Mod 1 - Port Kembla Grain Handling Terminal

Restricting public comment to 14 days on a project with such a large social impact is outrageous.
(The security code thingy is not user-friendly either!)

Please see attached

I am a University of Wollongong student writing in objection of the proposed 24 hour road access and lifting of a tonnage cap (200,000) tonnes by road to the Port Kembla Grain Terminal (PKGT).

Two years ago the nearby Port Kembla Coal Terminal was granted permission to lift its tonnage carried by trucks (to and from the terminal). Many community members were upset about the increased truck numbers on the already congested roads and highways. The PKGT wants to add even more trucks on the local roads causing increased concern to the local Wollongong community whilst at the same time the Port Kembla Port Corporation at a public briefing that I attended on 28 June said it wanted to see more freight on rail (see also The Advertiser 29 June). The Illawarra has a railway network which at times is currently under utilised, and should be further upgraded.

The Picton and Appin roads are major archery from Wollongong to Campbelltown and outer west. These roads have a heavy death toll rate from road collisions. Being a university student I know many students whom regular use the road to travel from Campbelltown to the University of Wollongong. There is concern for not just university students but the general community whom will have to share the Picton and or Appin Roads with increased truck levels resulting from any approval of the PKGT application.

A recent Auspoll study found that 70% of Australians want truck movement restricted to non-peak periods and of those surveyed half want large trucks banned from cities (Clay, 2011). This practice of banning trucks from cities is done in Shanghai which only allows middle sized trucks to enter the main city on non peak hours. The study also found that 80% of Australians wants the Federal Government to be more involved in strategic funding and planning of public transport. One could ask is this PKGT application in the NSW community’s best interest?

In the last ten years oil prices have seen an increasing trend rise (from $25/bbl to around the current $95/bbl). Many countries are heavily investing in transport infrastructure to dampen the effects of volatile oil prices and reduce carbon emissions. Trains are three times as fuel efficient as motor trucks. If the PKGT application is accepted, this will not only increase emissions but decrease the grain freight train usage which will decrease the economy’s ability to adapt to changing oil prices and increase the economies dependency on imported fossil fuels.

In conclusion here is a summary of major points in this submission:

• The high level of trucks already on the Illawarra road network
• Concerns for public road safety
• Research shows Australians want more truck restrictions
• Freight by rail is a better option (oil prices and carbon emissions)

The writer hopes that the NSW Department of Planning takes note of the objections of the community and groups regarding this matter and does what is best for the citizens of NSW - including those living in Wollongong and in the wheatfields.

Reference Lucas, C 2011 July 6 “Locals make a noice over buck-passing on trucks” The Age, http://www.theage.com.au/victoria/locals-make-a-noise-over-buckpassing-on-trucks-20110705-1h0rd.html#ixzz1RPDG3SeM

Submission – to the NSW Department of Planning and Infrastructure Re Port Kembla Grain Handling Terminal DA 0844/672 MOD 1 July 2011

Weddin Shire Council is a council in the Central West of NSW centred on the town of Grenfell. The shire includes the village of Greenethorpe near its eastern boundary.

GrainCorp operates a 50,000 tonne grain silo at Greenethorpe which has traditionally been cleared by rail. In recent years however the haulage has been contracted to road hauliers who travel from Greenethorpe via Young and Yass to Port Kembla for export purposes. This increased heavy traffic has caused considerable road damage, especially when carried out in winter when the roadside is wet and the road formation weaker.

It is Council’s view that the removal of the annual tonnage limit at Port Kembla Grain Handling Terminal would result in all export grain from the shire being transported by road, despite current attempts by this Council and four others to have the rail line reopened.

The councils referred to above, being Blayney, Cowra, Young, Harden and Weddin, have joined forces to seek the reopening of the Blayney-Cowra-Demondrille rail line (including the Greenethorpe spur line) to facilitate rail freight of export grain and mining products to Port Kembla. The five councils support the detailed submission of Associated Professor Philip Laird of the University of Wollongong, which raises many of the matters relevant to the councils.

This submission is forwarded on behalf of the Councils of Blayney, Cowra, Young, Harden and Weddin, following appointment of the undersigned as the group spokesman.

I object the propsal as submittted.

The air quality study needs to be redone properly.

The road network needs to upgraded along the southern freeway by an extra lane in each direction.

The noise wall onn the eatsern side of the southern freeway where it is low needs to be increased in height by approximately 4 meters.

Objection to 24/7 trucks to grain terminal.

I object to the conclusion that an environmental risk assessment has been undertaken and the proposal is not expected to adversely impact the environment as the proposal will clearly give rise to significant adverse traffic, increased acoustic impact and air quality impacts.

The proposal's studies on air quality, acoustic assessment and traffic congestion as submitted are grossly inadequate and should be read more as a lame exercise in justifying the project by sweeping under the carpet the rising cumulative impact of truck transport to Port Kembla. All the reports conclusions state that the impact is only a couple of percent over the existing and is within the carrying capacity of the road system or will not lead to a significant increase in acoustic discomfort to local residential receivers and is therefore acceptable due to the wider economic benefit.

If this is approved in the economic interests of the region and the State the cumulative impact of diesel particulate emission on the local air quality, rising acoustic impact on residents near the freeway and the increased traffic congestion on Mt Ousley and the Southern Freeway will become the new base then the next project will come in pushing the cumulative impact higher by another small amount because the base keeps expanding.


Diesel Emissions Impact on Air Quality

I object to the report into diesel emissions contending that the impact is insignificant.
The following conclusion on the impact of diesel emissions on local air quality by Cardno is an absolute joke and they should be told to go back and do the studies properly.

“Cardno concluded that the potential additional emissions associated with the increase in delivery hours would be insignificant and would be undetectable by measurement of local air quality (for example on the basis of hourly average atmospheric concentrations). Further quantitative assessment was therefore not considered to be necessary by Cardno.
The increased number of road deliveries will increase vehicle emissions along the route of national, regional and local roads. It is noted however that the local roads have been developed and approved as roads to carry the heavy vehicle traffic associated with port operations and the additional impact of the vehicles travelling to the grain terminal will be negligible.
In the context of existing traffic flows and other significant contributors to background pollution concentrations in the port environment, the potential additional atmospheric emissions associated with the change in operating regime were considered by Cardno to be insignificant and a quantitative assessment was not deemed to be necessary.”

The issue isn’t with the change in delivery hours it is the increase in truck movements that follow from 24/7 operation. When you increase the heavy vehicle traffic there is an air quality impact and this cumulative impact on local air quality is growing with every expansion. This should be studied and mitigated not pushed aside on the basis that there are too many other contributors and the roads already exists and carries heavy vehicles.


Traffic Impact on Roads

The proposal will significantly increase traffic congestion along parts of the Southern Freeway especially so between the Princes Hwy and Masters Road for both North and South bound traffic and also Mount Ousley Road again in both direction. The traffic study concluded that LoS dropped indicating more delays and lower performance along both these sections of road. Given that if you cause an impact on one section of road the flow on affect spreads back along the road from the from that pinch point the impact is really far greater than reported in the study.

The Southern Freeway between the Princes Hwy and Masters Road southbound is already difficult to safely drive as there is traffic merging onto the road from the left while other drivers are jockeying for position to exit at Masters Road by adding more heavy vehicles into this you will only exacerbate the problem and potentially leading to accidents. The solution is costly but it requires another lane to accommodate the increased traffic get the proponents of the development to pay something towards their increased impact on the road network rather than waiting until it is at grid lock and the RTA claims they have no funding to upgrade the road.

Mt Ousley has a problem on the accent as the empty coal trucks, grain trucks and car carriers race up the first km of the hill. I drive this road to Campbelltown every weekday and repeatedly see the situation where there are 3 trucks abreast racing up the hill while a stream of light vehicle build up waiting for the cowboys to finish their games. Inevitably they run out of steam and have to fall back into the left lane. All trucks should be limited to the left lane only and restricted to 40km/h the same as the decent. This will help alleviate some of the congestion that has been forecast in the report. Wake up RTA!!!. The signage saying heavy vehicles to only use the two left lanes on the accent only adds to the traffic confusion limit all heavy vehicle to the far left lane and they can all climb the hill without the cowboy games which impact road safety for all users and greatly reduces the efficiency of the road as a whole.

Acoustic Impact


Section 3.2 road haulage route assessment and discussion is particularly thin and only amounts to statements of facts without a conclusion being drawn on the imapct because the conclusions if drawn from the data would be damaging too the proposal. The roar of heavy vehicles in very apparent at my property in Mangerton and will only increase for all residential receivers in proximity to the Southern freeway if 24/7 truck movements is allowed without addition increase in the height of low noise barriers in the loacality.

The statement in the report “Subjectively, the acoustic environment for residential receivers located adjacent to the haulage route (Loggers 1 and 2) is dominated by road traffic noise.” is accurate so the conclusion that by adding more heavy vehicle traffic at night is acceptable is a real joke.

The noise Logger at 33 Phillips Crescent is currently recording daytime 60 dBA and night 57 dBA. The amenity criteria for sleep arousal at night is just 45 dBA. This noise logger was mounted below the noise wall height if it was higher like all the other homes to the east the reading would even be greater.

Any further increase in heavy vehicle numbers and hours of operation should result in an extension of the noise attenuation wall on the eastern side of the Southern Freeway between the Princes Hwy and the Masters Road exit. There is a section of approximately 300m where due to the topography and the noise wall being very low and the truck exhausts extend higher. The wall in this area needs to increased in height to be effective. The conclusion in the acoustic section of the report that all reasonable and feasible noise mitigation measures have been installed is absolute rubbish the wall is too low to be effective and should be increase in height. Get the developers to pay for this as the RTA will claim they have no money for it and will put it on a works program for 2020.

Furthermore a maximum noise level for residential receivers should be set rather than this cumulative creep in noise we keep experiencing as each new noise source only increase the background by a small amount and is therefore considered acceptable.

Dear Karen,
Re Port Kembla Grain Handling Terminal DA 0844/672 MOD 1


I am writing in relation to the above DA, and to object to the proposed lifting of the curfew on grain truck movements to the terminal and to removing the current limit of 200,000 tonnes per year on road haulage of grain to the Port Kembla Grain Terminal.


I believe that lifting the curfew and removing any limit on the amount of grain sent by road to the Port Kembla Grain Terminal would result in the following negative impacts that are not adequately considered or addressed in the DA:


Substantial increased noise for those in the vicinity of the roads used by the haulage trucks, for example Mount Ousley Road and Picton Road.

Curfews are used for good reason - they protect residents from disrupted sleep and poor quality of life resulting from the noise of large trucks. Noise levels have been increasing over recent years with the growing number of coal trucks and car transport vehicles, and are already at very high levels.
The use of compression braking is permitted in NSW and is already very loud at times in many areas near Mount Ousley Road. Use of compression braking at night is even more disruptive than during the day.
No approval for more truck movements, or for removing the existing curfew, should be given until it can be demonstrated that the current regime is effective in reducing noise levels from trucks. I am not aware of any evidence that it has been effective to date.
Increased congestion, number of road crashes, breakdowns and near misses on these already very busy roads.

Mount Ousley Road and Picton Road already support an enormous number of heavy vehicle movements as well as ever-increasing commuter movements to and from Sydney. There are accidents regularly on these roads, including fatalities.
The increasing number of truck breakdowns (two just today, 20 September 2011) cause inconvenience and delay, as well as independently increasing noise levels as other trucks brake to avoid the breakdown zone.
Substantial increases in greenhouse gas (GHG) emissions and air pollution.

The DA would increase GHG emissions and air pollution substantially relative to alternative transport modes such as rail.
Estimates are that road transport of grain would produce up to three times as much air pollution as transport by rail.
Given the existence of clean energy targets at state and federal levels, and the urgent challenge of addressing climate change, the NSW Government should be taking an approach that encourages and actively incentivises businesses to use rail wherever possible, including by factoring the (relatively higher) external costs of road haulage into fees and charges.

The DA does not consider or provide an estimate of these external costs, which are likely to be substantial and will be borne by the residents of the affected parts of Wollongong and the community more broadly (in relation to GHG emissions), rather than by the applicant.


I believe that both the proposed lifting of the curfew and of the 200,000 tonnes per annum cap on road haulage of grain to the Port Kembla Grain Terminal should be rejected by the Planning Commission for the above reasons.


I apologise for not submitting comments during the consultation period for the DA. The consultation period was only two weeks, and I unfortunately missed seeing it. I believe many of those potentially affected by the DA may, like me, not have been aware of the consultation process or the opportunity to provide input about this major proposed change to the use of roads in the Wollongong area.


Yours sincerely,


Emma Rooksby

155 Cabbage Tree Lane

Mount Pleasant

NSW 2519