Moorebank Intermodal Precinct East - Stage 1

Re; Objection to the Proposal for the SIMTA Concept Plan: Ref. No. SDD 6766
Attention; Andrew Beattie, Dept. of Planning and the Environment, NSW.

Thank you for the opportunity to comment on this proposal. The Georges River Environmental Alliance, represents individuals and groups with a concern for the environmental quality, biodiversity and related human health and amenity of the Georges River catchment. We object to the huge scale proposal to locate a transport intermodal virtually on the banks of the Georges River at Moorebank and adjacent to the heavily populated residential area of Wattle Grove_Moorebank.

The adjacent reach of the Georges River, impounded behind Liverpool Weir is arguably on of the most ecologically at risk reaches of the river. It is a freshwater and sluggish reach of variable flows, mostly low, within which any pollutants will be held, as a result of poor dilution and flushing capacities. An adjacent vast area of hard stand, with a huge volume of diesel dependent truck movements, represents an unacceptable level of risk from greasy runoff and chemical spills to the water quality of the Georges River.

A recent toxic spill did indicate 2 things; how this reach is the habitat for significant numbers of freshwater native fish, and how vulnerable it is to any spill of toxic stormwater. http://www.smh.com.au/environment/water-issues/mystery-chemical-triggers-massive-fish-kill-in-georges-river-20150218-13ihxu.html
Any developments approved around this river reach, should demonstrably achieve best practice for water sensitive urban design, to meet the goal of a net improvement in water quality and river habitat standards. Furthermore, a platypus population is known to exist in this river, with a recent sighting nearby at Simmos Beach, Glenfield. http://www.macarthuradvertiser.com.au/story/242876/warnings-erected-to-help-protect-platypus/
This site, just downstream is thus either existing or potential platypus habitat, and thus needs to be protected so that appropriate objectives in terms of water quality, environmental volumes of flow and riverbank condition should be consistent with platypus needs.

This proposed development is inconsistent with the agreed community-council vision for this urban river. It is ridiculous to industrialize these riverbanks, in a way that will destroy visual and environmental amenity, and result in the decimation of endangered ecological Cumberland Plain vegetation communities. No off-sets elsewhere would be appropriate as the river and its vegetation communities so close to the Liverpool CBD, is a place based community asset, that is needed to provide present and future opportunities for only environmentally sensitive recreational and residential re-development. This development also threatens the cultural and heritage values represented by the nearby Casula Powerhouse and the Historic Glenfield Farm.

Finally it is unacceptable that the existing residential community, with no prior warning, should have the unavoidable health and lifestyle risks associated with the huge and predicted increases in traffic, diesel emissions, noise and a 24 hour operation, dumped upon them.

Better long term solutions for the integrated logistics of road, rail and air transport exist at the alternative site of Badgery's Creek. The Moorebank site, is not appropriate for the scale of this development. Integrated port facilities cannot be accommodated here, so Port operations will always be needed off-site.

Sharyn Cullis
Secretary, Georges River Environmental Alliance. m. XXXX XXXX
Facebook; Georgesriver Enviroalliance

I understand that negative externalities arising from the Moorebank Intermodal may make the Casula Powerhouse Arts Centre 'unviable'.

The following are comments I have made on Facebook at:

https://www.facebook.com/liverpoolleader/photos/a.437393130987.234888.286302235987/10152821730765988/?type=1&theater

I am also attaching it in PDF.

I CANNOT imagine the community without the Casula Powerhouse Arts Centre. This is one of the most engaging treasures we have in the South West. I don't live in the Liverpool LGA but, as I have said repeatedly, it is a next door neighbour.

IT MUST BE NOTED that not only the Liverpool Community may be affected. There are huge numbers of people, individuals, families, schools, organizations and groups from outside Liverpool who also attend and get immense pleasure and use from this remarkable and unique place.

I HAVE VISITED the centre often to enjoy the delights of its high quality exhibitions and functions. I have also been to meetings held by Georges River Combined Councils' Committee, Hawkesbury-Nepean CMA and to meetings of the Botany Bay and Catchment Alliance, the last one being only last month. I have also been with walking groups that have visited. I am aware that bike groups have too.

THE MAYOR OF LIVERPOOL, the people of Liverpool and others have fought the good fight against the placement of the intermodal and I attended one of the rallies that have been held. I would have been to more but I can only be at one place at a time.

MY FACEBOOK PAGE HAS numerous albums about this fabulous place situated on the Georges River. Here is a sample:

https://www.facebook.com/media/set/...

https://www.facebook.com/media/set/...

https://www.facebook.com/media/set/...

I have just uploaded a video of a Disability Day to YouTube. It shows in my view another of the treasures associated with the centre, that is, as a pleasant and comfortable venue for many events. It is at:

https://www.youtube.com/watch?v=toc4J7LElsw

Look at it, listen to it and savour it. The loss of what the centre gives to us will be sword to our very soul.

It is for the above reasons, together with the proximity to the Georges River that I consider the intermodal would best be placed elsewhere such as proximate to the proposed Sydney second airport.

See attached PDF submission

Please see attached.

I strongly object to this proposal for the reasons given in my attachment. I am concerned about health, traffic, pollution, noise, environmental issues

20 June 2015
XXXX XXXX
Wattle Grove
Application Number: SSD 14-6766

Please find below my submission on the SIMTA Moorebank Intermodal Terminal.
I would like to firstly state that now that the SIMTA and MICL intermodals have been approved to become one project, I believe that the EIS process should start from the beginning again as this is a totally different, much larger proposal we are now talking about. The original proposal spoke of 2,600 truck movements to your site daily and now that has blown out to 10,000. Of course this will mean a monumental increase in air pollution, traffic, noise, vibration, etc and will impact the people, flora, fauna as well as the river - so much worse than the original proposal. It is immoral to totally change the ballgame part way through and just expect the public to accept the ramifications.
It seems that SIMTA and MICL, as well as the government, have not listened to the residents at all. So much for the community consultation sessions held by both parties! None of our concerns have been answered. All we hear constantly is talk of mitigation but nobody can tell us how our concerns re health, traffic, etc will be mitigated. I am firmly of the belief that none of our concerns will be mitigated as there seems to be no way of doing so. I believe that the community consultation has just been a matter of ticking boxes that you've held these sessions as there has been no evidence you have listened to us and taken any action in relation to our many concerns.
It seems that the only reason the intermodal will be built at Moorebank is it's proximity to the M5, M7 and the current freight line. This seems to override the fact that there are 39,000 people living in close proximity that will be impacted on severely by this intermodal. This is not a good enough reason, in fact there is no good enough reason to put the lives of people at risk and that is what you are doing. There have been several excellent suggestions for better locations such as Eastern Creek, Badgerys Creek and even Newcastle. These areas have much lower housing density and so not nearly as many people will be impacted. Eastern Creek, in particular, is a good area since it has been proven that 45% of the containers are destined for Western Sydney, not South Western Sydney (where Moorebank is). There is significantly less industry at Moorebank so it just doesn't make sense to put an intermodal here. I've recently heard that a new freight line will need to be built in any case so the freight line can be built to Eastern Creek. This will make much more sense than sending containers by rail to Moorebank to be unloaded, only to the have the last (and largest part of the journey) to be made by truck anyway to its end destination - double handling much? This is NOT taking trucks of Sydney's roads is it? Also since Chullora's site has now increased its capacity from 300,000 to 600,000 there is certainly no rush to build an intermodal as soon as possible.
It has also been shown by local traffic modelers that at least 32 intersections would need to be upgraded for the intermodal to work at the area is already at capacity in regards to traffic. You are only suggesting upgrading Moorebank Avenue up until it reaches the M5 motorway and not even this will happen until 2029/30. Your trucks will be going NOWHERE and neither will any of the residents. In a speech on the intermodal proposal made by Melanie Gibbons in the Legislative Assembly on 4 June, Melanie made the following statement, "I have read through the information provided by the company for the next period of community consultation. It says that, should there be an accident on the M5 or Moorebank Avenue, the facility will need to close while the accident is being cleared". This is not an efficient way to run a business and just highlights one of the reasons that an intermodal cannot work at Moorebank.
There is also a major problem with noise. There are residents at 3km away from the Port Botany terminal that are having major sleep deprivation issues so how can residents as close as 400 metres to the proposed Moorebank site supposed to get any sleep? There is also the issue with the poor people who live near the freight line at Casula who are already experiencing sleep deprivation problems and now you want to increase the number of trains that go past them every day and every night. This is just inhuman!
Air quality is a huge issue and one that I am particularly concerned about. We know that Moorebank is in the Sydney basin and, therefore, pollution is already higher. The PAC SIMTA determination showed that PM2.5 levels in the area are already close or above the advisory criteria. A project of this size can only increase the pollution substantially particularly of the PM2.5 and PM10 cancer causing particulates with the increase of 10,000 trucks per day as well as old diesel trains not to mention the extra cars on the road for the employees. The World Health Organisation likens PM2.5 and PM10 to asbestos. Should the residents and workers of Moorebank and surrounding areas be exposed to this? I think not.
Lastly, I would like to discuss creation of jobs. There have been television programs as well as newspaper articles in the last two weeks showing the further automation of Port Botany and the efficiency this brings about as many jobs have become redundant. We know that a brand new intermodal will be fully automated so there will be very few jobs created for the amount of land used. This land would be much better used as a technology park where many more jobs would be created for the same amount of land.
In summary there are no positive aspects of building an intermodal at Moorebank and I believe if this does go ahead it will be proven in a short time to be financially unviable as well as impossible to operate due to the congestion of the road system in this area.
Yours faithfully,
XXXX XXXX
Wattle Grove resident

I wish to object to the SIMTA Moorebank Intermodal development for the reasons detailed in the attached response.

See attached

See Attachment

As a resident of Wattle Grove I have read through the SIMTA Intermodal Terminal Facility - Stage 1: Environmental Impact Statement date May 2015 and the proposal still fails to provide any solution to mitigate increases in traffic noise to local residents living in Wattle Grove.

Details of my submission can be found in the attached PDF, SD 6766 Submission.pdf.

SIMTA's traffic modelling shows that the capacity of the local road network is 94,941 ''passenger car unit'' (PCU) trips per day and that this capacity was exceeded in 2010. In 2030, estimated traffic demand on the local road network will exceed capacity by 53 per cent, comprising future background traffic growth of 19,625 PCU and intermodal traffic of 30,204 PCU.

How will a ''planning process'' address a 53% deficit in local road network capacity?

I object to the proposed freight intermodal(s) at Moorebank/Wattle Grove.

The proponents and governments should have more respect for the health of local residents with 39,000 living in a 2km radius and 100,000 in a ten kilometre radius not counting the many hundreds of thousands who live in the area from Port Botany to Liverpool and the general area the Locomotives operate to.

Our Children's Health will be Damaged by the Pollution and Pedestrian Accidents - with 10 Schools and 19 Childcare Centres within a 2,000m radius of the proposed development. You will Kill many.

Please see attachment regarding how Diesel pollution Kills and Damages.


I writing to object to the proposed freight intermodal(s) at Moorebank/Moorebank.

There are Huge problems with the proposed Intermodal at Moorebank including Environmental, Social, Engineering and Economical which need to be addressed. Moorebank is unsuitable because there are too many Government Sponsored projects all in the one place such as Sydney South West Freight Line, Widening of Moorebank Ave, Spur Line Construction from SSFL, Major Ramp Construction to M5 off Moorebank Ave, Noise barriers and MORE. Any assessment should be of ALL the Imminent Projects to judge the TOTAL Damage to South West Sydney!

Most importantly, Liverpool is a deep basin so Diesel Fumes do not easily leave the Residents HOMES that surround the proposed 2 Intermodals! Compensation costs for Diesel Pollution will be Huge! Experience from other Inland Intermodals in America prove Increased Asthma, Cancer and ultimately Shorted Life Spans from Diesel Fumes.

The Federal Ministry of Infrastructure and Transport are doing the wrong thing by stating that the Moorebank proposal will remove Trucks off the roads in the Eastern Suburbs around Port Botany when it's just to suit the politics of that area. It will just move the problem to a worse situated are.

Liverpool Council is against the proposed 2 Moorebank Intermodals and wants it instead placed on the Government owned land at Badgeries Creek (in another part of Liverpool). Penrith City Council also wants it moved to Badgeries Creek.

Widespread opposition has been demonstrated by the fact that Residents of Liverpool have DEMONSTRATED against the Moorebank proposal.

Yours Sincerely,

Dominic Scutella
118 Daintree Drive
Wattle Grove
NSW 2173
Phone 0408 9731 97


We are against the SIMTA proposal for an Intermodal at Moorebank for many reasons:

* The EIS should be completed on the total number of projects proposed for the area, i.e. Federal Government Intermodal on the Australian Army Engineers site, SIMTA proposed intermodal as well as the SSFL since the effects will be felt of the total projects that are proposed not just the SIMTA proposal. Anything less does not give an accurate picture of the outcome.

I could not find any information that referred to the cumulative effects on air quality, noise and traffic that would occur from both the SIMTA proposal and the widely known about Moorebank Project Office proposal operating simultaneously. This renders any information on SIMTA's EIS inappropriate, inaccurate and does not tell the true story. This is misleading and unfair to the people of Liverpool and to anyone that uses this area whether to travel through it , provide serices or use services provided by the area.


ROADS AND TRAFFIC

-Impacts to Traffic should be considered including the exiting and entry of trucks to and from the site and the deadly impact this will have as these trucks attempt to merge onto the M5 with traffic travelling at 100kph. Trucks merging from Moorebank Ave onto the M5 travelling towards the M7 will inevitably cause accidents as those already on the M5 travelling in the same direction swerve to avoid them or simply crash into the back of them. Also as cars travelling in that same direction on the M5 try to merge into the far left lanes in order to get onto the Hume Hwy whilst trucks from the SIMTA intermodal are merging from Moorebank Ave onto the M5 travelling towards the M7, accidents are inevitable. For these scenarios to be mitigated would possibly mean lowering the speed limit on the M5 for that area or building complexed and expensive underpasses, overpasses or tunnels. Not enough information has been provided in SIMTA's EIS regarding mitigating or providing solutions to such matters. Any information provided is vague and does not display who would be responsible implementing for such action.

In Appendix N, SIMTA say " M5 Motorway/Moorebank Avenue interchange. The analysis has suggested the need for additional capacity improvements in the form of widening at the following ramp locations including:
 M5 westbound off ramp;
 M5 westbound on ramp;
 M5 eastbound off ramp. "


My comment to this remark by SIMTA is............
This action is insufficient to prevent accidents such as those I have mentioned above from occurring. SIMTA boast about all the widening and work they recommend will need doing on Moorebank Ave but have not addressed the crucial aspect of the traffic accidents on the M5.

- "SIMTA supports all measures to stop trucks driving through local
streets on the way to and from the intermodal terminal."


My question is to this remark by SIMTA is............

What will it do to implement procedures to prevent trucks from using local streets? How will it follow through, monitor and carry out these these procedures? What are the so called local streets specifically? Please name them specifically?

- there will be a huge impact to the residents living close by as well as a significant impact to all people living within a 10km radius of this site. The location is within very close proximity to houses. How would anyone expect our lives to be with all the air pollution that would be generated, the noise and the light 24/7. Not discussing the rail impact, our streets are already very congested and as it stands now it is almost impossible to go on the local roads during peak hours let it be with 2000 trucks more. The M5 is already over full capacity during these peak hours and roads in the surrounding areas of the proposed Intermodal would become gridlocked.

- I am glad that 3300 trucks are taken off the road from Botany to
Moorebank Avenue. But how wrong is it to put 3300 trucks back on the
road from Moorebank Avenue in an existing pollution basin. The truth behind this simple fact has been hidden by SIMTA as well as the Moorebank Project Office from the beginning of these proposals.
With up to one million trucks expected to enter and depart Moorebank Ave to and from the SIMTA terminal annually, many of them using the M5....How is this NOT due to the SIMTA freight terminal???
How can they say that this number of trucks they intend to bring to the Liverpool area will not increase truck movements on the M5? It may be on a different section of the M5 ie between Moorebank Ave and the M7 junction but the same number of trucks and more will still be using the M5 due to the fact that goods must be delivered from Moorebank to the warehouses in the west and south west of Sydney.
I feel the Liverpool community are being fed lies by SIMTA to avoid conflict with residents on their proposal.

SIMTA have said "Moorebank Avenue will be assessed to investigate if it would support increased truck traffic to and from the intermodal terminal.
Appropriate upgrades would be implemented as required.''

My question is to this remark by SIMTA is............

When will it be considered appropriate to upgrade the road? At what point? When is the right time and when is it too late? How will this progress or regress be measured?


-"Together with the Moorebank Avenue widening, roads
approaching the traffic lights at Moorebank Avenue/Anzac Road
may also need to be widened.''

My question is to this remark by SIMTA is............

Is this to accomodate trucks turning on and off Anzac Ave? I thought the trucks will not use Anzac Ave according to previous satatements by SIMTA. Are these more lies?


AIR QUALITY AND PEOPLE'S HEALTH
Air Quality is really important. Australia has one of the worlds highest incidents of Asthma. Residents suffer from many other lung complaints as well. Any degradation in air quality will make these conditions worse. Every truck that they take off the road at Port Botany will have to start at Moorebank, queuing with its engine running, pushing pollution into the air.

Air Pollution has really serious health effects. Studies show the following:
* Air Pollution from busy roads shortens life expectancy
* Asthma symptoms (and childhood hospitalisations) caused by truck exhaust
* Babies are more likely to be premature or have low birth weight if mum lives near high traffic areas
* Respiratory symptoms in two year olds linked to Traffic
* Asthma more common in children who live near freeways
* Children (and people generally) who live near busy roads are more likely to develop cancer
* Air Pollution causes more traffic related deaths than accidents
This link has an index of relevant studies from the San Diego Earth Times.

Another study http://www.ehjournal.net/content/6/1/23 talks about the Cardiac and Pulmonary effects of living in close proximity to pollution.

Specific questions to be addressed in the terms of reference should include;
a) what increases in PM10 and PM2.5 will occur at different locations in the local environment, arising from all sources related to the proposed Moorebank
Intermodal Terminal Facility
b) what increases in PM10 and PM2.5 will occur at different locations in the local environment, arising from the combined effects the proposed Moorebank
Intermodal Terminal Facility and the Department of Finance Intermodal
terminal project.
c) Will the increases in PM10 and PM2.5 arising from the Intermodal developments push the levels of PM10 and PM2.5 (in any location) above the guidelines set by the World Health Organization.
d) What, if any health effects are likely to occur in the local population resulting from increases in PM10 and PM2.5 levels associated with the Intermodals.
e) What are the economic costs (loss of productivity, cost of health care, etc) of any adverse health effects.
f) If the proposed Intermodal facility was to be located in another area of Sydney,what PM10 and PM2.5 levels would result in these other local areas.


- The proponents of the massive terminal complex at Moorebank say that residents won't be impacted by noise, but residents are not convinced.

Overseas, authorities acknowledge the noise impacts on local residents. The Port of Houston Authority in Texas has offered $US40,000 "mitigation payment" per house for houses as far as 920m (Baywood Ave Shoreacres) from the Bayport Container Terminal so home owners can install soundproofing.

You can read all about it here.
http://www.bayportmitigationsolution.com/

- In 1997 the Holsworthy Airport proposal was scrapped, one of the reasons being that the air pollution would adversely affect the region. 15 years later that population is now substantially bigger and more people would be affected by a much bigger proposal. The location is the wrong place for such an operation


- Since pollution in the area is already high compared to a lot of areas in Sydney any increase in pollution must be considered to be dangerous and must be monitored in full and in all conditions. Any adverse findings must be reported and remediated including fines and/or criminal penalties where applicable.

- There has been a mountain of research from all over the world that diesel emissions cause great problems to residents even short term exposure.It effects the brain lungs diabetes child birth weight hearts as diesel contains 40 toxic chemicals. And still it appears the ones deciding on these freight terminals are choosing to ignore the facts and the resident's concerns. It is unbelievable that governments and companies can be so short sited when planning such infrastructure in residential areas. Or is it simply neglect?

- The SIMTA construction has been noted as extending over a period of 12 years and some of the equipment used will bring noise levels of 122 dbs /. Also it is noted that they say that freight trains will bring sound levels of 41-45 decibels along Casula Liverpool when residents have been complaining about excessive noise levels up to 97 decibel. Also I have noted that the receptor pollution points are in areas that doesn't represent the levels of pollution in heavy industrialised areas. It has been recorded in the Local area pollution rate of 20.22 which is over the world health organisation (WHO) maximum of 20. It can only get worse with the growth of freight numbers.



OTHER ISSUES

-"Operations at the intermodal terminal would schedule truck arrival
times to minimise queuing.''

My question is to this remark by SIMTA is............

And what about when there is a hold up between Port Botany and Moorebank via the M5 which occurs frequently or at Port Botany itself? Schedule times will mean nothing. This may unfortunately for the Wattle Grove residents produce poisonous diesel emissions in their living spaces as the trucks are forced to queue on nearby roads. Many will leave their engines on to use their airconditioning in their cabin as they wait.




- The threat of terrorist attack on the Intermodal site including freight and infrastructure. With only 3% of containers currently being checked for illicit and illegal goods how can we be certain that terrorists will not attempt to attack and cripple Sydney's Freight flow, particularly as it seems that the Government is concentrating all of the freight flow into 1 or 2 narrow freight corridors.


- The potential for an accident with unknown container contents spillage or leaking into the George's River, local watertables, soil or air is of concern


- The potential for an explosion resulting from an accident or careless handling of containers resulting in damage to resident's homes and other surrounding infrastructure.



-Most of the 13,000 families within 2km of the container terminal are paying off a mortgage and they are worried about the effect of having a huge container terminal appear next to their house.
Houses next to terminals drop in value, a lot. Local residents don't deserve a slug like that.
What compensation will be on offer for residents within the 2km zone from the Intermodal?




- Why is the Crime and statistics of the suburb of Moorebank studied so heavily when in fact the planned intermodal lies closer to the residential areas of Wattle Grove and Casula than it does to the predominant residential area of Moorebank? It seems Wattle Grove and Casula have not been considered in the planning and the social and health requirements of these suburbs will not be considered by SIMTA.
I realise this is not part of the DGR but it just shows SIMTA's attitude and disregard towards the local residents.


- Nowhere in the planning for Moorebank complex has there been any mention of compensating residents so they can insulate themselves against noise or top up their mortgage so the drop in property value doesn't leave them with negative equity.


- I have to remind the planners of these Intermodals both Federal and Private that flooding of the Georges River is of great concern.
There have been numerous times flooding has occurred along Newbridge Rd near Flower Power and heavy rain in a short period can cause flooding along Newbridge Rd which has the Georges River at 2 points near the area.
With heavy rain recently part of the area has been flooded and to believe you could operate a freight hub with such uncertainty beggars belief and if the flooding occurred it would cause great damage and inconvenience to the SSFL freightline and the transport of diesel trucks along Newbridge Rd , Moorebank Ave and other heavily patronised roads.

Can you please listen to these concerns and reply with a personal response?

Our community would appreciate the chance for your group to meet with us to discuss these and other concerns.

Kind Regards,

Dominic Scutella
Phone 0408 9731 97
118 Daintree Drive
Wattle Grove
NSW 2173


The Environmental Impact Statement prepared by the Moorebank Intermodal Company (MIC) states that the proposed Moorebank intermodal will allow imports and exports to grow through Port Botany. This will mean additional traffic on the already congested road network. 10,000 heavy vehicles per day will need to access and leave the terminal utilising the M5 and local roads.
The MIC state that an additional intermodal is required to reduce supply chain costs; however, it is questioned how the proposal at Moorebank will assist in reducing these costs. The proposed terminal in Moorebank will include transferring freight by rail less than 25 Kilometres from Port Botany, while increasing the handling costs of the supply chain with containers having to be loaded and unloaded multiple times in a very short distance. Infrastructure NSW has also questioned the viability of short haul freight and the funding of additional intermodal facilities until this has been properly investigated. That being the case, the increase in capacity at Chullora should be investigated with proper planning for a true intermodal at Badgerys Creek. Jenny Wiggins, in her Sydney Morning Herald article, states that Asciano is primed to invest $112 million to `compete "vigorously" with its own intermodal terminals', for example Chullora, and challenge the Moorebank intermodal essentially casting doubts over the economic viability of the Moorebank site (Wiggins, J., 2014, `Asciano challenges Moorebank freight hub', Sydney Morning Herald, 2 July 2014).
To truly reduce supply chain costs, the intermodal location should be moved to Badgerys Creek, a facility more than 40 Kilometres from the Port with access to key roads such as the M7 and the proposed M9. This location will also have the capacity to support future growth centres. The M9 motorway will provide `a direct link between the Central Coast and the Illawarra, connecting the growth centres of Camden, Penrith and Windsor' (O'Rourke, J., 2014, `What Sydney needs to transport us to the future', Daily Telegraph, 3 November 2014). An intermodal at Badgerys Creek demonstrates good strategic and growth planning.
Why Badgerys Creek is a better location than Moorebank
The MIC, in their Environmental Impact Statement, attempt to describe why Moorebank has been selected as a location. However, Badgerys Creek is better suited to meet the criteria that the MIC has listed.
Badgerys Creek is an ideal location for an intermodal terminal to handle both interstate and import-export freight. This is because it is:
* long enough for interstate freight trains without the need for trains to be broken up and shunted, creating unnecessary additional noise in the area;
* big enough to handle the number of container movements required - up to 1.1 million twenty foot Equivalent Units (TEUs) per year of import-export freight and another 500,000 TEUs per year of interstate freight. This is a greater capacity than the proposed Moorebank site;
* strategically located in an area where a new rail line is planned for the airport;
* near the M7 Motorway, a link to the West and North West where it has been identified by Deloitte that most of the container freight will be headed, and accessible to the M5;
* near the proposed M9 Motorway, providing the ability of the intermodal to service future growth centres;
* near the Western Sydney Employment Area (WSEA), future industrial areas and future freight markets in Western Sydney, where two-thirds of container freight received at Port Botany will be transported.
* further from Port Botany than the Moorebank site, making rail a viable alternative to trucks, and reducing supply chain costs;
* in development, meaning that truck access can be configured into the $3.5 billion already allocated to the surrounding road infrastructure network rather than upgrading roads that are already at capacity in the Moorebank precinct; and
* owned by the Australian Government and available for use consistent with the airport.
Problems with the Moorebank proposal
The Moorebank site constrained by a number of issues:
* The area is already suffering from significant traffic congestion, the addition of an estimated 10,000 truck movements and approximately 5,000 passenger car movements per day will exacerbate this congestion.
* The Planning and Assessment Commission (PAC), following their community meeting on the SIMTA proposal, has identified that the Moorebank area is already suffering from significant traffic congestion. `The community has strongly argued that the proposal is only going to move the congestion from Port Botany to the Liverpool/Campbelltown region. The Commission understands the Moorebank site is constrained by the surrounding residential and industrial land uses and the already heavily congested local and regional road network. If the concept plan were to be approved with the levels of throughput proposed by both SIMTA and MIC, then clearly the community's case is strengthened.' (2014, Planning and Assessment Commission, SIMTA assessment).
* The SIMTA Concept plan was approved by the PAC on the basis that they are limited to 250,000 TEU's, plus an additional 250,000 ONLY if the road network is able to handle the volume of heavy vehicle traffic. This being the determination made by the PAC, and in the absence of a master plan that would have enabled the commission to assess the impact of both proposals as part of the one process, this limit should apply to the operation of both SIMTA and Moorebank intermodal sites combined. TEU's should be limited to a total of 250,000 in this precinct.
* The economic viability of the site has been questioned due to the limits placed by the PAC on the number of TEUs SIMTA can move through their terminal. Chief Executive of Asciano has also questioned the economic viability of the site as previously mentioned, stating that Asciano plan to invest $112 million in their sites to increase capacity and making Chullora more competitive, able to handle an increased capacity from Port Botany, and open for operation before Moorebank (Wiggins, J., 2014, `Asciano challenges Moorebank freight hub', Sydney Morning Herald, 2 July 2014). With the Chullora intermodal capacity increased to 800,000 TEU it will easily be able to support increased in freight through Port Botany while the Badgerys Creek site is planned and constructed.
* The Moorebank site is surrounded by water on all sides. This means that the complex road and rail upgrades needed to service an intermodal in this area will be extremely costly. Liverpool Council has estimated these upgrades are likely to cost in excess of $750 million.
* There are significant problems relating to air quality, construction and operational noise impacts created by the intermodals. A proposal of this size and nature should not be earmarked for a residential area.
* The PAC determination of the SIMTA proposal has already revealed that Particulate Matter 2.5 levels in the local area are close to or above the advisory criteria for this pollutant, this applies to the current background levels as well as the predicted impacts. Additional diesel and liquid natural gas powered vehicles in this area will exacerbate this problem.
* Noise impacts, light spill and air pollution will have a detrimental effect on the local community, some of whom live as close as 400 metres from the site. Residents around Port Botany living as far as three kilometres from the port are affected by these factors; many residents in Chifley for example have been very vocal about sleep disturbance in the online domain.
* The Moorebank site will have a detrimental impact on the Casula Powerhouse Arts Centre. The presence and accessibility of an art and cultural facility in a low socio-economic area, such as Liverpool, is essential for positive community growth.
Problems with the process
The Freight Infrastructure Advisory Board (FIAB) recommended a master plan for the site, this was not undertaken. Residents agree the SIMTA and MIC proposals should have been considered as a single precinct application. This has created an unfair advantage for the proponents with confusion being created among the community with both proponents presenting different figures. The fact that both proposals were assessed separately also means that media attention highlighting the different stages of the planning and assessment process has also created confusion in the community. Coupled with this, the relocation of the Defence National Storage Distribution Centre (DNSDC) and the current construction works at Holsworthy Barracks have also exacerbated this confusion with many people within the community thinking the proposal is already in its construction phase.
Liverpool Council, in meeting with PAC expressed disappointment that a master plan was not undertaken and confirms that this has created confusion within the community `The ad hoc approach .........leaves gaps and inconsistencies in the information available resulting in a lack of transparency and reduced faith in government decision making.'
A master plan would have reduced this confusion and allowed the community to better understand the impacts these proposals will have on their family, friends and neighbours. It would have allowed the community to better refute claims made by the proponents, and have a much greater grasp of any proposed mitigation strategies for this proposal.
The MIC has also created confusion and doubt within the community, adding to a reduced faith in government process and decision making. They have done this first by splitting their figures. Rather than telling the community that there will be 1.55 million TEUs going through the site, they have split these figures between import-export and interstate. And rather than stating that there will be an estimated 297 train movements expected at the site, they have again split these figures to make them sound lower. The Liverpool Leader, in their article `Intermodal company gives community $1m for compensation package but concerned residents aren't buying it', reports on community concerns around the consultation process. This `compensation package' will be completely inadequate to address the impacts this proposal will have on the area, and made MIC seem like it was trying to `buy community support'. At the same time MIC also made a highly publicised donation to the Liverpool Mayoral Ball, which Liverpool Council subsequently rejected (Hansen, N., 2014, `Liverpool Mayor knocks back $5k ball donation from intermodal group but the cash is still destined for charity', Liverpool Leader, 22 August 2014).
An intermodal at Badgerys Creek would not require this level of compensation, as it can be properly planned for a suitable area; it also has residential and council support.
Second, the Sydney Morning Herald in their article `Waterfront baron and Liberal Party donor scored inside running on freight hub tender' has highlighted a possible issue around transparency and due process in the awarding of tenders for the Moorebank precinct. In light of the recent ICAC investigations and the problems faced by the Newcastle community, transparency and due process are paramount in the government decision making process.
Key issues from the community
There were some issues raised by local representatives and the community at the PAC determination meeting on the SIMTA proposal. These have remained largely unchanged in relation to the MIC proposal.
Traffic and access * The proposal will move the congestion from Port Botany to Moorebank, which is already congested;
* Modelling does not include the predicted growth of the region;
* The intersections and road network are already congested, how is it possible for the proposal to decrease traffic delays?
* Trucks `weaving' onto and off the M5 between the Moorebank and Hume Highway interchanges, this is going to cause accidents; and
* Trucks parking and taking short‐cuts through the nearby streets.
Noise * There is no noise wall along the rail corridor along the Georges River, so noise will carry particularly at night;
* Noise from the unloading/loading and movement of containers within the terminal;
* Noise from the breaking and shunting of trains due to the site sizing constraints; and
* Wheel squeal from the trains exiting the SSFL, tight radius curves lead to wheel squeal.
Air quality * Increased diesel fumes in the community generated from locomotives, heavy vehicles and other heavy equipment used on site;
* Health impacts from the increased diesel fumes;
* South‐west Sydney is already heavily polluted due to the topography; and
* Dust and odour, particularly during construction.
Two intermodal
proposals
(SIMTA and MIC)
* There is an ad hoc approach to the two proposals;
* Cumulative impacts of the two proposals have not been adequately addressed; and
* Confusion as to the total traffic generated from the two proposals, as the modelling for each is different.
Heritage * Removal of heritage features from the site, particularly those of military and indigenous significance.
Location * Site is surrounded by residential development; and
* Other sites are preferable, such as Badgerys Creek, which is not surrounded by an established community.
Moorebank Intermodal Company EIS presentation
There was considerable concern from the community over the presentation that was given for the MIC EIS submission. Figures and statistics presented by MIC seemed to be inconsistent and the facilitator tried, on a number of occasions, to ask the community to voice their concerns directly to MIC representatives rather than in the public forum. At each of the three sessions the facilitator kept stating that she was conscious of time; however, the community feel that their questions about a proposal that will impact their family and community deserved an answer, and are more important than clock watching. The number of questions from the community at the final community information session saw the session run over time.
Traffic and Transport
* The MIC recognised that there are significant transport and traffic congestion problems in the Moorebank precinct; however, they claim that the additional 8,160 heavy vehicles and 5,724 cars they predict to be brought into this precinct every day due to an intermodal will not have any further impact.
* The Chief Executive Officer of MIC stated that there would be approximately 1.6 trucks required per TEU. He also stated that 1,400,000 TEUs would be required to leave the terminal by truck. According to this statement, and given that heavy vehicles will have to both arrive and leave from the precinct, the figure of 8,160 heavy vehicles per day seems low, this actually equates to 12,376 heavy vehicles per day. For the purposes of this document the figure of 10,000 heavy vehicle movements per day has been chosen as a more accurate representation of the figures.
* The Chief Executive Officer of MIC also confirmed that the Moorebank intermodal will not take heavy vehicles off the M5 between Port Botany and Moorebank, and that as Port Botany expands the number of heavy vehicle movements on this stretch of the M5 is expected to grow. It should be noted that Labour Minister Anthony Albanese previously claimed that the Moorebank intermodal would take trucks off the M5; this fallacy gained a lot of momentum especially in the media and it has never been publicly corrected.
* Questions were raised by the community about the problem of Trucks `weaving' onto and off the M5 between the Moorebank and Hume Highway interchanges. MIC recognises this as a significant problem.
This `weaving' has the potential to cause a recognised `black spot', with potentially fatal consequences for the community. It is worth noting that a `black spot' is already located at the Nuwarra Road and Heathcote Road intersection, only 2 Kilometres from the `weave' site.
* The traffic modeller for MIC presented information about the predicted impacts on intersections both with the intermodal and without. Intersection surveys were undertaken on Tuesday 7 December 2010, and Tuesday 18 March 2014, in peak hours only. It is concerning that these surveys seem to only have been conducted on two days, four years apart, with the December date being in a peak holiday period.
* A Seven-day automatic traffic count was also conducted from Tuesday 7 December 2010 at only three locations along Moorebank Avenue. It is concerning that four year old data, gathered prior to a number of new and extensive residential developments in the area, is being used as a base for traffic modelling.
* The data presented by the traffic modeller showed a delay of over 200 seconds at some intersections when the intermodal is in operation. A 200 second delay, coupled with a 150-180 second cycle on a normal set of traffic lights is a significant impact (approximately six minutes at EACH set of lights), one that is likely to have flow on effects.
He has compared data, which is based on a scenario where the intermodal is operating with road and intersection upgrades, with predicted data based on no intermodal without road upgrades. This is not comparing like for like. Given that intersections in this area are currently operating at D or E classification (near or at capacity), it is hard to believe that the roads in the area will not be upgraded by relevant authorities to attempt to reduce congestion before they reach an F classification.
* It has been noticed that traffic figures do not take into account the recently announced WestConnex which will have major traffic implications on the M5 during construction; this coincides with the proposed opening date of the Moorebank intermodal.
The WestConnex project also aims to increase Port Botany by 272% more container ships by catering for a greater number of heavy vehicle traffic movements on the M5.
Labour Minister Anthony Albanese criticises the WestConnex `proposal for not going near Port Botany, where it is expected there will be a large rise in the number of container trucks'. He also questions the government's transparency, citing that `the decision to release new information about the impact of WestConnex on Melbourne Cup Day indicates to me that those who support this route are aware of its shortcomings and are keen to avoid public scrutiny.' (Saulwick, J., 2014, `Albanese pans plans for the WestConnex', Sydney Morning Herald, 10 November 2014).
* Residents are understandably concerned about the impact of intermodal traffic on local and residential roads. The MIC confirmed at the community information session that while they can implement some measures for traffic movements, it will ultimately be up to the design of the precinct, the way the precinct operators choose to use the precinct, and choices made by heavy vehicle drivers as to which route they choose to use. With heavy congestion on Moorebank Avenue and the M5, two of the key roads in the area, it is likely that Anzac Road and Cambridge Avenue will be used as `rat runs' for heavy vehicles.
* The MIC traffic modeller recognised that currently 6% of traffic on Anzac Road in the peak is heavy vehicle traffic; however he failed to include any heavy vehicle movements in his trip distribution figures for this road. In current heavy traffic conditions Anzac Road is a very attractive option, as demonstrated when the M5 is congested. Heavy traffic movements on a congested day are far higher than those measured by MIC. The omission of this traffic flow information from MIC data sets is hard to fathom. For the local residents, especially those with houses that back onto Anzac Road, it creates uncertainty and distrust in the accuracy of the information presented.
* The construction of an intermodal terminal at Moorebank shows a lack of strategic planning, particularly in relation to future traffic movements.
* An intermodal at Badgerys Creek will be a true intermodal with road, rail and air access. This area will serve the purpose of meeting the needs of future growth centres. The government currently has the ability to configure appropriate and safe truck access in the Badgerys Creek area with $3.5 billion in funding dedicated for road infrastructure.
Rail access
* MIC has predicted an additional 297 train movements each week, this figure does not include the interstate trains that may transit through the terminal.
* It was unclear how these train movements would impact residents in the area, due to three different rail entry options currently under consideration.
* Due to the length of trains, they will need to be broken up and shunted.
* MIC communicated that the actual rail entry will be decided once a tender for operation of the facility has been awarded. This makes it difficult for residents to understand the impacts of the rail access.
* It is unclear whether rail access will impact the passenger rail line and impact on travel times for people travelling by rail to the Sydney CBD.
* An intermodal at Badgerys Creek will not have the same rail implications. The size of the site will allow trains to remain whole within the terminal without the need for breaking and shunting.
Noise and vibration
* In order to ascertain acceptable noise levels in the area, the MIC have measured ambient noise levels between 2010 and 2011, and then from July 2012 to establish a base index. Approximately 20 of the 34 noise receptors set up and monitored by the MIC to establish this base index were located along train lines and major roads.
* Given that most residents in the area live in quiet, peaceful streets, it is a concern that the receptors set to ascertain the base index for ambient noise seems to have been placed in predominantly noisy locations.
* The residential suburbs of Casula, Wattle Grove and North Glenfield are the closest communities to the Project site; however, these will not be the only locations impacted by the noise generated from the proposed intermodal.
* In a recent article in the Sydney Morning Herald it was learned that `After more than a year of residents around Port Botany being told the night time noises they were complaining about did not exceed "sleep disturbance criteria", the Environment Protection Authority has admitted they were right.' (O'Brien, N., 2014, `EPA admits it was mistaken about Port Botany noise levels', Sydney Morning Herald, 17 August 2014).
* Residents in the precinct are understandably concerned that noise levels will exceed those acceptable. Above acceptable noise levels can have health impacts including: annoyance, sleep disturbance, performance issues (reduced concentration), cardiovascular health problems, hearing problems, mental health effects, and general health impacts (e.g. on the immune system).
* There is currently no noise wall along the rail corridor along the Georges River, so noise will carry particularly at night.
* There is no doubt there will be excessive noise from the unloading/loading and movement of containers within the terminal, which will operate 24 hours a day, as well the breaking and shunting of trains due to the site sizing constraints, and compression breaking of trucks on the surrounding roads.
* Wheel squeal from the trains exiting the SSFL have also been identified, as tight radius curves lead to wheel squeal. The MIC noise analyst has agreed that wheel squeal is likely to be a factor with some of the three different rail entry options currently under consideration. A factor that will apparently be decided once the tender is awarded, a decision that is likely to be economically based with no consideration for the nearby community.
* An intermodal at Badgerys Creek will not have the same noise implications, due to it being located in a purpose built heavy industrial area. The size of the Badgerys Creek site will also allow trains to remain whole within the terminal, negating the need for breaking and shunting of trains. Rail access will not be restricted by the construction of rail bridges over the Georges River, as is the case at Moorebank, reducing the instance of wheel squeal by negating the need for tight entry and exit points. Compression breaking can be limited through planned road upgrades specifically designed for heavy vehicle movements.
Local air quality
* MIC have recognised that exposure to pollutants and particulate matter (PM) can contribute to, or exacerbate, respiratory and cardiovascular issues, including premature mortality and morbidity, in addition to increasing associated hospitalisations. This supports that point that this proposal should not be planned for a residential area.
* Placing a heavy industrial facility in the middle of a residential area is negligent and will be detrimental to the community. The proposed site is located in a basin which allows pollution to lie, rather than easily move away. The NSW Planning and Assessment Commission have already recognised that the air quality in the Liverpool area is generally well below guidelines, particularly PM2.5 concentrations which are close to or above the advisory criteria. Additional diesel emissions and particulate matter released from this proposal will prove dangerous for residents, especially the most vulnerable: children, the elderly and disabled members of the community.
* Diesel fumes and particulate matter are carcinogenic, and as well as causing other serious illnesses, will be fatal for some members of the community.
* It has been identified that diesel locomotives and switch engines are significant contributors of SO2, NOx, PM10, PM2.5 and PAHs, while onsite mobile equipment (ITVs, side picks and forklifts) are the highest contributor to CO and VOC emissions, they also contribute substantially to PM10, PM2.5.
* It is understood the decision about onsite equipment will be made by the tender winner and based on economics rather than community welfare.
* During operation of the Project, combustion engine emissions (i.e. NOx, CO, SO2, PM2.5, PM10, VOCs and PAHs) from locomotives, mobile LNG equipment and heavy vehicles represent the greatest potential for air quality impacts.
* With 297 train movements each week and approximately 10,000 truck movements each day it is concerning that a proposal of this nature could be considered alongside family homes, and close to pre-schools, primary schools, high schools, as well as aged care facilities.
* Badgerys Creek, an Australian Government owned area, is away from residential properties, and therefore not likely to cause the same risks as the Moorebank site. It is also well placed near the M7 and the proposed M9 Motorways, providing the ability of the intermodal to service future growth centres, near the Western Sydney Employment Area (WSEA), future industrial areas and future freight markets in Western Sydney, where two-thirds of container freight received at Port Botany will be transported.
Human health risks and impacts
* The NSW Chief Health Officer's Report (2010) identified that health gains achieved over the past few decades have not been equally shared across the entire NSW population and that there is a gap between those with good and poor health. This gap is exacerbated in poorer communities.
* South Western Sydney has some of the poorest communities in NSW as measured by the SIEFA data (Australian Bureau of Statistics (ABS 2011).
* South Western Sydney has higher rates of people with disabilities than the NSW average. People with disabilities have health conditions which may or may not be related to their disability.
* In 2004 - 2008, South Western Sydney residents had higher incidence of lung, kidney, head and neck, pancreas, thyroid, stomach, bladder, uterus and liver cancer than NSW.
* Mortality rates in South Western Sydney for cardiovascular disease at 83.9 per 100,000 are 5% higher than the NSW average of 100 and are significantly higher in Liverpool LGA (111.4) (2005/06).
* Very high psychological distress was reported by 13.2% of South Western Sydney residents (2.1% above the NSW average).
* As previously noted, MIC have recognised that exposure to pollutants and particulate matter (PM) can contribute to, or exacerbate, respiratory and cardiovascular issues, including premature mortality and morbidity, in addition to increasing associated hospitalisations. And that that diesel locomotives, switch engines, and onsite mobile equipment (ITVs, side picks and forklifts) are significant contributors of PM10, and PM2.5.
* As also noted, above acceptable noise levels that will result from an intermodal terminal can have health impacts including: annoyance, sleep disturbance, performance issues (reduced concentration), cardiovascular health problems, hearing problems, mental health effects, and general health impacts (e.g. on the immune system).
* Traffic impacts with the identified the problem of Trucks `weaving' onto and off the M5 is a significant problem. This `weaving' has the potential to cause a recognised `black spot', with potentially fatal consequences for the community.
* It is highly negligent of the Government to consider building an intermodal at the currently proposed Moorebank site. The site is located in the middle of a residential area, and the consequences of such a decision will prove dire to the community.
* Badgerys Creek is by far a site better suited to meet the criteria that the MIC has listed in their EIS summary.
Support from elected representatives
The role of three tiers of government is to ensure that community needs can be voiced to the government by their local elected representatives. These representatives are based within the community, they understand the local area, and are acutely aware of the geographic typography of the area and their constituents needs.
The representatives from the Liverpool area are all unequivocally stating that the Moorebank Intermodal proposal is in the wrong location. This includes the federal member for Hughes, Craig Kelly MP; the state member for Menai, Melanie Gibbons MP; and Liverpool City Mayor, Ned Mannoun.
It is worth noting these representatives recognise the need for an intermodal terminal within metropolitan Sydney to support future freight growth in New South Wales; however, Badgerys Creek is the ultimate location for this development. Liverpool Council have recently released a discussion paper titled `Badgerys Creek: the ideal location for an intermodal' (October 2014).
It is time for the government to listen to their party members who are voicing some very valid concerns, and join the discussion about a new location for this project.
Alternative uses for the land at Moorebank
The residents of Liverpool also support the Freight Infrastructure Advisory Board (FIAB) recommendation of the development of new intermodal freight capacity within metropolitan Sydney. However, the residents believe that the location of this development should be strategically placed to meet future growth and freight capacity. Therefore, it is proposed that Badgerys Creek, rather than Moorebank, is recognised as the consummate site for development.
`In 2011, the Australian Government developed the Liveable Cities Program (now called the Liveable Communities Programme) to support state, territory and local governments in meeting the challenges of improving the quality of life in our capitals and major regional cities' (2011, Department of Infrastructure and Regional Development website).
As part of this program, Parramatta City Council (the only Sydney council selected for the program) received $16,150,000 in funding to complete three missing links on the Parramatta Valley Cycle way, and undertake a series of related works on the Parramatta River Foreshore. The money used for this revitalisation has given Parramatta an economic and social boost.
The site identified for the Moorebank intermodal is prime, urban, riverfront land. This land should be used to assist the government in solving the housing crisis identified in the draft Metropolitan Strategy for Sydney, by using the development as a premium riverside residential lifestyle precinct. The land is situated less than 30 Kilometres from the Sydney CBD. It is in close proximity to public transport, including the T2 Airport and T2 Inner West & South lines (both of which have capacity to accommodate urban growth in this area), the Liverpool to Parramatta T-Way, the M90 Liverpool to Burwood bus route, and many suburban bus routes. In short, the Moorebank location is perfectly positioned and adequately serviced by public transport to assist the government in meeting its housing targets set in the Metropolitan Strategy for Sydney.
An independent valuation (Cushman and Wakefield Development Opportunity Liverpool Riverside Lands, September 2014) valued the SIMTA and MIC sites at more than $482 million. Revenue raised from the sale of this land could be used to assist in the funding of the infrastructure needed to support, and fast-track an intermodal at Badgerys Creek.
NSW Chief Health Officer's Report (2010) identified that there is considerable evidence that social factors (e.g. income, employment and education) have a critical role in health outcomes. A plan to revitalise the Liverpool area by embracing natural assets, such as the Georges River, and utilising land to its full potential presents an opportunity to lift the socio-economic status and improve overall health in the area. The Liveable Communities Programme in Parramatta is a testament to this.
Preserving the Casula Powerhouse Arts Centre and maintaining its accessibility to the community will boost the social economy of the area and contribute positively to community growth.
Linda Silmalis, in her Sunday Telegraph article (9 November 2014) says that `NEW housing sites for 11,000 homes will be unlocked today as the NSW government seizes on a building boom with one of the biggest land releases in Sydney this year.' On this topic, `State Planning Minister Pru Goward said the areas will help drive the housing construction boom, while placing downward pressure on house prices.' (Silmalis, L., 2014, `Grab your new home out west', Sunday Telegraph, 9 November 2014). Liverpool Council estimates that the land proposed for the Moorebank intermodals has the capacity for approximately 16,500 riverside dwellings, housing more than 40,000 people, and giving the community access to the Georges River. This will assist the government in meeting its targets, identified in the draft Metropolitan Strategy for Sydney, to develop housing for more than 1.6 million people. Affordable housing is a much better use of the land in this area.
Good, well considered, strategic planning is required to maintain New South Wales' status as the Premier State. This includes planning major infrastructure projects, such as an intermodal terminal, in the right location. The right location for this proposal is not Moorebank; Badgerys Creek is far better suited and situated to meet the Government's freight infrastructure needs.
Please reject this proposal on the grounds that it is not in the public interest of the residents of Liverpool or the wider community or to the Economy.


I am against the proposal for an Intermodal at Moorebank for many reasons:

* The EIS should be completed on the total number of projects proposed for the area, i.e. Federal Government Intermodal on the Australian Army Engineers site, SIMTA proposed intermodal as well as the SSFL since the effects will be felt of the total projects that are proposed not just the SIMTA proposal. Anything less does not give an accurate picture of the outcome.

I could not find any information that referred to the cumulative effects on air quality, noise and traffic that would occur from both the SIMTA proposal and the widely known about Moorebank Project Office proposal operating simultaneously.
By splitting the projects, it is is misleading and unfair to the people of Liverpool and to anyone that uses this area whether to travel through it , provide serices or use services provided by the area.


ROADS AND TRAFFIC

-Impacts to Traffic should be considered including the exiting and entry of trucks to and from the site and the deadly impact this will have as these trucks attempt to merge onto the M5 with traffic travelling at 100kph. Trucks merging from Moorebank Ave onto the M5 travelling towards the M7 will inevitably cause accidents as those already on the M5 travelling in the same direction swerve to avoid them or simply crash into the back of them. Also as cars travelling in that same direction on the M5 try to merge into the far left lanes in order to get onto the Hume Hwy whilst trucks from the intermodal are merging from Moorebank Ave onto the M5 travelling towards the M7, accidents are inevitable. For these scenarios to be mitigated would possibly mean lowering the speed limit on the M5 for that area or building complexed and expensive underpasses, overpasses or tunnels. Not enough information has been provided in EIS regarding mitigating or providing solutions to such matters. Any information provided is vague and does not display who would be responsible implementing for such action.

- What will you do to implement procedures to prevent trucks from using local streets? How will it follow through, monitor and carry out these these procedures? What are the so called local streets specifically? Please name them specifically?

- there will be a huge impact to the residents living close by as well as a significant impact to all people living within a 10km radius of this site. The location is within very close proximity to houses. How would anyone expect our lives to be with all the air pollution that would be generated, the noise and the light 24/7. Not discussing the rail impact, our streets are already very congested and as it stands now it is almost impossible to go on the local roads during peak hours let it be with 2000 trucks more. The M5 is already over full capacity during these peak hours and roads in the surrounding areas of the proposed Intermodal would become gridlocked.

- I am glad that 3300 trucks are taken off the road from Botany to
Moorebank Avenue. But how wrong is it to put 3300 trucks back on the
road from Moorebank Avenue in an existing pollution basin. The truth behind this simple fact has been hidden by SIMTA as well as the Moorebank Project Office from the beginning of these proposals.
With up to one million trucks expected to enter and depart Moorebank Ave to and from the SIMTA terminal annually, many of them using the M5....How is this NOT due to freight terminals???
How can they say that this number of trucks they intend to bring to the Liverpool area will not increase truck movements on the M5? It may be on a different section of the M5 ie between Moorebank Ave and the M7 junction but the same number of trucks and more will still be using the M5 due to the fact that goods must be delivered from Moorebank to the warehouses in the west and south west of Sydney.
I feel the Liverpool community are being fed lies to avoid conflict with residents on their proposal.

-

AIR QUALITY AND PEOPLE'S HEALTH
Air Quality is really important. Australia has one of the worlds highest incidents of Asthma. Residents suffer from many other lung complaints as well. Any degradation in air quality will make these conditions worse. Every truck that they take off the road at Port Botany will have to start at Moorebank, queuing with its engine running, pushing pollution into the air.

Air Pollution has really serious health effects. Studies show the following:
* Air Pollution from busy roads shortens life expectancy
* Asthma symptoms (and childhood hospitalisations) caused by truck exhaust
* Babies are more likely to be premature or have low birth weight if mum lives near high traffic areas
* Respiratory symptoms in two year olds linked to Traffic
* Asthma more common in children who live near freeways
* Children (and people generally) who live near busy roads are more likely to develop cancer
* Air Pollution causes more traffic related deaths than accidents
This link has an index of relevant studies from the San Diego Earth Times.

Another study http://www.ehjournal.net/content/6/1/23 talks about the Cardiac and Pulmonary effects of living in close proximity to pollution.

Specific questions to be addressed in the terms of reference should include;
a) what increases in PM10 and PM2.5 will occur at different locations in the local environment, arising from all sources related to the proposed Moorebank
Intermodal Terminal Facility
b) what increases in PM10 and PM2.5 will occur at different locations in the local environment, arising from the combined effects the proposed Moorebank
Intermodal Terminal Facility and the Department of Finance Intermodal
terminal project.
c) Will the increases in PM10 and PM2.5 arising from the Intermodal developments push the levels of PM10 and PM2.5 (in any location) above the guidelines set by the World Health Organization.
d) What, if any health effects are likely to occur in the local population resulting from increases in PM10 and PM2.5 levels associated with the Intermodals.
e) What are the economic costs (loss of productivity, cost of health care, etc) of any adverse health effects.
f) If the proposed Intermodal facility was to be located in another area of Sydney,what PM10 and PM2.5 levels would result in these other local areas.


- The proponents of the massive terminal complex at Moorebank say that residents won't be impacted by noise, but residents are not convinced.

Overseas, authorities acknowledge the noise impacts on local residents. The Port of Houston Authority in Texas has offered $US40,000 "mitigation payment" per house for houses as far as 920m (Baywood Ave Shoreacres) from the Bayport Container Terminal so home owners can install soundproofing.

You can read all about it here.
http://www.bayportmitigationsolution.com/

- In 1997 the Holsworthy Airport proposal was scrapped, one of the reasons being that the air pollution would adversely affect the region. 15 years later that population is now substantially bigger and more people would be affected by a much bigger proposal. The location is the wrong place for such an operation


- Since pollution in the area is already high compared to a lot of areas in Sydney any increase in pollution must be considered to be dangerous and must be monitored in full and in all conditions. Any adverse findings must be reported and remediated including fines and/or criminal penalties where applicable.

- There has been a mountain of research from all over the world that diesel emissions cause great problems to residents even short term exposure.It effects the brain lungs diabetes child birth weight hearts as diesel contains 40 toxic chemicals. And still it appears the ones deciding on these freight terminals are choosing to ignore the facts and the resident's concerns. It is unbelievable that governments and companies can be so short sited when planning such infrastructure in residential areas. Or is it simply neglect?

OTHER ISSUES

- The threat of terrorist attack on the Intermodal site including freight and infrastructure. With only 3% of containers currently being checked for illicit and illegal goods how can we be certain that terrorists will not attempt to attack and cripple Sydney's Freight flow, particularly as it seems that the Government is concentrating all of the freight flow into 1 or 2 narrow freight corridors.


- The potential for an accident with unknown container contents spillage or leaking into the George's River, local watertables, soil or air is of concern


- The potential for an explosion resulting from an accident or careless handling of containers resulting in damage to resident's homes and other surrounding infrastructure.



-Most of the 13,000 families within 2km of the container terminal are paying off a mortgage and they are worried about the effect of having a huge container terminal appear next to their house.
Houses next to terminals drop in value, a lot. Local residents don't deserve a slug like that.
What compensation will be on offer for residents within the 2km zone from the Intermodal?




- Why is the Crime and statistics of the suburb of Moorebank studied so heavily when in fact the planned intermodal lies closer to the residential areas of Wattle Grove and Casula than it does to the predominant residential area of Moorebank? It seems Wattle Grove and Casula have not been considered in the planning and the social and health requirements of these suburbs will not be considered by SIMTA.


- Nowhere in the planning for Moorebank complex has there been any mention of compensating residents so they can insulate themselves against noise or top up their mortgage so the drop in property value doesn't leave them with negative equity.


- I have to remind the planners of these Intermodals both Federal and Private that flooding of the Georges River is of great concern.
There have been numerous times flooding has occurred along Newbridge Rd near Flower Power and heavy rain in a short period can cause flooding along Newbridge Rd which has the Georges River at 2 points near the area.
With heavy rain recently part of the area has been flooded and to believe you could operate a freight hub with such uncertainty beggars belief and if the flooding occurred it would cause great damage and inconvenience to the SSFL freightline and the transport of diesel trucks along Newbridge Rd , Moorebank Ave and other heavily patronised roads.

Can you please listen to these concerns and reply with a personal response?

Our community would appreciate the chance for your group to meet with us to discuss these and other concerns.

Kind Regards,

Dominic Scutella


The consultations regarding the proposed Intermodal(s) at Moorebank/Wattle Grove are illegal.

According to the 2011 Census, Wattle Grove's population included 27.8 % of people who did not speak English, however the consultations (both the limited posted material and the limited in person meetings) have not included any translated material or provided any interpreters. Specifically, other languages spoken included 4.1% Arabic, 3.0% Other, 2.5% Language spoken at home not stated, 2.4% Hindi, 1.6% Tagalog, 1.5% Tamil, 1.3% Greek, 1.3% Cantonese, 1.3% Bengali.


A study has found that the Liverpool road network without the Intermodal, the traffic demand will exceed the network capacity by 21% by 2030.

With the Intermodal, the traffic demand will exceed the network capacity by 53% by 2030.

How can the proponents possibly claim that Moorebank is the ideal location for this development. What Liverpool will be is a parking station.

Question: (1) What has been put in place to ensure the road network is upgraded to cope with the traffic volume.

Question: 2 This now being basically a private development, the developer should be responsible for the cost of the upgrades, not the taxpayer.


Moorebank is the wrong place to put an intermodal. The poisonous diesel emissions from 10,000 trucks a day, outdated diesel trains as well as an increase in other related traffic will destroy our health. Our roads, at capacity already will be impassable and we won't get any sleep due to noise and sound vibration 24 hours a day, 7 days a week. Don't destroy our homes and our health.


Dear Sir/Madam,

The proposed Moorebank Freight Intermodals are based on Corruption, Lies on a number of levels and are a Break of Contract with Australian Voters.

The BIG Problem is that DEFENCE HOUSING AUSTRALIA in a previous entity SOLD THE LAND NEXT DOOR to the MOOREBANK INTERMODAL FIASCO for a Big FAT PROFIT!.......The Commonwealth of Australia cannot now decide to wreck the adjoining residential 1000 Block land project to suit a profit motif.
The NSW Planning DEPARTMENT is Being Used to Validate a Complete Con Trick
The lack of HIGHER MORALITY by the Commonwealth of AUSTRALIA demonstates the POLLUTION of VALUES IN THE GOVERNMENT OF THE COUNTRY>
The residents of Wattle Grove to be affected detrimentally in this instance next to the Moorebank Site whom bought in good faith the properties adjoining cannot now be affected by an enconomically expedient decision OTHERWISE NO FUTURE COMMONWEALTH LAND SALE WOULD WARRANT RESPECT OR VALUE ON THE AUSTRALIAN PROPERTY MARKE+

I have attached a file with my reasons for objecting

See attached document

There is a short phrase on page 88 of the EIS that clearly explains the problem that local residents have with this proposed development. It reads "The surrounding area does not have a desired future character". In this respect the proponent could not be more wrong. The Liverpool area is a growing city, open for business, but more than anything a place people call home.

The proponent speaks and acts as if the impact of thousands of traffic movements a day and the imposition of an industrial wasteland on what is primarily a residential area is no significant thing, but it is to honest hard working residents who just want to enjoy their street and their backyard while they pay off their mortgage. They don't want their kids to get sick and they don't want their suburb and local environment degraded in any way. Not degraded "within acceptable levels". They don't want "low level" impact on their sleep and health. They want to get on with their lives, to sleep at night and go to work refreshed in the morning and to spend time with their families kicking a ball in the backyard without choking on diesel fumes while the kids wheeze and reach for their puffers.

Liverpool Council supports these objectives and is pursuing a vision for the City of Liverpool that maximises opportunities for businesses while providing an enriching and livable city for residents. For that reason Liverpool Council supports the Badgerys Creek Airport proposal and is strongly encouraging the moving of the intermodal development to the vicinity of Badgerys Creek where there will be acres of warehousing and which is much more centrally located in the catchment identified by SIMTA. Any consideration of this development must be considered in the context of the wishes of the local community and the plans expressed by their elected representatives.

Having reviewed the EIS, I have the following comments for your consideration.

Since SIMTA has been appointed by the government to implement its MIC project, it is contrary to good planning to submit two separate EISs that are effectively for the same development. It divides the impact into two separate impacts which will nevertheless be cumulative.

It is unfair to produce two EIS documents for two parts of the same development (SIMTA and MIC) and release them simultaneously. Residents are only able to devote a limited time to reviewing the documents and the combined size, and the complexity of separately lodging the two EISs and the timing limits residents ability to protect their rights by responding in detail.

SIMTA still provides no promises of sound mitigation for its rail link. There is nothing but trees between the rail link (as it enters the site at the south end) and residents in the southern part of Wattle Grove and SIMTA seeks approval to put many of these to the chainsaw to put the rail link in.

While SIMTA claims the development "Will assist with alleviating freight-related road congestion between Port Botany and Moorebank, particularly along the M5 Motorway". The statement simply makes no sense. SIMTA will only provide capacity to increase output from Port Botany, rather than improving the movement of current capacity. MIC modelling shows containers put on the road at Moorebank would otherwise only travel through Moorebank in small numbers since the south west already has several IMTs and the primary destination for containers is Eastern Creek and further north. This is borne out by the SIMTA EIS figure 2-1 which very clearly shows a distant destination is the most probable with the majority of the catchment around the M4 or north of it as far away as Richmond.

The section `Consideration of other alternate IMT sites" is superficial in the extreme. There are clearly alternative options that are significantly superior. The Moorebank location is a long way distant from the final destination of the containers. The impact on the roads is not properly considered and almost all of the expense of the road congestion caused by the terminal traffic is to be paid by the government. Liverpool Council has proposed a significantly superior location - Badgerys Creek. The airport location is actually ideal since it is a compatible land use to the airport and the necessity to build out infrastructure for the airport will allow the roads and rail necessary for an IMT to be developed in tandem with no need to retrofit. Further, the warehousing that is obviously going to be developed around the airport will actually need an IMT much more than residential areas of Wattle Grove and Casula.

While the proponent blandly states "The Proposal would operate 24 hours a day, 7 days a week.", this is a very significant point. Since the proponent intends to ultimately operate a significantly higher capacity, it ought to be able to operate 250,000 TEUs in daylight hours only, thus minimising noise impacts to residents, without impacting its business.

The proposed rail corridor impacts valuable native vegetation. The recent agreement between the Federal Government and SIMTA regarding MIC enables a greater degree of cooperation and infrastructure sharing between the MIC and SIMTA components of the development and the proponent should be compelled to share its rail connection with MIC and not impact the native vegetation to the south of the SIMTA site. This area is recovering from previous land use and cannot support a rail corridor being carved through its middle and the consequent weed incursion and impact on native fauna.

The traffic and transport analysis artificially and deceptively minimises traffic impact by separating the MIC and SIMTA parts of the development into separate projects and separate EISs, even though they are being developed simultaneously, by the same organisation and in the same location. Discussion of the impact of MIC is limited to the development phase and excludes the operation.

The statement that air quality impacts from construction can be managed is not credible. Residents have recently endured the construction impacts from the new DNSDC facility and residents experienced visible buildup of airborne material on surfaces and were compelled to inhale the same material. The same kind of measures as are proposed by SIMTA were taken by the DNSDC developer and were inadequate.

The air quality analysis artificially and deceptively minimises air quality impacts by separating the MIC and SIMTA parts of the development into separate projects and separate EISs, even though they are being developed simultaneously, by the same organisation and in the same location. Discussion of the impact of MIC is limited to the development phase and excludes the operation.

The noise and vibration analysis artificially and deceptively minimises impact by separating the MIC and SIMTA parts of the development into separate projects and separate EISs, even though they are being developed simultaneously, by the same organisation and in the same location. Discussion of the impact of MIC is limited to the development and excludes the operation.

The non-indigenous Heritage impacts are significant and unacceptable. The relationship between the military and the local area has been a significant element for over a century. The eradication of that heritage with no measures to minimise the loss is unthinkable. At least one of the WWII buildings, but preferably more, could be relocated and repurposed perhaps with adaptive reuse as administrative buildings on site.

The assurances in the "Visual Amenity, Urban Design and Landscape" section are uncompelling. Similar assurances were given for the new DNSDC development and residents are stuck with clearly visible structures, impacting the streetscape in areas as distant as Lakeside Park in Wattle Grove. Concrete promises are needed along the lines of "no aspect of the development will be visible from any residential area".

The EIS makes a lot of affirmative statements, but offers nothing to enforce them, without which they will clearly be ignored a proportion of the time. These include:
No trucks on Anzac Road
No idling policy
Rejecting smokey trucks
Driver Training
Stand down of equipment with smokey exhaust
Track Lubrication
The proponent should be compelled to fund a council ranger position (full time and ongoing) to enforce these and other measures.

There are a number of other residents concerns that the proposal does not address and should:
Pollution from aging locomotives
Noise from locomotives travelling on the SSFL to the site further impacting Casula residents quality of life

Application number: SSD 6766
Project name: Sydney Intermodal Terminal Alliance Project Stage 1
Objection to the SIMTA Intermodal Proposal

The development of an intermodal terminal at Moorebank will mean additional traffic on the already congested road network. 10,000 heavy vehicles per day will need to access and leave the terminal utilising the M5 and local roads.
There is a notion that an additional intermodal is required to reduce supply chain costs; however, it is questioned how the proposal at Moorebank will assist in reducing these costs. The proposed terminal in Moorebank will include transferring freight by rail less than 25 Kilometres from Port Botany, while increasing the handling costs of the supply chain with containers having to be loaded and unloaded multiple times in a very short distance. Infrastructure NSW has also questioned the viability of short haul freight and the funding of additional intermodal facilities until this has been properly investigated. That being the case, the increase in capacity at Chullora should be investigated with proper planning for a true intermodal at Badgerys Creek. Jenny Wiggins, in her Sydney Morning Herald article, states that Asciano is primed to invest $112 million to `compete "vigorously" with its own intermodal terminals', for example Chullora, and challenge the Moorebank intermodal essentially casting doubts over the economic viability of the Moorebank site (Wiggins, J., 2014, `Asciano challenges Moorebank freight hub', Sydney Morning Herald, 2 July 2014).
To truly reduce supply chain costs, the intermodal location should be moved to Badgerys Creek, a facility more than 40 Kilometres from the Port with access to key roads such as the M7 and the proposed M9. This location will also have the capacity to support future growth centres. The M9 motorway will provide `a direct link between the Central Coast and the Illawarra, connecting the growth centres of Camden, Penrith and Windsor' (O'Rourke, J., 2014, `What Sydney needs to transport us to the future', Daily Telegraph, 3 November 2014). An intermodal at Badgerys Creek demonstrates good strategic and growth planning.
Why Badgerys Creek is a better location than Moorebank
Badgerys Creek is an ideal location for an intermodal terminal to handle both interstate and import-export freight. This is because it is:
* long enough for interstate freight trains without the need for trains to be broken up and shunted, creating unnecessary additional noise in the area;
* big enough to handle the number of container movements required - up to 1.1 million twenty foot Equivalent Units (TEUs) per year of import-export freight and another 500,000 TEUs per year of interstate freight. This is a greater capacity than the proposed Moorebank site;
* strategically located in an area where a new rail line is planned for the airport;
* near the M7 Motorway, a link to the West and North West where it has been identified by Deloitte that most of the container freight will be headed, and accessible to the M5;
* near the proposed M9 Motorway, providing the ability of the intermodal to service future growth centres;
* near the Western Sydney Employment Area (WSEA), future industrial areas and future freight markets in Western Sydney, where two-thirds of container freight received at Port Botany will be transported.
* further from Port Botany than the Moorebank site, making rail a viable alternative to trucks, and reducing supply chain costs;
* in development, meaning that truck access can be configured into the $3.5 billion already allocated to the surrounding road infrastructure network rather than upgrading roads that are already at capacity in the Moorebank precinct; and
* owned by the Australian Government and available for use consistent with the airport.
Problems with the Moorebank proposal
The Moorebank site constrained by a number of issues:
* The area is already suffering from significant traffic congestion, the addition of an estimated 10,000 truck movements and approximately 5,000 passenger car movements per day will exacerbate this congestion.
* The Planning and Assessment Commission (PAC), following their community meeting on the SIMTA proposal, has identified that the Moorebank area is already suffering from significant traffic congestion. `The community has strongly argued that the proposal is only going to move the congestion from Port Botany to the Liverpool/Campbelltown region. The Commission understands the Moorebank site is constrained by the surrounding residential and industrial land uses and the already heavily congested local and regional road network. If the concept plan were to be approved with the levels of throughput proposed by both SIMTA and MIC, then clearly the community's case is strengthened.' (2014, Planning and Assessment Commission, SIMTA assessment).
* The economic viability of the site has been questioned due to the limits placed by the PAC on the number of TEUs SIMTA can move through their terminal. Chief Executive of Asciano has also questioned the economic viability of the site as previously mentioned, stating that Asciano plan to invest $112 million in their sites to increase capacity and making Chullora more competitive, able to handle an increased capacity from Port Botany, and open for operation before Moorebank (Wiggins, J., 2014, `Asciano challenges Moorebank freight hub', Sydney Morning Herald, 2 July 2014). With the Chullora intermodal capacity increased to 800,000 TEU it will easily be able to support increased in freight through Port Botany while the Badgerys Creek site is planned and constructed.
* The Moorebank site is surrounded by water on all sides. This means that the complex road and rail upgrades needed to service an intermodal in this area will be extremely costly. Liverpool Council has estimated these upgrades are likely to cost in excess of $750 million.
* There are significant problems relating to air quality, construction and operational noise impacts created by the intermodals. A proposal of this size and nature should not be earmarked for a residential area.
* The PAC determination of the SIMTA proposal has already revealed that Particulate Matter 2.5 levels in the local area are close to or above the advisory criteria for this pollutant, this applies to the current background levels as well as the predicted impacts. Additional diesel and liquid natural gas powered vehicles in this area will exacerbate this problem.
* Noise impacts, light spill and air pollution will have a detrimental effect on the local community, some of whom live as close as 400 metres from the site. Residents around Port Botany living as far as three kilometres from the port are affected by these factors; many residents in Chifley for example have been very vocal about sleep disturbance in the online domain.
* The Moorebank site will have a detrimental impact on the Casula Powerhouse Arts Centre. The presence and accessibility of an art and cultural facility in a low socio-economic area, such as Liverpool, is essential for positive community growth.
Problems with the process
The Freight Infrastructure Advisory Board (FIAB) recommended a master plan for the site, this was not undertaken. Residents agree the SIMTA and MIC proposals should have been considered as a single precinct application. This has created an unfair advantage for the proponents with confusion being created among the community with both proponents presenting different figures. The fact that both proposals were assessed separately also means that media attention highlighting the different stages of the planning and assessment process has also created confusion in the community. Coupled with this, the relocation of the Defence National Storage Distribution Centre (DNSDC) and the current construction works at Holsworthy Barracks have also exacerbated this confusion with many people within the community thinking the proposal is already in its construction phase.
Liverpool Council, in meeting with PAC expressed disappointment that a master plan was not undertaken and confirms that this has created confusion within the community `The ad hoc approach .........leaves gaps and inconsistencies in the information available resulting in a lack of transparency and reduced faith in government decision making.'
A master plan would have reduced this confusion and allowed the community to better understand the impacts these proposals will have on their family, friends and neighbours. It would have allowed the community to better refute claims made by the proponents, and have a much greater grasp of any proposed mitigation strategies for this proposal.

My wife and I currently own Glenfield Farm. This historic cluster of farm buildings (circa 1817) was owned by 'the state' prior to October 2013 and administered by the Historic Houses Trust.


One of two sites now being considered for the two spur lines serving the intermodal will be built directly in the sightline, ~200m, on the Glenfield waste facility. This facility according to Council documentation sighted when we bought the house, was to be remediated and turned into public parkland. While being in our sightline is a major issue we consider the noise abatement for this major project has been very inadequately addressed (see attachment). The approval process requires consulting neighbouring landowners, which may have been 'the state' at the time; we weren't consulted or our lawyer informed.



This process appears to be more about maximizing the value of Commonwealth and State land holdings than a genuine desire to reduce the impact of container traffic. This is particularly the case as the Planning Assessment Commission (PAC) has determined that originally proposed 1M container movements has been reduced by half to only 500,000. The proposal should be located where the predicted growth in container movements can be better accommodated. The project should be relocated at Badgery's Creek.



If it is mandated to continue at its current site the approach from the south to the spur should be moved several hundred meters south so it is parallel to the East Hills train line, thus avoiding the acute angle this approach takes with the marked braking and wheel noise which cannot be obviated given the elevated location of our property relative to the rail line.

My issue as per the attached PDF is about the noise pollution associated with the freight liners on the nearby residents of Casula Links NSW 2170. Noise from freight trains on the SSFL as well as movements across the rivier to and from the MIC site. At this point there are NO NOISE WALLS/BARRIERS along the SSFL, despite houses located within 20m of the SSFL.

Also, the Noise Pollution to Casula residents coming off the M5 Georges River Bridge which is government owned ie. RMS. The only stretch of road on the entire orbital road network in Sydney Metro with no noise walls/barriers. The truck compression braking and constant traffic, which will only get worse between Hume Highway and Moorebank Avenue is a total disgrace. No noise testing and no noise monitoring from Liverpool Links and Casula Links has been undertaken. There are houses 50m from the bridge. Add to that the SSFL this is a nightmare. Noise Barriers on the M5 Bridge and SSFL are a necessity not an option.

The concerns and health of the local community and our local council have only been given lip service by the proponent. They constantly dismiss the concerns of residents and minimise the negative impacts of this development while never the substance of the concerns people address and overstating its potential benefits.

The Moorebank precinct is not the main area of need for the output of this development. The proponent's own documentation highlights this. It would be better to locate this development closer to the intended destination of the warehouses needing the containers which is the Eastern Creek area and further, towards the center of the intended catchment area.

Approving this development would place an unfair impact on the residents of Wattle Grove, Moorebank, Casula and surrounding areas. The terminal is recommended by the proponent for its positive outcomes for NSW but the terminal's many neighbouring residents would have to shoulder an unfair share of the state's traffic, pollution, degradation of the natural environment and the loss of nationally significant historical sites.

This development will turn the area around it into an industrial black hole, destroying all the hard work of our local government in developing Liverpool as a livable city with room for both development and a healthy family friendly lifestyle.

The proponents make a big deal that their development will ease traffic on the M5 between Botany and Moorebank. They also claim that those same trucks as they leave the Intermodal Terminal will not adversely impact the roads of Western Sydney. It is inconceivable that trucks that are causing great impact on the M5 in one area will have little or no impact in another. Residence have a right to expect honesty in the EIS.

Now that SIMTA is behind both projects it would be appropriate for them to resubmit their EIS with one comprehensive document that covers the impact and scale of the project on both sides of Moorebank Avenue.

We believe that this development is wrong. We believe that the NSW Department of Planning made a big mistake in recommending this development.

We have provided proof that the decision was based on wrong and misleading information.