Moorebank Intermodal Precinct West - Concept & Stage 1

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Application number: SSD 5066/EPBC 2011/6086
Project name: Moorebank Intermodal Environmental Impact Statement
Objection to the Moorebank Intermodal Proposal
Name: Dominic Scutella
Address: 118 Daintree Drive Wattle Grove NSW 2173
Phone: 0408 9731 97
Email: [email protected]

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.

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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

Application number: SSD 5066/EPBC 2011/6086
Project name: Moorebank Intermodal Environmental Impact Statement
Objection to the Moorebank Intermodal Proposal
Name: XXXX XXXX
Address: XXXX XXXX Wattle Grove NSW 2173
Phone: XXXX XXXX
Email: XXXX XXXX
Signature:
I want my name released online with my submission: Yes X No

I oppose the Moorebank Intermodal proposal and Environmental Impact Statement for the following reasons:
The Moorebank intermodal will place more 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, 5,000 cars per day will need to access the site.
The Moorebank intermodal will not be an economically viable investment for the Federal Government and the state of New South Wales. The proposal should be relocated to Badgerys Creek in order to reduce supply-chain costs and cater for future urban growth.
Traffic
* The proposal will move the congestion from Port Botany to Moorebank, which is already congested;
* The Modelling does not cater for the predicted growth of the region;
* The intersections and road network are already congested, the proposal will increase traffic delays;
* Trucks `weaving' onto and off the M5 between the Moorebank and Hume Highway interchanges will cause accidents and present a danger to my family; and
* Trucks parking and taking short‐cuts through the nearby streets will make the area unsafe for my family and friends.
Noise
* There is no noise wall along the rail corridor along the Georges River, so noise will carry particularly at night;
* There will be no way to mitigate noise from the unloading/loading and movement of containers within the terminal, especially for residents living within 400 metres of the site;
* There will be no way to mitigate noise from the breaking and shunting of trains which will need to happen on site;
* There will be wheel squeal due to the tight radius curves needed for trains to enter and exit the site; this will keep me awake at night; and
* Residents up to 3km from Port Botany are kept awake at night, I don't want this for my family.
Air quality
* There will be Increased diesel fumes in the community generated from locomotives, heavy vehicles and other heavy equipment used on site, these fumes are carcinogenic;
* My family and friends will develop cancer or other health problems from the increased diesel fumes;
* The South‐west Sydney is already heavily polluted due to the topography of the area;
* There will be dust and odour generated from this site, particularly during the construction period;
Heritage
* We have a strong military history in this area and we are proud of our heritage; removal of heritage features from the site will break ties for the community.
Location
* The site is surrounded by residential development, this site should have never been selected due to the young families who have settled in this area;
* This area is full of quiet, leafy suburbs with strong community connections, this development will be detrimental to the area and depreciate its value; and
* Other sites are preferable, such as Badgerys Creek, which does not have residential development nearby.
Contamination
* The unloading of imported containers in this area will have the potential to destroy native flora and fauna; and
* The unloading of imported containers in this area will have the potential to destroy the Georges River.
MICL and SIMTA Proposals
* There has been a lot of confusion around the fact that two proposals have been proposed for one area (SIMTA and MICL).
* The cumulative impacts of the two proposals have not been adequately explained or addressed by the proposals; and
* There is confusion as to the total traffic generated from the two proposals, as the modelling for each is different.
I support strategic planning and good land use. The intermodal development should be moved to a non-residential area, like Badgerys Creek.
Please reject this proposal on the grounds that it is not in the public interest with other better suited sites available.

I have a more detailed letter that can be viewed in the file below. I am against the inter-modal at Moorebank as it will be too large. It will be too noisy and too pollutive. It will also reduce the amenity of the Casula Powerhouse Art Centre, the surrounding park lands and the Georges river. The surrounding suburbs will also have a further increase in traffic congestion. There has been a lack of real consultation with the residents and this inter-modal has been rammed up our throats. A large inter-modal should not be placed next to well populated suburbs or a river.

Please refer to uploaded document.

I would like to object to this project and attached is my submission

See attached file

I would like to submit my objection to this proposal

Please see attached.

Please see attachment

My submission is attached

Attached is a pdf response objecting to this proposal.

Introduction:
I understand a 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 radial 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. This is why I write.
Reasons why the proposal is the right idea:
To satisfy the growing needs of goods forwarding/logistics of Sydney
To have a development proximal to connecting major arterials to reduce travel time and minimise congestion
Employment opportunities
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.

The site appears to have good connectivity options by rail and road


Reasons why this proposal is inadequate:
Heritage destruction
The plan does not entertain the idea of preservation of military heritage predating this development.
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.
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.
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:
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.
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).
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.
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.

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.

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.
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.

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 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).
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.
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.

I OBJECT THIS, AS TRAFFIC IN M5 ALREADY WORST

I object against the Moorebank Intermodal Terminal because it is in the wrong location. It does not serve the existing or future freight markets.

It will be located near residential areas, and there is no transport infrastructure for the trucks to leave the Intermodal.

Further comments are in the attachment.

I object to the proposal.
See attachment for more details