Moorebank Intermodal Precinct West - Concept & Stage 1

i would rather have the new airport and the project into one place as they contribute to each other. traffic wise and work also.

Dear Sir/ Madam, regarding the planned Intermodal at Moorebank, I would like to express my concern that continuation of the project could cause major damage to the local structure of the community for a long time into the future and I feel major public perception damage to the parties pushing for the completion of this project.
Prior to announcement of the new Airport at Badgerys Creek the idea of the intermodal at the proposed location, was almost half acceptable but now the only acceptable and I feel sensible location is near the new airport for logistical and humanitarian reasons. Thank you for the opportunity to comment and possibly make a difference for the better. Rgds. Anthony Bell.

I am vehemently opposed to the intermodal. I am raising a young family and do not want the excessive air, noise and traffic pollution the intermodal will bring. This is a residential area. Badgery's Creek is a much better option.

[ Full Submission is being sent postally ]

BRIEF SUMMARY ONLY :

The most appropriate location--and that by a wide margin--
for an Intermodal Centre in Sydney is the Auburn-Clyde-Granville site;both for------

1. Maritime Containers { Import-Export Traffic],and
2. Road-rail Interfacing of Various containers in domestic traffics.
Some reorganizing of site costs will be easily outweighed
by the extensive advantages enumerated in the submission

I oppose the proposed intermodal terminal site at Moorebank Avenue based on negative impacts it will definitely cause to the quality of living to the local community, noise and sound pollution and the added congestion to the surrounding roads. As a local resident and homeowner living within one kilometre of the proposed site I will be directly impacted and also believe there are other potential sites which may be suitable including in Badgerys Creek.

Traffic is already bad enough. It already takes me an hour and a half just to get to and from the city and its only going to get worse! Liverpool's main areas are progressing beyond industry, our land is worth more than that especially to us, especially Moorebank!
Badgerys creek makes a lot more sense!

I am very much opposed to the Intermodal based on adverse air, noise and traffic pollution. Please move it to Badgery's creek.

There would be negative impact on George's river landscape and its environment by placing this terminal at Moorebank.

It makes more sense to locate this terminal at Badgerys Creek where the vast land available required by this project. Also, where the Airport and rail facilities can be more handy.

Dear Hon. Warren Truss MP,
As a resident of the South West Region of Sydney, I write to register my strong opposition to the location of the proposed intermodal freight terminal at Moorebank. I believe the logical place for the Intermodal is the new international airport your Government is building at Badgerys Creek. Here, it will be a true Intermodal for road, rail and air, run at its capacity with room for expansion (which the PAC has determined it cannot do at Moorebank), and will be profitable from its first day of operation. It will also create new jobs, growth and bring major industry to this part of South West Sydney.
I urge you to act and make the right decision for the South West Region and the Australian people - build the new intermodal at Badgerys Creek.

I believe the Moorebank Intermodal is proposed in the wrong location therefore should be relocated to Badgeries Creek or Eastern Creek Areas.
I believe the proposed development is unwelcome in the district as more suitable residential or public recreation/conservation is best adjoining the Georges River.
In addition as a resident of Wattle Grove I believe the proponent is dishonest about the full ramifications of the actual Negative Impacts of such a massive freight hub for the environment and surrounding populations whom have purchased in good faith ex Defence Lands from the cash strapped Federal Authorities whom have pursued this avenue without care or chivalry. I believe further that this proposal if approved will lead to Traffic Gridlock on our Motorway System and will not alleviate gross congestion generated by the over reliance on Port Botany for Container Landing.
I have attempted on several sessions to alert the proponent of my concerns and have been told by senior government and Political Figures that the project is going to happen regardless of environmental, engineering or social negative impacts because the EIS produced by the proponent is tailored to gloss over the real detriment potentials and the Federal Government is dishonestly supporting the project. I want the NSW Planning Department and all other NSW Authorities to apply full scrutiny and uphold the rights of NSW residents to a fair process result by presenting a full list of genuine conditions that protect the society and environment of the Liverpool NSW Region and the Highly Valuable Georges River.

My husband and I grew up in Moorebank and have since purchased property in Chipping Norton, where we are raising our young family. We also run a small business in Chipping Norton and both our children attend local schools.

We love this area; it's a family-friendly community and we plan on eventually building a new home in Brighton Lakes. We plan on being here for the long-term!

Having both lived in the area all our lives, we have supported the positive changes that have been made to our community including new schools, shops, businesses, sporting grounds and parks. We have always been passionate about positive development and look forward to the Moorebank Marina being built as the Georges River is an under-utilised asset in this community.

The planned Transport Intermodal is at odds with all of positive things that our community has to offer. I oppose the Moorebank Intermodal proposal for the following reasons:

The site identified for the Moorebank intermodal is the wrong location for such a facility. It is situated on 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 has the capacity to house 40,000 people.

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.

The Auditor-General's report recently released shows a target of 800,000 TEUs to be moved to and from NSW Ports by rail in 2020. In a recent Sydney Morning Herald article, J Wiggins wrote 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'. 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 NSW Long Term Transport Master plan states there are significant challenges in using infrastructure that is shared between freight and passenger journey such as the current rail lines. This also supports a purpose built facility at Badgerys Creek to suit the future freight needs and targets of NSW.

The T1 Western line was identified in the Auditor-General's report as a poor performer in on-time running, while the T2 Airport and T2 Inner West & South lines performed better in this area. This suggests that the Moorebank location would be better suited to residential development than to heavy industry.

The traffic congestion in the area, particularly on the M5 and Hume Highway, indicates that additional heavy vehicle movements in this area would be detrimental to the road network. The Planning and Assessment Commission have already recognised traffic congestion in the area as a significant factor. Another reason to move the proposal to Badgerys Creek.

It is well known that truck drivers regularly ignore road rules and use excessive speed to meet deadlines. With the increased number of trucks in this area, members of the community are placed at a greater risk.

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.

Moorebank is no place for a Transport Intermodal. It is a family-friendly community with a lot more potential than a Transport Intermodal.

I believe the building of the intermodal at Moorebank will have a detrimental impact on my community. This area will be significantly impacted by noise and pollution with the onslaught of heavy vehicles using our roads. Please consider another site for this proposed project. Badgery's Creek has been presented as one option and I would ask that this be looked into as a better alternative site.

I support the Intermodel at Badgerys Creek, and NOT in Moorebank

The proposed intermodel at Moorebank does not have the infrastructure to support it and the already congested roads will have their capacity pushed to the limit. Badgerys Creek is a better option as it will then be able to be a true intermodel for air, road and rail.

The intermodal should not be developed at Moorebank, instead should be developed at Badgerys Creek Airport where it would be more conducive than at Moorebank.

I can not believe that the government is seriously thinking about building a freight terminal right beside a river. It is really having no vision and it is definitely not giving a fair go to the west. There is absolutely no common sense to this decision. It will penalized south west Sydney. Why do this, when there is other options?During that time, in Parramatta there are talking about cleaning up the Parramatta river so that people could eventually swim in it. But in south west Sydney the government wants to approve the construction of a freight terminal directly on the river...ridiculous. I live in Glenfield, and I know that we will have negative impact from that freight terminal. Are you really thinking about the people living around the area? It's an area that is transforming positively and you will kill it. Shame on you if you decide to go ahead with this project.

As a resident of the South West Region I write to register my strong opposition to the location of the intermodal freight terminal at Moorebank. Badgerys Creek is far more suitable the roads are already there, the Government owns the land, it makes far more sense to use Badgerys Creek the airport the rail way will accommodate the the intermodal freight .Please make the right decision for the South West Region don't approve the Intermodal at Moorebank.

MIT submission Dec 2014

JOBS
One of the selling points for this proposal is the apparent large number of jobs for the people of the area. This is false advertising as everybody knows that jobs will be awarded on the basis of skill and experience, not location of where one lives.

It's anticipated 1650 full time jobs will be created during construction, and a further 1,700 people could be employed in the Liverpool region once the project is up and running.

Since a technology park or commercial development could employ 15,000 people on that block of land, 1700 jobs in the region, not even at the terminal, but every related industry from the lunch shop to the warehouse to the trucks that are going to congest local roads. That's over 13,000 local people forced to catch the overcrowded trains into town or drive to North Ryde or Rhodes or Mascot because the government doesn't want them to work locally.
This terminal robs around 13,000 local people of the opportunity to work in the local area. A commercial development of a similar density to Rhodes or Macquarie Park could easily accomodate 15,000 office workers on the site and with a station just across the river all that's needed to reduce the traffic is a foot bridge.

Many local residents have raised concerns about the likelihood that other land uses, such as commercial land uses, could provide many more jobs. At the PAC meeting we heard just how much worse a container terminal is as a source of jobs than a commercial development on a hectare for hectare basis.

What shocked me was hearing how the terminal actually takes jobs away from the local area!

If the terminal goes ahead, then it is reasonable to think that light industrial areas will be converted to warehousing. All of those containers have to go somewhere right? But large warehouses employ fewer people per hectare than light industrial developments - each small manufacturer and panel beater, and so write more pay cheques at the end of the week than a huge warehouse does.


TRUCKS OFF ROADS LIE
Another selling point for this proposal has been the false statements that it will take trucks off the M5 motorway between Port Botany and Moorebank. This falsity was even admitted by the CEO of the MIT, Ian Hunt in one of the community consultations in Casula.
"A new freight terminal in Sydney's south-west will take 3,300 trucks off Sydney roads" has been a phrase used to push this proposal through.
Now this lie is so obvious that I can't believe they aren't ashamed to say it. Each container that arrives on a train has to get back onto the same truck that would have taken it away from Port Botany. That's a sum total of zero trucks taken off the road. They might be closer to their destination, but they are still on the road and they are on roads they weren't on before.

Another statement widely used had been
"Moorebank is the ideal location because of its close proximity to major connecting routes such as the M5, M7 and the Southern Sydney Freight Line"

If all of these trucks are disappearing from the roads, why the emphasis on proximity to the M5 and M7? The truth is they are taking trucks off the roads in their electorates and putting them somewhere else. This doesn't fix the problem, it just moves it.



COMMUNITY CONSULTATION

This has been not covered adequately and appropriately. The information sessions at Casula of which I attended 2, were inadequate.

Firstly the timing of some of these meetings was unfair. It coincided with the everyday family's dinner time or after school arrangements or most of all occurred during normal business hours or at times when residents might be travelling home from work.

Secondly the rushed approach by the lady acting as a mediator or host of the meeting was inappropriate. There were many people with questions and concerns which needed answering and naturally that would take a long time to answer all of them. But that is what the community consultation is supposed to be for. It was like the MIT group were trying to dodge the issues and not face the facts that this proposal is inappropriate for Moorebank on so many levels.

The phone book size of each technical EIS relating to the various fields of study is too much information for the everyday person to read and comprehend and therefore makes a detailed technical submission very difficult to produce.



NOISE

Moorebank Intermodal Company state that some mitigation will be required to protect residents of Wattle Grove and Casula from substantial noise levels. I question the words, "some mitigation" due to the fact that residents who live in the suburbs that surround the Port Botany Container Terminal have for some time suffered from sleep disturbance. The noise created by the terminal is so loud that people living up to 3 kilometres from the SITE are being kept awake of a night.
What hope do MICL have of mitigating the noise level on those residents living as close as 400 to 900 metres from their facility. "They are certainly with the fairies"

The EIS states "Negligible increase in noise levels from 8160 trucks, 5724 small vehicles and 39 freight trains per day". How can this be so? Especially to resident living within 400 metres from the site.



POLLUTION

Base line studies for air pollution need to be accurate and based on a wide selection of the community. The testing stations should be placed in schools, child care centres, aged care facilities, local streets, parks etc. The figures should be made available to the public via a website and should be updated on an hourly/daily basis as they do in Japan so the public is warned when the pollution levels get too high for people to be outside for too long.

THE FUTURE

Ian Hunt said during the community consultation that MICL are in negotiations with SIMTA as the preferred operator of the terminal. Whether it is SIMTA or another company that ends up operating it, MICL plan to sell it regardless he told us.
It has also been stated in an MICL booklet that "the plans will be revised by the terminal operator so the final design is likely to be different from the concept plan".
Does this mean that the operator of the terminal will not have to strictly stick to the design features that MICL have said will:
1) mitigate or control the noise
2) mitigate or control the traffic congestion
3) mitigate or control air pollution
4) enhance the community or be beneficial to the community ie in relation to aesthetic appeal or number of predicted jobs

MICL will set the guidelines or recommendations as stated in their EIS, Project Plan and Approval Stage Processes that are intended or estimated (note: not guaranteed) to mitigate (note: not remove) any negatives as a result of the operation being built to their plans. If this isn't terrible enough for the nearby residents or commuters to accept, there is no guarantee that the future operator, as a business trying to save money, will strictly follow all of the recommendations made in the EIS. It is expected that as a company trying to save money, that they will cut corners at the detriment of the nearby residents and commuters of South Western Sydney.

Who will monitor their movements and practices?

How will statistics such as air and noise pollution be monitored and made available to the public?

Can we trust this information to be an accurate representation of the area? Even the EPA get things wrong-this fact was displayed recently when noise pollution figures at Port Botany were shown to be incorrect and the local residents within a 3 km radius were affected

Who will be responsible for all the noise, pollution and traffic accidents due to the operator not sticking to the guidelines set in the EIS?

Who will be responsible for all the noise, pollution, traffic congestion and traffic accidents due to the experts in their field that have carefully worded their part of the EIS by using weasel words and phrases such as "expected to", "not expected to", "likely", "unlikely" etc to remove any responsibility from themselves once the negative impacts actually begin to take place?

"Mitigating the impact" will not "remove" the negative impacts this intermodal will produce if built at Moorebank which are far too many in number to make this proposal a viable and fair project to go ahead with.

An MIC booklet states " Most of the vehicles using the terminal...are expected to enter the terminal from , and exit to the north....Entrances to the terminal will be designed to prevent trucks travelling to/from the south".
To me this does not give any guarantee to what they are implying because it is only "expected to" (not guaranteed) and "will be designed" (does not mean will be built that way).
This sort of terminology throughout all of the documents does not give the local residents and commuters any sense of security as to what they can expect in the future should this monstrosity be built.

On the same page, "the terminal is likely to have a small impact on vehicle speeds on the M5 Motorway, Hume Hwy and other roads near the terminal. Some local intersections may experience a slightly longer delay time. These impacts will be further investigated in the EIS for the terminal's project approval".
This message is subjective. The words "small" and slightly longer delay time" might mean something totally different to the roads expert writing the EIS verses the commuter who uses the local roads on a daily basis. I also find it hard to believe that only small increase in delay at intersections will be experienced as a result of the terminal's operations in the year 2030 given the volume of vehicles expected to use this site on a 24 hour basis..


Who will pay for all the upgrades to the roads (not on Moorebank Ave) that will be required should this intermodal go ahead? I can see a blame game will start to occur and nothing will get done and commuters will suffer.
Upgrades to roads from Anzac Road to Newbridge Road via the intersections of Wattle Grove Drive, Nuwarra Road, Heathcote Road, Brickmakers Drive have not been mentioned in any literature. Trucks and smaller vehicles will use these roads and nothing has been said about upgrading them to cope with the traffic generated from the intermodal.




Other more appropriate locations have been suggested but everyone seems to be turning a blind eye and going with a poorly considered and ill-conceived plan. Badgerys Creek and Eastern Creek do not cause the same impacts and would make far more sense.

MIT submission Dec 2014

JOBS
One of the selling points for this proposal is the apparent large number of jobs for the people of the area. This is false advertising as everybody knows that jobs will be awarded on the basis of skill and experience, not location of where one lives.

It's anticipated 1650 full time jobs will be created during construction, and a further 1,700 people could be employed in the Liverpool region once the project is up and running.

Since a technology park or commercial development could employ 15,000 people on that block of land, 1700 jobs in the region, not even at the terminal, but every related industry from the lunch shop to the warehouse to the trucks that are going to congest local roads. That's over 13,000 local people forced to catch the overcrowded trains into town or drive to North Ryde or Rhodes or Mascot because the government doesn't want them to work locally.
This terminal robs around 13,000 local people of the opportunity to work in the local area. A commercial development of a similar density to Rhodes or Macquarie Park could easily accomodate 15,000 office workers on the site and with a station just across the river all that's needed to reduce the traffic is a foot bridge.

Many local residents have raised concerns about the likelihood that other land uses, such as commercial land uses, could provide many more jobs. At the PAC meeting we heard just how much worse a container terminal is as a source of jobs than a commercial development on a hectare for hectare basis.

What shocked me was hearing how the terminal actually takes jobs away from the local area!

If the terminal goes ahead, then it is reasonable to think that light industrial areas will be converted to warehousing. All of those containers have to go somewhere right? But large warehouses employ fewer people per hectare than light industrial developments - each small manufacturer and panel beater, and so write more pay cheques at the end of the week than a huge warehouse does.


TRUCKS OFF ROADS LIE
Another selling point for this proposal has been the false statements that it will take trucks off the M5 motorway between Port Botany and Moorebank. This falsity was even admitted by the CEO of the MIT, Ian Hunt in one of the community consultations in Casula.
"A new freight terminal in Sydney's south-west will take 3,300 trucks off Sydney roads" has been a phrase used to push this proposal through.
Now this lie is so obvious that I can't believe they aren't ashamed to say it. Each container that arrives on a train has to get back onto the same truck that would have taken it away from Port Botany. That's a sum total of zero trucks taken off the road. They might be closer to their destination, but they are still on the road and they are on roads they weren't on before.

Another statement widely used had been
"Moorebank is the ideal location because of its close proximity to major connecting routes such as the M5, M7 and the Southern Sydney Freight Line"

If all of these trucks are disappearing from the roads, why the emphasis on proximity to the M5 and M7? The truth is they are taking trucks off the roads in their electorates and putting them somewhere else. This doesn't fix the problem, it just moves it.



COMMUNITY CONSULTATION

This has been not covered adequately and appropriately. The information sessions at Casula of which I attended 2, were inadequate.

Firstly the timing of some of these meetings was unfair. It coincided with the everyday family's dinner time or after school arrangements or most of all occurred during normal business hours or at times when residents might be travelling home from work.

Secondly the rushed approach by the lady acting as a mediator or host of the meeting was inappropriate. There were many people with questions and concerns which needed answering and naturally that would take a long time to answer all of them. But that is what the community consultation is supposed to be for. It was like the MIT group were trying to dodge the issues and not face the facts that this proposal is inappropriate for Moorebank on so many levels.

The phone book size of each technical EIS relating to the various fields of study is too much information for the everyday person to read and comprehend and therefore makes a detailed technical submission very difficult to produce.



NOISE

Moorebank Intermodal Company state that some mitigation will be required to protect residents of Wattle Grove and Casula from substantial noise levels. I question the words, "some mitigation" due to the fact that residents who live in the suburbs that surround the Port Botany Container Terminal have for some time suffered from sleep disturbance. The noise created by the terminal is so loud that people living up to 3 kilometres from the SITE are being kept awake of a night.
What hope do MICL have of mitigating the noise level on those residents living as close as 400 to 900 metres from their facility. "They are certainly with the fairies"

The EIS states "Negligible increase in noise levels from 8160 trucks, 5724 small vehicles and 39 freight trains per day". How can this be so? Especially to resident living within 400 metres from the site.



POLLUTION

Base line studies for air pollution need to be accurate and based on a wide selection of the community. The testing stations should be placed in schools, child care centres, aged care facilities, local streets, parks etc. The figures should be made available to the public via a website and should be updated on an hourly/daily basis as they do in Japan so the public is warned when the pollution levels get too high for people to be outside for too long.

THE FUTURE

Ian Hunt said during the community consultation that MICL are in negotiations with SIMTA as the preferred operator of the terminal. Whether it is SIMTA or another company that ends up operating it, MICL plan to sell it regardless he told us.
It has also been stated in an MICL booklet that "the plans will be revised by the terminal operator so the final design is likely to be different from the concept plan".
Does this mean that the operator of the terminal will not have to strictly stick to the design features that MICL have said will:
1) mitigate or control the noise
2) mitigate or control the traffic congestion
3) mitigate or control air pollution
4) enhance the community or be beneficial to the community ie in relation to aesthetic appeal or number of predicted jobs

MICL will set the guidelines or recommendations as stated in their EIS, Project Plan and Approval Stage Processes that are intended or estimated (note: not guaranteed) to mitigate (note: not remove) any negatives as a result of the operation being built to their plans. If this isn't terrible enough for the nearby residents or commuters to accept, there is no guarantee that the future operator, as a business trying to save money, will strictly follow all of the recommendations made in the EIS. It is expected that as a company trying to save money, that they will cut corners at the detriment of the nearby residents and commuters of South Western Sydney.

Who will monitor their movements and practices?

How will statistics such as air and noise pollution be monitored and made available to the public?

Can we trust this information to be an accurate representation of the area? Even the EPA get things wrong-this fact was displayed recently when noise pollution figures at Port Botany were shown to be incorrect and the local residents within a 3 km radius were affected

Who will be responsible for all the noise, pollution and traffic accidents due to the operator not sticking to the guidelines set in the EIS?

Who will be responsible for all the noise, pollution, traffic congestion and traffic accidents due to the experts in their field that have carefully worded their part of the EIS by using weasel words and phrases such as "expected to", "not expected to", "likely", "unlikely" etc to remove any responsibility from themselves once the negative impacts actually begin to take place?

"Mitigating the impact" will not "remove" the negative impacts this intermodal will produce if built at Moorebank which are far too many in number to make this proposal a viable and fair project to go ahead with.

An MIC booklet states " Most of the vehicles using the terminal...are expected to enter the terminal from , and exit to the north....Entrances to the terminal will be designed to prevent trucks travelling to/from the south".
To me this does not give any guarantee to what they are implying because it is only "expected to" (not guaranteed) and "will be designed" (does not mean will be built that way).
This sort of terminology throughout all of the documents does not give the local residents and commuters any sense of security as to what they can expect in the future should this monstrosity be built.

On the same page, "the terminal is likely to have a small impact on vehicle speeds on the M5 Motorway, Hume Hwy and other roads near the terminal. Some local intersections may experience a slightly longer delay time. These impacts will be further investigated in the EIS for the terminal's project approval".
This message is subjective. The words "small" and slightly longer delay time" might mean something totally different to the roads expert writing the EIS verses the commuter who uses the local roads on a daily basis. I also find it hard to believe that only small increase in delay at intersections will be experienced as a result of the terminal's operations in the year 2030 given the volume of vehicles expected to use this site on a 24 hour basis..


Who will pay for all the upgrades to the roads (not on Moorebank Ave) that will be required should this intermodal go ahead? I can see a blame game will start to occur and nothing will get done and commuters will suffer.
Upgrades to roads from Anzac Road to Newbridge Road via the intersections of Wattle Grove Drive, Nuwarra Road, Heathcote Road, Brickmakers Drive have not been mentioned in any literature. Trucks and smaller vehicles will use these roads and nothing has been said about upgrading them to cope with the traffic generated from the intermodal.




Other more appropriate locations have been suggested but everyone seems to be turning a blind eye and going with a poorly considered and ill-conceived plan. Badgerys Creek and Eastern Creek do not cause the same impacts and would make far more sense.

Introduction:
I understand little about the economy of attempting to situate a freight hub at a point where there are major arterials, but the question will be discussed "At what cost?" The upgrade of thirty six intersections? The invasion and pollution of a residential area that does not consume the goods? How can this make economic sense? Is it because the land was a snap? The decision to build at Moorebank was made years ago, and unfortunately, is outdated. If trends in metropolitan growth, goods consumption, modern infrastructure project construction and access to arterials/transport were considered, would Moorebank still be best?
In an ideal scenario, an intermodal proximal to road arterials, railway connection, a port, an airport, all being proximal to the consumption and distribution of goods would tick some serious boxes and be cost effective. And if there were no ill effects for the environment immediately proximal to the project, there would be no objection proximal to the project. This is why I write.


Reasons why the proposal is the right idea:
1. To satisfy the growing needs of goods forwarding/logistics of Sydney
2. To have a development proximal to connecting major arterials to reduce travel time and minimise congestion
Employment opportunities
3. Conceptually, to have an intermodal that utilises rail rather than road to transport freight. This is fantastic for many reasons such as congestion abatement and net energy expenditure, but is negated somewhat due to its distal location from the foci of goods utilisation.
4. The site appears to have good connectivity options by rail and road


Reasons why this proposal is inadequate:
1. Heritage destruction
The plan does not entertain the idea of preservation of military heritage predating this development.
2. Property values
As part of the residual level of impact (section 8.2.1 of NSW Industrial Noise Policy) I do not believe that consideration has been given to property values in the surrounding suburbs that will be impacted directly and indirectly by this project. The proponents will not consider regulating noise or air emissions from vehicles associated with the development equating to no consideration. There are residents who have invested knowing nothing of this proposal several years ago who feel cheated by this development proposal, and given its proximity and effects on their quality of life, rightly so.
3. Increased traffic congestion
No need to expand on this point, as the negative traffic effects due to increased vehicular movements locally and on arterials such as M5, and queuing times at lights will be experienced. Also, there is the reassessment of traffic light duty, which will cause increased waiting times for commuters, workers and trucks alike.
4. Light spill
Although there are mutterings of "mitigation", I, on behalf of the local community, certainly do not look forward to the extra light of an evening. This also will impact behaviours of nocturnal animals associated with the underdeveloped site.
Extra taxpayer cost associated with development
It is known that the number of intersections requiring upgrades for this proposal numbers over thirty, confirmed by the proponent's traffic modellers and also by independent modelling by members of RAID (Residents Against Intermodal Terminals). Who is going to pay for this? I believe there is no doubt. The road and intersection upgrades alone will result in significant cost.


Reasons why this is unacceptable:
1. Poor location choice
Without a doubt, this is the wrong position given consumption of the goods. The net energy expenditure and traffic movements are excessive and not economical in comparison to a more viable alternative eg Badgery's Creek (potential true intermodal), Eastern Creek (more efficient intermodal given goods destination and land zoning).
There will be excessive impact on moderate density population (proximal local residents), who will be exposed negatively by the proposal every hour of every day of every year.
The outdated location has not taken into consideration more recent civil projects including rail, road, and airport developments which are currently being constructed or in the process, yielding more common sense alternatives than Moorebank.
2. Compounding negative effects of SIMTA and MICL proposals with land rezoning
Subversively the developments have been staggered in their presentation to the public, in an attempt to dupe the public into the idea that the impacts are essentially halved and therefore half as significant. Unfortunately the effects of the development proposals will compound, and either proposal does not appear to include in its environmental impact data the existence or effects of their proposed neighbour (refer noise).
3. Risk to community maximised
If one can draw their attention to the risk matrix which offers through a likelihood and severity analysis a degree of "harm" for an activity. This process has been dutifully conducted for a number of facets of the project including environmental impacts. Given the localised and continuous release of particulate matter and polycyclic aromatic hydrocarbons from diesel combustion, I believe that the risk matrix should have been assessed as probability "almost certain" and consequence "severe", giving the resultant risk as "very high," which, under any circumstance would indicate neglect if the activity were to progress - a point which even the proponents tout. I would anticipate multiple but localised fatalities in the medium to long term, mostly due to the next point.
4. Lack of air quality considerations
There is no doubt that there will be medium to long term health effects of such an operation given its proximity to pre-existing residential settlement.
There are measureable indicators for air quality, and there are more elusive chemicals that are produced by the incomplete combustion of diesel such as 3-nitrobenzanthrone, nor 4-nitrobiphenol, nor benzopyrene which currently have no regulations or guidelines regarding exposure, along with other known carcinogens. (Source: SA Health). This effect will be magnified by the quantity of emission and the lack of convection and circulation of the ambient air due to topographical and meteorological considerations of the Liverpool basin.
Intake of PAHs from contaminated soil may occur via ingestion, inhalation or dermal (skin) exposure to contaminated soil/dust, and from inhalation of PAH vapours. Tilling of dry soil can result in ingestion of small but measurable amounts of carcinogens. (Source: SA Health)
This point is critical - since the study of the detrimental health effects of nanoparticles is still in its infancy, and the nature and extent of negative health impacts from diesel exhaust continues to be discovered.
The transport hub has realistic potential to gravely harm the health of the workers employed on site, workers at the NDSDC (National Defence Storage and Distribution Centre), surrounding commercial venture employees, with the most impacted group being surrounding residents.
5. Increase in patient load on the health system
There is a city in central Queensland called Gladstone that is a heavy industry town and has been for years, with a coal fired power generation station (the largest one of its kind in the southern hemisphere for its time) and companies such as Queensland Alumina Limited which have been present for over forty years. It has been known that these industries have been heavy particulate polluters with coal dust and alumina dust being released with reasonable consistency into the atmosphere. In a report commissioned by Queensland Health, it was found that between 1996 and 2004 Gladstone had a chronic lymphocytic leukaemia (CLL) rate twice that of the state average. These incidences have occurred with medium term regular exposure to pollutants, which is what you will expect with this proposal. It will not only affect workers of industry, but also residents. The real cost may be incalculable in the short term.
To take a risk based approach, I can not help but believe that the effects of development-associated air pollution will be more ubiquitous and far reaching than modelling accounts for, impacting quality of life for residents, and further burdening acute, chronic and palliative care for disorders involving the lung at local hospitals such as Liverpool.
6. Inability to regulate incoming/outgoing emissions/pollution
The proponents of the development are not capable of addressing the pollution from vehicles accessing and egressing the site, and have stated that any upgrades of, for example, trucks to a five or six star Euro emissions level for particulates, will be the choice of the individual operators. There is no plan for the proponent to retrofit vehicles to minimise or reduce pollutants or noise. Effectively this is ratifying the gross pollution of the site, whilst accepting no responsibility and focussing furthermore on the (lack of) impact of the terminal.
7. Nuisance noise
As outlined by the EPA guidelines for noise emission, I fail to see best management practice (BMP) or best achievable technology economically achievable (BATEA) strategies fully (or even partially) and appropriately employed in this proposition to mitigate noise to residential areas from;
1) Traffic, hoists/cranes, forklifts operating on site
2) Trucks and cars accessing and egressing site
3) Trains accessing and egressing site
The proponents do not suggest any noise buffering on the eastern side of Moorebank Avenue for example. We are interested in effective noise buffering, not a token investment to comply with requirements. There has been suggestion that continuous emissions monitoring will occur, but no mention of what operational changes will be actioned if exceedances are encountered. Ie what are the response mechanisms for excess noise pollution?
Forget not the recent media coverage of noise impacts of rail wheel squeal from the Botany container handling facility where nuisance noise has been reported by residents over 3km away, and we are talking of introducing this type of issue within 500m of residents?
According to the National Institute for Occupational Safety - NIOSH - noise exposure should be controlled so that the exposure is less than the combination of exposure level. A valid question is, "Was the noise assessment of the MICL and SIMTA developments considered as a combined exposure in the EIS?"
Inadequate provisions for the control of noise at its source, its transmission to, and its reception at residential areas is identified.

8. Pest species introduction
Given the proximity to both a terrestrial and an aquatic environment (Georges River), I ask what pest species of vermin, beetles, borers, fungus, parasites and so forth will be inadvertently released into the natural habitat through the transportation and storage of containers at the proposed facility. I know not of a biological quarantine area that is proposed that addresses potential threats to the ecology of the surrounding habitat. There is ample opportunity for pest organism release into the adjacent land which is unique to this site given the surrounding geography (ie bushland and estuarine river system).

9. Maximum detrimental effects for moderately populated residential area
Let me get this straight. With the subversive, yet forceful "application" for land rezoning to cater for such a development, this is madness! This development is essentially proposed to be built and operate adjacent a residential precinct, and is neglecting the quality of life and health of the residents of surrounding residential suburbs. Residents have settled in the area in good faith in what was a desirable quiet area, but are going to be cheated the lifestyle they deserve by this proposition.
The proposition is too proximal to neighbouring establishments - from 400m - exposing residents 24 hours a day, seven days a week.
Population density is close to 30 people per hectare and growing - high number of residents will have exposure and be affected, and in the medium to long term this will reflect unfavourably at Liverpool Hospital.
The reclassification of the land is a significant oversight of utilisation of the land, and it can not be said that there has been consideration for residents, commuters, or the Government's affordable housing scheme for example.
How many people is it anticipated that this project will adversely affect? The answer is "Too many," given its proposed location and proximity to residents.
10. Poor land utilisation
Other options could be to rezone the area a sanctuary or green space and rejoice in its underdevelopment, or develop it into another less pervasive and polluting venture whilst solving some Sydney housing issues, or create more employment by creating a commercial venture, or even better, return services to the community such as a library/arts/fire brigade. There are many alternate less destructive options.

Conclusion:
The health cost to a moderately populated community through operational pollution that this proposal will introduce to the residents, the reduction of the quality of life for residents and commuters, the burdensome cost to ratepayers, the truth that the development is no longer appropriate at Moorebank are significant counterarguments for the development of this proposed State Significant Development at its current location in south western Sydney.
The proposal needs to be located;
1) logically where consumption of goods occurs,
2) where there is lower population density i.e. less people that are impacted, and
3) where an intermodal should be located after a modern infrastructure assessment.
Only then will a valid and well planned proposal evolve.
I do not deem the employment opportunities and perceived value of the proposal's location to outweigh the detrimental health effects and risk of the development to the local community. Secondary topical arguments exist such as disruption to commuting, excessive public infrastructure expenditure, public nuisance and heritage destruction to name a few. The reduced health impact and positive economic impact at a location that provides a minimum amount of impact to the least amount of people needs to be considered. This is defined as risk.
If the development is to remain at the proposed site, the deleterious effects of the project should be mitigated sparing no expense for the health and quality of life for the many residents in surrounding suburbs who have been duped by inappropriate land zoning and will be adversely and extensively affected by this project. This is undoubtedly a nuisance proposal amongst suburbia at the Moorebank site, and the very least that the proponents can do is minimise the harm to the local community and the environment given its ubiquitously polluting and cost ineffective nature.
Seemingly, this is a short sighted attempt to justify an economic outcome for the state at the grave expense of the local community - the effects of which will be seen in all processes from its construction and operation to the medium term public health morbidity effects that will only be confirmed in years to come.