Shoalhaven Starches MOD 25 Rail Line and Dryer Baghouse

Thank you for the opportunity to comment on Shoalhaven Starches MOD 25 Rail Line and Dryer Baghouse

Bomaderry Community Inc. is a volunteer association working to drive positive systemic change in Bomaderry. As regards MOD 25 we submit:

1. The exhibition description of proposed modification states extension of rail line by 1245 metres (m) with a 180 m rail maintenance spur however, Site Plans MN7464-002 and 007 and the modification report indicate an extension of 1065m with maintenance spur of 100m? An extra 80m would cross Bolong Road requiring a second level crossing, and subsequent DA. Can you please confirm the final finished length?

2. MN7464 – 003 notes 25m lights ‘spaced not less than 20m’ with a minimum setback of just 5m in one area. The Shoalhaven River Bank Stability Assessment questions riverbank stability in this area and recommends of clear area 11.5 m to contend with likely riverbank failure. If this was the case back in 2017 what has changed to reduce the risk today?

3. While Manildra has requested exemption from maximum height restrictions in its Statement of Environmental Effects and Planning Report, we are not sure why the proposed lighting towers are 25m high when Manildra’s incoming rolling stock of GT46C ACe locomotives are under 5m?

4. NSW Planning acknowledges the damage caused by light pollution so will appreciate that Manildra’s contribution to night glow in Bomaderry is significant. Bomaderry is home to both the Green & Gold Bell Frog, and Grey Headed Flying Fox; both of which are endangered species and both are night feeders. Yet there are no design strategies to control the risk of light pollution to nocturnal ecological communities?

5. We reject that ‘the proposed development will have a limited visual impact’ or that it meets the ‘desired future character of the locality’. Manildra’s factory is visible for the length of Bomaderry’s main street, from the Nowra riverbank, and to motorists travelling along Bolong Road. With its imposing presence the operation reduces visual amenity, and presents an ugly facade to visitors - impacting local pride in the town. This does not reflect the future character residents desire for Bomaderry.

So agree that ‘the development standard has been virtually abandoned or destroyed by the council’s own actions in granting consents departing from the standard’ but feel there are still some issues for Manildra to address as part of this Modification Application.

Unlike the recently approved Port Kembla Project, we have not been able to locate a Social Impact Assessment for the Bomaderry Works, but would say that the impact of Manildra's operation in Bomaderry has many direct, indirect and ongoing impacts on the social fabric of our town. Looking forward we encourage Manildra to build stronger, on-ground relationships within Bomaderry that will contribute to the future sustainability of our small town.

I totally am against the extension of existing rail line by 1280 m including a 850 m train reverse loop and 180 m rail maintenance spur on the east side of the old Shoalhaven paper mill by Shoalhaven Starches. Since moving here in 2010 I am only aware of one noise test being conducted for a fortnight in 2012 by an independent tester and the result was the factory was too loud especially at night. I have been effected by the vibration of the trains and the movement of shipping containers since mid 2023, including being woken throughout the night and kept awake even on public holidays ( eg: 11pm 26 December to 11am 27 December 2023). I can hear diesel trucks and their gear changes entering and exiting the old paper mills at night off Bolong Rd now ~11.30pm despite the front door being shut and I'm sick of having to close the front door and windows due to the noise from the factory, the gas release from Sugagas whose two white towers with green logo name suddenly appeared and of course couldn't be low lying like the original gas plant 500m away, the onslaught of vehicles speeding past due to end of shifts or avoiding the Manildra train closing Bolong Rd as well as the noise from the water recovery plant (farm) or as I know it the coal storage farm opposite. I've been woken by trucks coming off Bolong Rd and entering the farm with numerous rumbling at 12.30am and then am kept awake while the back flap slams and a digger constantly beeps away while the truck is loaded with coal until it leaves at 1am. Then I have the pleasure of hearing the train vibration and shipping containers being 'slammed' between 3am and 6am, if lucky I can also hear beeping and train horns blasting before finally falling asleep again but as the truck arrives back at the farm before 7am sleep is very shortlived. I can tell you I hate October to the end of March as that is when the factory is at its worst but living here has been a nightmare since October 2021. Shoalhaven Starches are the worse polluters I know and in every respect from the litter that comes out of the workers cars/utes/trucks including coal to visual polluters (what an eyesore), light polluters (can be seen from the highway at Berry & Worrigee), odor polluters (the factory stench can be now smelt at Bomaderry Woolworths and on a daily basis) and noise polluters ~ you name it and Manildra will made a noise, from constant beeping to electricity hum, metal banging, train vibration and carriage slamming, shipping containers, metal on metal, sirens and of course explosions. There is no 'low impact' on local residents, it is constant and ongoing and getting worse. The concern is now with all this concrete filling the floodplain when and how high will the next flood be? Shoalhaven Starches just waste my taxes ~ Federal, State and local, obviously there is no such thing as climate change or it didn't matter that there was a sink hole with a crane on top or that the site of the new packing plant, railway siding and northern car park extension was flooded in 2012, 2015, 2020 and 2022! It is a joke, you can't complain because EPA only control the noise within the factory or farm, NSW Govt the roads and the Council have very little say over anything. The white shirt inspections are useless ~come back a few hours later and you will see and hear the factory in full flight. They are well known to being quiet and looking good while any white shirts are on site eg Thursday 14 March I was wondering why the factory, train etc was so quiet as Wednesday it was loud, well I saw white shirts at 12.30pm and by 6pm the noise, smell and clouds were back, also probably the tankers sitting on the shoulder of Bolong Road blocking the 'No Stopping' signs.