosh Street, in Forster, so assume theses trucks will be using this road as the main, and only way, from the south, over the bridge to Tuncurry.

The exhibited statement appears to continue buck pass the impact of increased heavy vehicle traffic on both The Lakes Way and Failford Road. The SIDRA analysis does not adequately address the overall impact on both these narrow roads that provide the only emergency access for ambulances and SES vehicles.
While supportive of the MC ROPS for the MidCoast regional area, without guarantees for upgrading and safety improvements to The Lakes Way and Failford Roads and the Lakes Way & Failford Road intersection, before both the construction and operational periods commence we can not agree the development will have no significant impact on road conditions and residents' travel.

I write to formally object to the proposed MidCoast Regional Organics Facility (SSD-84090218) and, in particular, the proposed location of the compactor and associated operations in proximity to residential properties along Lake View Drive and The Lakes Way, Darawank.

The proposal is wholly inappropriate for this area and represents a serious and unacceptable intrusion into what is a predominantly residential and rural-residential environment. The introduction of an industrial-scale waste processing facility so close to established homes will fundamentally alter the character and amenity of the locality.

Residents in the immediate area will be directly exposed to a range of adverse impacts associated with the facility, including but not limited to:

Persistent and potentially severe odour impacts
Continuous operational noise, including the likelihood of 24-hour activity
Heavy vehicle movements and associated traffic congestion
Increased road safety risks from frequent truck traffic
Potential health impacts associated with waste processing operations
A substantial and irreversible loss of residential amenity
Significant negative impacts on property values
The proximity of the proposed facility to residential properties makes these impacts unavoidable. Residents in the immediate vicinity will effectively become sensitive receptors to an industrial activity that is fundamentally incompatible with the surrounding land use.

The proposal therefore represents a clear conflict with the expectations of residents who have invested in this area as a place to live, and it constitutes an unacceptable encroachment on established homes and properties.

In addition, the exhibition period provided for community review is insufficient given the scale, complexity, and potential impacts of the proposal. Residents have been given only a limited period to review extensive technical documentation and seek appropriate advice. This is not a reasonable timeframe for a project of this magnitude, and additional time should be provided to allow for proper community consideration and response.

For these reasons, I strongly object to the proposal and request that the Department reject the development application in its current form. At minimum, the proposed location should be reconsidered and alternative sites evaluated that are appropriately separated from residential areas.

The current proposal is untenable in its present form and should not proceed in this location.

I support the project

To whom it may concern,
We have received your letter dated 18th February 2026. That we retrieved from our letterbox on Tuesday 3rd March 2026 as all of our mail goes to our Post office box and not the house letterbox.
The letter was regarding the Notice of Exhibition- MidCoast Regional Organics Facility (SSD-84090218).
We have not been given sufficient time to prepare our objection submission. Only allowing until the 19th March 2026 which gives us 12 business days to respond is not long enough. Given the enormity of all the documentation provided on the portal to peruse and seek advice.
We seek an additional 30 days from the 19th March 2026 to complete our objection submission.

We strenuously object to the location of the development in the proposed area near my property. We are the closest resident in proximity to the development and are certainly a sensitive residential receptor. The odours, noise, 24 hour operation, truck noise 24 hours, health issues, and traffic congestion and danger caused (amongst other potential harmful impacts) will severely affect our property and present a significant loss of amenity and property value.

This proposal needs to be halted.

Regards
Raymond and Susan Hill

As a long standing Community representative in the MidCoast as a resident, as a business owner and as the President of the Forster Tuncurry Business Chamber. I am an advocate for open communication and collaboration between Government and Community, my submission both supports the positive but outlines the concerns for consideration in this Development.

I have only just received a letter in the post from the Department of Planning, Housing and Infrastructure about the MidCoast Regional Organics Facility (SSD-84090218) and I only have 4 working days to make a submission.
I am totally against this project for a number of reasons. My home is just meters away from the proposed composting site.
My property is referred to as R2. There are many more properties along The Lakes Way and Manns road that will be affected if this proposal was to go ahead. There will be a strong odour from rotting organics and lots of noise and dangerous trucking activities.
Not only will local residents be affected, but all local tourism to the Forster/Tuncurry holiday region will pass within just a few meters of this facility. Government planned housing nearby will be affected just when we have a housing crisis.
We already have a very dangerous part of The Lakes Way where there have been many accidents including a fatality. This will only get worse with many heavy trucks coming and going to the site. The smell and the noise will affect the lifestyle of all local residents and certainly lower property values.I hope we can extend the submission time as many local residents don't seem to have been given notice of this proposed development. I will add to my submission and upload more evidence as soon as possible.
Andrew Payne
31 Manns Road
Darawank NSW 2428
0419818439

This proposal will destroy the Tuncurry area, clog our already overcrowded Road especially Failford Rd which desperately needs a roundabout at The lakes way intersection, and will cause road damage beyond what our already over stretched council can barely manage. The proposal of a state organic waste facility will cause untold stench and ruin our fragile ecosystem, ruin the local golf course and local beaches plus its near our rivers which will destroy the local waterways. It is also near semi rural and residential realestate which will make the area un inhabitable. It insabsolutely a disastrous development and should never be approved to be developed let alone be proposed. It should be put somewhere remote and totally away from any tourist, rural residential or river/estuary system and away from any residence. It’s somthing that should be put at least 50-100km from any residence or tourist area. This is a destructive environmentally irresponsible development for our council area and should be proposed somewhere totally remote away from any rural or residential areas.

I strongly object to this projects location, the about of traffic that this would cause is unacceptable, the amount of stench to nearby residents is unnecessary, the location shows lack of foresight and council integrity to the community

I dont want a smelly compost plant as a neigbour. No to that....

Truly awful plan, woth devastating impacts to local tourism, housing development, road traffic, and smell. Please reconsider this proposal, and look at a location well away from a local tourist haven or expect significant upheaval.

I’m 27 Female and have liveed in Forster Tuncurry my whole life. I object against this completely the community is outraged and if it goes ahead the Mid Coast Council will lose the trust and respect of an entire region we don’t want this.

I believe this project will put extra strain on our roads that are already crumbling.

I am a solicitor with Stacks Law Firm, Forster and I lodge this submission in that capacity on behalf of our client. Please see the attached objection

19/3/2026
Submission At this stage i object to the project (due to lack of Consultation)
I being a resident in Tuncurry was made aware of this project from a friend last night 18th of March 2026, I immediately corresponded with my two-close friend about what I had found out and after trying to work out fact from fiction, decided to make the effort and seek the correct information direct from Council. I have now had that meeting with Council today 9am with the representatives of this project, as to why I, being a resident of The Lakes Way, Tuncurry, have not ever been notified of any stage of this development and I seek more time to explore, objectively to this issue.
No one in Council has provided me, as yet, even though I have asked at the meeting and was promised a response today, as to how many people were notified and the method of notification of this development.
It appears to me that this project has already been rubber stamped by the amount of work and expenditure already completed. Regardless of any submissions, this is substantiated by the fact that works have been going on over the past 4 years and has most certainly gone past the any submissions by the public with the idea of any relevant input or having changes to this project as it is presented to me today. My property is the second house south of the project and as a nearby resident should have been notified.
Not a whisper of anything or correspondence has come my way, from either the Council or the developer of any description. Not good enough and I seek an answer.

Sincerely, Phillip Lee, Retired