State Significant Development
Moorebank Intermodal Precinct West - Concept & Stage 1
Liverpool City
Current Status: Determination
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Moorebank Intermodal Precinct West - Concept & Stage 1
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Note: Only documents approved by the Department after November 2019 will be published above. Any documents approved before this time can be viewed on the Applicant's website.
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Inspections
25/06/2020
9/07/2020
11/11/2020
11/11/2020
11/07/2024
27/02/2024
Note: Only enforcements and inspections undertaken by the Department from March 2020 will be shown above.
Submissions
Jenny Lukunic
Object
Jenny Lukunic
Message
- Enfield has an unused Intermodal - why is this?
- it will add excessive traffic on roads which are already congested to their capacities
- this is an area of families with young children and we are very concerned at the pollution this amount of trucks will create
- fine particulate matter from trucks is a major concern in regards to health
- the area is changing with new residential developments everywhere
-trucks will end up using residential back roads to get around congestion - how can you prevent this
- why are these industrial sites in this day and age being placed next to rivers - shouldn't we be cleaning up the rivers not polluting them further
- Badgerys creek is a better option where it will also be linked to the airport.
Name Withheld
Object
Name Withheld
Message
Name Withheld
Object
Name Withheld
Message
The reasons I object are:
· Local roads will be choked by large container trucks increasing travel time and reducing road safety
· Air pollution will be greatly increased affecting the health of my family and local residents
· the light and noise pollution generated by the Intermodal operating 24 hours, seven days a week
· the destruction of military heritage;
· the destruction of native flora and fauna habitat;
· the negative environmental impact on the Georges River;
· the diesel pollution from the freight trains;
· the location of the Intermodal is surrounded by a high density residential area, this includes pre-schools, primary and high schools and a nursing home;
· the freight trains to and from the intermodal will negatively impact the local arts and cultural centre - Casula Powerhouse;
· the negative impact on the value of residential properties surrounding the intermodal site; and
· the negative impact it will cause to the lifestyle of the community.
David Cowell
Object
David Cowell
Message
The reasons I object are:
· Local roads will be choked by large container trucks increasing travel time and reducing road safety;
· Air pollution will be greatly increased affecting the health of my family;
· the light and noise pollution generated by the Intermodal operating 24 hours, seven days a week;
· the destruction of military heritage;
· the destruction of native flora and fauna habitat;
· the negative environmental impact on the Georges River;
· the diesel pollution from the freight trains;
· the location of the Intermodal is surrounded by a high density residential area; and
· the negative impact it will cause to the lifestyle of my family.
Name Withheld
Object
Name Withheld
Message
Having bought residential land from the government in Wattle Grove in 1993, I never thought that such a bad development would happen and was certainly never told by the developers or the Government that such a thing could or would be built.
These terminals are just to close to our community , just 400 metres
The noise and pollution from these terminals 24 hours a day as proposed or at all will be impossible to live with.
Already the noise from the near-by motorway is excessive during sleeping hours with unfavourable wind direction.
Just some of the issues unacceptable are --- and these can not be reduced to nill or mitigated to an acceptable level when so close to the residential areas.
1) Train wheel squeal operating on the very tight radius bends approaching and departing the site also within the sites, even if the train is moving very slowly this noise would be unacceptably bad due to the maximum wheel traction & friction at these low speeds, and this is proposed 24 hours a day.
2) Train shunting noise within the site through the still of the night and day from both old and new rolling stock.
3) Train noise on the new bridges over the river.
4) Greatly increased train Diesel engine noise particularly with our old engines and also new engines.
5) Increased Diesel pollution from these trains.
6) Noise from large elevated gantry cranes operating powerful high speed (or slow ) winches loading and unloading containers particularly in the middle of the night and day, this noise will travel far in the flat terrain and over the waters of the river.
7) Container crashing noises at put down and lifting, in the middle of the night.
8) Noise and pollution from thousands of extra, large container trucks and smaller vehicles operating on our local streets and nearby motorway at all hours of the day.
The Intermodal developers continually tell us that tey will be taking trucks off our roads, how can that be when there will be thousands more locally, also they contradict themselves by requesting alowace for unlimited truck movements on our motorway.
9) Noise and pollution from various methods of moving containers within the sites through day and night.
No amount of monitoring and mitigation of noise or pollution will fix the impact on the nearby communities and environment , we have already seen the true unacceptable impact on the communities sorounding the Port Botany site and the false and proven wrong monitoring there. All this will just be repeated here at Moorebank-- But on a larger scale.
It is unbelievable that massive terminals of this size and type ( or smaller ) can even be considered within the long established near-by residential area.This near pristine fresh water river front land should be used for residential & recreational use only and not for the purpose of heavy and polluting industry, destroying the quality of life for the long established residential community who paid a high price to the government for their land. For many residents, selling up and moving is just not an option given the reduced value of our properties due to the Intermodal Terminals, why just a few days ago our Prime Minister was howling in Parliament about the unacceptable possibility of people being forced to accept reduced property values.
Name Withheld
Object
Name Withheld
Message
Melinda Aylett
Object
Melinda Aylett
Message
Firstly, with the announcement of the merge of the SIMTA/MIC proposals into one large super terminal, I feel this DA/EIS should really become null and void. The proponents should have to submit a DA based on the one terminal and not seeking separate approvals, therefore trying to deceive the community as to the real impacts a super terminal will have on the local community. I think the residents of our local area at least deserve to have the impacts of a super terminal fully and properly examined before this is dumped on them.
The proponents have claimed there will be significant financial benefits to the local area, and the South West region as a whole. The job amounts this terminal will add vary, from 2000 up to 10,000. With proposed automation mentioned, taking noise emissions down 10 DBA with removal of alarms, it seems the plan is to fully automate at least some of the terminals operations, calling into question the number of jobs this terminal will provide. Only 40 operating jobs will be provided in SIMTA's stage one development, so it will be long into the future before any real economic benefit is felt by local service providers and residents, but will add extra trucks and pollution to already congested roads and air.
I am yet to understand how any of the proponents can continue to claim it is going to take trucks off the M5. All that will happen will be trucks off roads at Port Botany, and moving them to Moorebank and surrounding suburbs. Also, how are empty containers to return to Port Botany? This will add additional trucks on the road back to Port Botany, which I don't feel has been taken into account in any transport modelling. So any so called environmental benefit will be limited at best, taking into consideration it is only shifting the trucks from one area to another, plus adding emissions from locomotives.
The current existing intermodal terminals in Sydney have the capacity to deal with the projected demand of rail transported freight past 2020, meeting government strategies. The demand for freight transported from Port Botany in this manner has to this day not really been tested. With the construction of the Westconnex, I doubt that companies with warehouses based at Eastern Creek and Erskine Park especially will pay for the double to triple handling of their freight, when they can easily send there own trucks to Port Botany to retrieve their freight and return it directly to their warehouse. My father and husband have worked in the freight industry for the majority of their working lives, and have intimate experience with this industry. No real demand has been shown for a intermodal of this size, as the super terminal is seeking ultimate approval for 1.55 million TEU per annum to economically viable, meaning this could turn into a very expensive white elephant. This alone fails the impact to benefit ratio test, showing it is not in the publics best interest.
There is also no guarantee that trucks will not use local roads to rat run when there is heavy local traffic. This has happened in my own residential street, CHRISTIANSEN BVD, when there has been heavy traffic on local roads. Heavy vehicles carrying containers should not be on local roads populated with young children. The recent accident of a container truck overturning at Auburn recently just highlights the increased risks to local residents of potentially fatal accidents. I hold no confidence in monitoring of this by government agencies.
I find it appalling that on one hand, governments are encouraging young families to consider moving to the south west and investing their life savings into building a new house then, on the other hand, dump new heavy industrial into the area. This area has moved on from when this idea first came to fruition. We have a beautiful natural resource in the Georges River, and our governments should be looking to protect it, not destroy it. All residents of this country deserve to live a relatively quiet life, without having to constantly worry about the health and wellbeing of their families. Please, do not make Moorebank the dumping ground of Sydney, please reject this application and protect the long term wellbeing of the residents of South west Sydney.
Name Withheld
Object
Name Withheld
Message
Dawn Thompson
Object
Dawn Thompson
Message
The health issues it will cause in the community with the increased air pollution.
The increase in traffic in a long time established residential
Riverfront land is valued in all other areas of Sydney, why shouldn't people in the south west be able to use this community asset for recreation purposes
Michael Russell
Object
Michael Russell
Message
Michael Russell of 7 Buckland Rd Casula Secretary's Environmental Assessment Requirements.
Section 78A (8A) of the Environmental Planning and Assessment Act 1979 Schedule 2 of the Environmental Planning and Assessment Regulation 2000 Application Number SSD - 5066 In response to revised SEARS comments please see my response below:
Director Generals Requirements
future trends in container origin/destination in Sydney, intermodal capacity and demand, and identification of the terminal's freight catchment area and freight split; The MIC has not taken into account that Chullora Intermodal has just doubled its capacity by changing the cranes that move containers. There has been no investigation of the capacity of Chullora or Enfield terminals and the possibility that future innovations at either of these terminals will rob Moorebank of the line timeframe required to deliver TEU's to Moorebank. MIC has responded to community questions that there is very limited availability of freight services along the SSFL from Pt Botany to Moorebank ( Via Chullora and Enfield Yards)at that the capacity of the line from Pt Botany has limited there containers trains to 1.1million TEU's. If this information is true from MIC then Chullora, by the introduction of new cranes, has taken the spare capacity that MIC needs . The fact that Enfield is operating below predicted levels and also has the capacity to double its throughput like Chullora would mean that the available movements to MIC/SIMTA would be severely limited to less than 1m TEU's and therefore MIC/SIMTA would become economically un-economical.
an analysis of feasible alternatives to carrying out the development, having regard to its objectives, including the consequences of not carrying out the development; This has not been satisfactorily responded by MIC. They have ignored the requirement to show that Chullora and Enfield terminals are better placed to deliver much of MIC plans. Neither Chullora or Enfield will have a significant impact on local residents because both operate in commercial areas, unlike MIC which is planning its operations in the middle of family homes where there is no existing commercial premises. The Impacts of noise, and air quality have been estimated far in exceedance of standards published world health standards and use the much outdated Australian standards which are more than 10yrs old. The AS need to be updated to match or exceed WHO standards. The consequences if the project at MIC did not proceed would be taken up by Chullora, Enfield and future Badgergy's Creek operations. The maths and assumptions used by MIC are not true reflections of updatred technology and WHO standards.
an identification of how relevant planning, land use and development matters (including relevant strategic and statutory matters) have been considered in the impact assessment (direct, indirect and cumulative
impacts) and/or in developing management, mitigation, and monitoring measures, including 79C of the Environmental Planning andAssessment Act 1979 (EP&A Act), applicable State Environmental Planning Policies (SEPP) and Local Environmental Plans (LEP), andthe nature and extent of any prohibitions that apply to the developmentand demonstration that the site is suitable for the proposed use in accordance with SEPP 55; MIC has not shown the combined effect of both the SIMTA and MIC sites as one combined assessment.
\Nor have they taken into account any noise assessment outside of the immediate areas of the site. There has been no estimates of noise or pollution generated by 24/7 operation outside of the MIC site. When questioned about noise along the SSFL the MIC responded that it was not their problem as their brief was only for the MIC site and that any noise generated by addition operations of trains into MIC would be required to be conducted by ARTC as it held the operating License. The residents of Casula and assuming other areas have been verified by Railcorp as having excessive noise upto 40dba above recommended and Director Generals guidelines. ARTC recently installed the SSFL at Casula with promises to the community that where noise is excessive it would installl noise barriers and to limit the number of trains that were held to late night operations due the curfews installed by Railcorp and change them to daytime services so as not to disturb the sleep patterns of residents close to the rail lines. Levels of 103dba have been recorded by Railcorp during the night time which is more than 60dba above State Gov. recommended levels. The noise barriers were not installed because ARTC argued that the trains were being moved 5m away from residents homes and therefore the noise would be reduced. Trains are now operating at all hours with additional longer, faster operating freight trains. The response from ARTC is that the trains are no noiser than previous freight trains because the longer fast trains take the same time to pass the homes than the old short slower services.
a compilation of the measures proposed to mitigate any adverse effects of the development on the environment; MIC has provided construction noise modeling and operating noise models in the vicinity of Moorebank only. The MIC response to the DG's requirements does not take into account the cumulative effect of the MIC and SIMTA sites nor the ongoing operational noise. I would like to make an observation from the information provided that there is more environmental protection during the construction phase than during the operations phase. Why is it that the construction restrictions are so much more strigent than the ongoing operational environmental impacts of air and noise quality.
The EIS must also include:
* a detailed description of any rail link option, together with a detailed impact assessment for each option; Only southern option has been provided through the very sensitive Glenfield tip. A nortern opproach through Liverpool following the original train tracks into Holsworthy has not been considered. Most of the land is still available however some additional land will need to be purchased. The big advantage of the northern option along old tracks would be well away from both sensitive receivers being the residential homes and powerhouse arts centre.
* a health impact assessment of local and regional impacts associated with the development, including those health risks associated with relevant key issues; The issues of Noise and Air Quality have not been addressed to impact up to date technology but instead use standards that are more than ten years behind WHO standards. There is no benefits to the community in that this modern MIC facility will have automated cranes and therefore fewer jobs than Pt Botany. Massive amounts of vehicle movements will be introduced into the Liverpool precinct with only Moorebank Ave being upgraded. What are the advantages to the local community that the MIC development will bring.
* potential options for future ownership of the development; and * consideration of the cumulative impacts of this proposal with the adjacent SIMTA proposal.
MIC has not addressed the cumulative impacts along the roads or freight lines outside the immediate area of the MIC. The roads and rail tracks impacts of addition trains and trucks on the roads within the Liverpool precinct have not been advised, discussed or mentioned within any documents provided by MIC.
* the number of train and truck movements, origin and destination, time of movements, modal split targets, types of road transport likely to be used (for example B-Doubles) and the capacity of existing and proposed road and rail routes to handle predicted increases in traffic, based on appropriate empirical analysis and modelling, including freight and non- freight movements and vehicle utilisation; consideration of the cumulative impacts of this proposal with the adjacent SIMTA proposal and other existing and proposed freight distribution facilities in the locality and on local and regional road and rail networks; Response from MIC has been poor. Information from MIC indicates that the additional massive truck and smaller van movements will have only a 6 second impact at F level existing traffic intersections. This would be not be a true reflection considering one additional B double can be so slow moving from stationary position thru green traffic light can slow the cars behind it by some 20seconds based on average recordings conducted at intersection of M5 and Moorebank Ave.
* identification of required road and rail infrastructure upgrades within proximity of the site, including the M5 and M7 motorways and interchanges, the Moorebank Avenue / Heathcote Road intersection, the Moorebank Avenue / Newbridge Road intersection and Cambridge Avenue; The analysis has been poor in that vehicles have only been calculated along M5 , M7 and Moorebank Ave. If trucks were to find these roads blocked or congested then naturally they would take back streets through Liverpool to bypass the congestion. MIC response is it will be Liverpool Councils responsibility to alleviate and enforce road restrictions. This would crate a burden of responsibility on the council and the residents. MIC is shirking its responsibility in dealing with the issue of road congestion and road restriction enforcements.
* a consideration of road safety in the vicinity of the site including the identification of any `black spots'; MIC has to indicated only a few intersections would be effected yet other private traffic assessors have indicated up to 36 intersections would be downgraded to Level F which is significant delays.
Noise and Vibration - including but not limited to:
* assessment of the noise and vibration impacts from the development (on and offsite), including cumulative impacts from associated precursor activities, the Southern Sydney Freight Line and the SIMTA intermodal proposal on sensitive receivers;
No indication of noise or air quality along SSDFL of local raods have been provided to a level where the community can accept the assumptions on which MIC have based their limited responses.
* consideration of associated road and rail noise impacts; Nil provided outside the Morrebank area.
* the nature and sensitivity of, and impact to potentially affected receivers (including nearby residential areas of Moorebank, Wattle Grove and Casula, transport noise affected receivers and other sensitive land uses); MIC response was that there would be insignificant effects on sensitive receivers outside Moorebank locality.
* the consideration of relevant meteorological conditions and topographical features; and * taking into account the Interim Construction Noise Guideline (DECC 2009), NSW Industrial Noise Policy (DEC), Assessing Vibration: A Technical guideline (DECC 2006), NSW Road Noise Policy (DECCW 2011), and the Rail Infrastructure Noise Guideline (EPA 2013).
Existing guidelines recommend no more than 40dba for sensitive receivers bedrooms between nightime hours. Existing Railcorp reports indicate existing levels are more than 40dba above recommended levels and MIC report that their 24/7 operations of longer faster and more often train and truck services will have no significant effect.
I would like to request that the existing SIMTA and MIC sites need to be combined into one EIS for both sites and that the existing two separate EIS reports be declined as suitable for acceptance for both sites when combined. I ask the DG not to accept the MIC and SIMTA requests that two separate reports for the combined areas be accepted by the EPA. We need to get the EIS correct for both sites when combined and from what I have recently read from the two separate responses by these companies for public comment, both at the same time, is not to an acceptable standard.
In Conclusion
I implore the EPA and DG to request a combined EIS be supplied by the newly combined SIMTA and MIC agreement as recently reported by the federal Government. I ask this so that the local community and sensitive receivers are given up to date information and not EIS reports which were conducted separately and are now out of date. I ask that new guidelines be given for and EIS using new technology, past testing results and WHO best practices.
I implore the DG to request a new investigation into the viability of MIC/SIMTA now that Chullora and Enfield terminals can be shown to handle much of the projected Moorebank TEU's and better distribute the imports and export container handling activities using new advanced technologies and they changed distribution areas at Eastern and Badgerys Creek industrial areas which MIC and SIMTA have ignored in their submissions as alternative sites of operations for the delivery and distribution of Container TEU's.
Since the MIC site was established as a possible intermodal in early 2000, many things have changed in the Distribution of containers and this needs to be addressed again to include the recently announced Second airport for Sydney at badgerys Creek and the ongoing development of eastern Creek.
Please provide protection for the Community and a better outcome for Sydney.
Thanking You
Michael Russell
7 Buckland Rd Casula 2170
[email protected]
0407231244
Mirella Riga
Object
Mirella Riga
Message
Mirella Riga
11 Clarendon Court,
Wattle Grove 2173
Allan Corben
Object
Allan Corben
Message
Allan Corben 13 Woolmer's Court Wattle Grove NSW 2173 Contact: [email protected] Phone 0451 998 774
Please find below, my submission on the SIMTA Moorebank Intermodal Terminal.
Reference: AC1612
I do question as to why I'm even bothering to lodge a submission again, as virtually no notice has been taken of previous submissions lodged by local residents by either the proponents or the Australian Government.
First and foremost, now that SIMTA and the Federal Government have agreed to jointly develop the Intermodal, the EIS process should commence again from the start, based on the full operation and cover all aspects and duration of construction. The fact that SIMTA are planning three stages for the development does not allow a clear prediction of what the overall impact of Noise, Air quality and Traffic will have on the residents of the numerous suburbs that surround the proposed sites when the development is at full operation. It's fine to have a PM2.5 outcome of 10 µg/m³ at the completion of stage 1, to then find that when the facility is in full operation that the particulate PM levels constantly exceeds the NSW EPA criteria. I like many others, don't need to know what impact stage 1 will have on my families health, but of what the impact will be at full operation. Staging of construction is a strategy to get the development under way as once it commences, there is little hope of stopping it should it negatively impact on the communities' health. Originally it was proposed that there would be 2600 trucks movements into the site daily, and now they are talking of 10,000 movements + it was previously proposed that the would be one rail line to the terminal and now they propose two. This has created an all new ball game.
Having an employment background of 47 years in the transport & Logistics industry, and having an extensive knowledge of the industry, I have been involved in the opposition to these proposals since day one as and I'm firmly of the opinion that professionally Moorebank is not the correct location and neither the proponents nor State & Federal Governments have any intention at all of addressing or accepting the concerns of the people who are facing massive negative health and wellbeing impacts. The reason for this opinion is that those involved have their minds firmly set on building this unacceptable transport industry operation at Moorebank based purely on (a) close to the M5 & M7, and (b) adjacent to the Southern freight line, ignoring the fact that the proposed site is surrounded by residential housing. Furthermore, in this day and age, operations of this nature, that operate 24/7, create dangerous air pollution and traffic congestion, should under no circumstances be sited amongst residential housing. "Haven't we yet learnt our lesson?"
The proponents ignore the fact that 39,000 + people live within a radius of two kilometres of the Moorebank site, some as close as 400 to 1000 metres, and that the Liverpool road network is already at its capacity.
Following are my comments by category on facts that both the Government and proponents are ignoring,
Site: The proponents claim that Moorebank is the ideal location for the Intermodal, yet ignore the fact that 45% of all containers landing at Port Botany are destined for Western Sydney not South Western Sydney. One function avoided by the transport industry is double handling of freight. In the case of Moorebank the freight will be unloaded from inbound shipping and placed in a holding area. It will then be reloaded on a Moorebank train and travel 26 kilometres to Moorebank, were it will again be unloaded into a holding area ready for delivery. The next action is to load the container on to a truck for the delivery involving a road trip in excess of 40 kilometres to the end customer. This will result in handling the container twice, not once and delaying the delivery of the container for an additional 24 hours. Definitely not what I would call efficient, nor will it have improved delivery time.
Infrastructure NSW is on record as recommending that no future investment be made in rail infrastructure till such time that short haul rail is proven viable. To load a train to travel 26 kilometres to unload is considered in my mind as being inefficient and not viable.
Traffic: It is well known that the Liverpool road network is near capacity. In an article published in the Daily Telegraph 4th June, the Federal Government is quoted as rebuffing critics who say it will clog Western Sydney roads with trucks, but in a speech on the Intermodal proposal made by NSW MP Ms Melanie Gibbons in the Legislative Assembly on the 4th June, she made the following statement, quote "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". Would the most outrageous comment I have ever heard and totally disputes the Federal Governments rebuffing critics, not to mention the outcome when the facility is shut down for any period of time, and again questions the suitability of the site.
I'm sure that transport companies servicing the site, warehouse tenants and their customers would be less than impressed with this prediction. Although a traffic model, completed on behalf of our community, has shown that there are many roads and intersections that will require substantial upgrades, the proponent has only acknowledged only one upgrade being Moorebank Avenue, but not till 2029/2030. This is regardless of the fact they intend to bring upwards to an extra 10,000 truck and 5700 car movements on to the local road network daily and handling a throughput of upwards of 500,000 containers.
One of the main selling points, claimed by the proponents, has been that Moorebank will take thousands of trucks off the Sydney roads each day, which is absolute rubbish as all it will do is relocate the trucks to Moorebank, where they will enter the Sydney road network. The fact is that it will remove trucks in the interim from the M5 between Port Botany and Moorebank, but this will only be a short term reduction. The reason for this is due to the handling capacity of the Port Botany freight line. It has been suggested (government has refused to reveal capacity) that the line has a maximum capacity to handle 1.2 million containers per annum. If we consider that Port Botany currently receives 2 million containers per annum and is predicted to handle in excess of 4 million in future years, how will the additional 2.8 million containers be delivered, simple, on the back of a truck.
Noise: The intermodal site is located in the middle of a number of residential suburbs that are home to many thousands of people. It is a known fact that residents living within a radius of three kilometres of the Port Botany container terminal are currently suffering from sleep disturbance, yet the proponents and government are obviously of the opinion that residents who live within a radius of 400 to 1000 metres of the proposed site will not be impacted by sleep disturbance. The government claims that the warehousing on what is currently SIMTA's site will act as a buffer zone to the suburb of Wattle Grove, but anyone who has been exposed to the level of noise created by this type of operation knows; the warehousing will barely reduce the overall noise level. The people living in the elevated suburb of Casula (400 metres on the Western side of the site) look directly down into the proposed area, with no chance of avoiding the noise level whatsoever. When asked how the proponents would mitigate the noise level, MICL stated that it would be up to the successful company who was appointed to develop the site to address.
Air Quality: It is well know that the Liverpool area is one of the most polluted areas in Sydney. This is qualified in a statement made in the PAC SIMTA determination that has already shown that PM 2.5 levels in the local area are close to or above the advisory criteria, yet MICL state that, quote "Air quality monitoring has demonstrated that the concentration of different airborne pollutants in Liverpool is generally well below guidelines. Conflicting statements????
Regardless of the above, that substantiates the proposed area is already highly polluted, the proponents intend to bring 10,000 + diesel trucks, ancient diesel locomotives and thousands of car movements into the site area daily. It should be noted that the emissions created by diesel types of equipment are carcinogenic and in the same category as asbestos, which is a well-known cause of death.
Alternative site: Although the ideal site is Eastern Creek, with the announcement of the Badgerys Creek airport, it was suggested that the ideal site for the intermodal would be to amalgamate the two projects together at Badgerys. This would eliminate the need to spend many millions of dollars upgrading the eastern area of the Liverpool road network and reduce the truck travel distance by approximately 20 kilometers and increase the rail kilometre component by 20 kilometres, and totally eliminate noise and air quality issues that pertain to Moorebank. This suggestion has been completely dismissed by the Government and the proponents as not possible due to (a) not sufficient time due to the urgency of the predicted increase in import container arrivals, calling for additional handling facilities and (b) no rail line into the Badgerys' site. There have been two changes that suggest that the urgency to build Moorebank no longer exists. Firstly, the Chullora terminal has announced that it has increased its handling capacity from 300,000 to 600,000 and secondly, the predicted annual increase in import containers of 7%, as advised by the proponents, has not been achieved and, in fact, is only in the area of 4%. Where's the hurry? Furthermore, for some time, Anglo Ports have been very keen to operate a container in the Newcastle area which would remove pressure off Port Botany, but the Government continues to ignore the interest. Its appears that the lease holders of Port Botany and Port Kembla have a contractual agreement with the NSW Government that involves a container cap restriction on Newcastle which restricts its viability. The Government continually refuses to confirm that the cap exists.
In closing I would like to note that, Government and their various departments need to be reminded that they have a duty of care to ensure that people aren't exposed to health threats, which this type of transport operation is well known to create. Should this development go ahead and impact on my family's health, I will not hesitate to seek legal action. This is the first time I have made this statement in 6 years of involvement, but I'm sick and tired of our community (the people) being ignored by those who are paid to represent us.
Yours Sincerely,
Allan Corben
---------------------
16th June 2015
Submission on Reference: SSD 14_6766 SIMTA Stage 1, Provided by Allan Corben 13 Woolmer's Court Wattle Grove NSW 2173 Phone: 0451 998 774 Email: [email protected].
In the minutes of a PAC meeting held on the 30th July 2014, a statement is made under air quality that quote, "PM2.5 concentrations are close to or above the advisory criteria, this applies to the current background levels as well as the predicted impacts. This statement gives great concern that the current level is close to or above the criteria and at full capacity, when this terminal is planned to have an additional 10,000 diesel trucks, 42 ageing diesel locomotives and 5700 cars coming into the site each day.
In my opinion, the additional diesel powered equipment, will increase the PM2.5 level dramatically to well above any acceptable level.
It's a bit late to say, whoop's, the PM levels are too high, once this facility is in full operation.
As such, no further approvals should be given till such time that independent, qualified evidence is provided that shows what the predicted full capacity PM2.5 levels will be.
To ignore this issue, would be a total dereliction of duty.
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 developement. What it 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.
The following submission on the SIMTA Stage 1 EIS is provided is provided by Allan Corben 13 Woolmers Court Wattle Grove 2173 on the 26th June 2015. Phone: 0451 998 774 Email: [email protected]
Required Road and intersection upgrades
Now that it's obvious that a number of roads and intersection will require extensive upgrades my question is who will be responsible for the cost of the upgrade process. SIMTA have made no commitment other than to say that they will contribute. In my opinion, SIMTA are the private developer of the Moorebank Intermodal and as such, should be responsible for the cost involved and that the taxpayers should have to pick up the cost.
Secondly, SIMTA's traffic modeling 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?
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The following response to the MICL submission reply is provided by Allan Corben 13 Woolmers Court Wattle 2173 on the 26th June 2015. Phone: 0451 998 774 Emial: [email protected]. I'm a retired person with a background of employment for 47 years in the Transport and Logistics industry. 14 years of this period was spent in a container handling rail business. As a result of the period of employment, I suffer from a 30% industrial deafness. As such, I have an extensive knowledge of this industry and its negative aspect.
6.1.1 Page: 86
Highlighted are comments that I disagree with.
The Project is in the public's best interest as its residual impacts will be localised and managed; however its benefits will be significant and widespread for the entire community. The benefits include a major (1) contribution to jobs and productivity growth, supply chain efficiency and (1) reduced congestion growth. The local community will receive a share of these benefits as well as a local benefits program. In addition, the public interest is also served by the IMT in terms of its contribution to government policy, (2) the lack of suitable alternative sites; and the (3) unique characteristics of the site which are not needed for other land uses but make it ideal for an IMT. While some local community members oppose the Project, the broader (4) community interest is reflected by strong support from government and industry stakeholders.
Response: Don't accept these comments as the as the road network is currently capacity, how will it benefit the community.
(1) I fail to see how the facility will assist in any large degree of employment. With the proponents committed to install automated handling equipment reduces the employment opportunities.
(2) There are alternative, but the Government and proponents have their blinkers on so they don't see them.
(3) How can the site be unique, its sits on an island with massive road entry restrictions.
(4) Of course there is strong support from the Government and stakeholders, they will make the profit. There are many transport operators who don't see Moorebank as the solution.
6.1.2 Page: 87
A business case was prepared for the Project which assessed the Project's feasibly and determined that an IMEX facility with capacity for approximately 1.05 million TEU at Moorebank would be economically viable. The business case considered, among other things, the distance to freight markets, containers destinations and costs of development of the Project. Chapter 2 - Assessment of the issues raised by the NSW Planning Assessment Commission of this report, provides a further justification of the demandfor intermodal capacity in the Moorebank precinct.
Response: If it was viable, why is it that Infrastructure NSW is on record as recommending that state public funding for additional Intermodal terminal capacity in Sydney including in relation to supporting Moorebank and that infrastructure be minimised until there is greater clarity on whether the short haul rail freight market is viable. From my background, short haul rail has always been questionable.
6.1.3 Page 87 concerns the IMT is being built where there is insufficient demand. In particular, one submission (224) states that 45% of the freight goes to Eastern Creek and argues that once Eastern Creek, Enfield, Minto and the southern intermodals are operational; there should be no need for theMoorebank IMT; thirds of all containers from Port Botany are destined for the western suburbs, approximately 26 to 35 km west of the Moorebank IMT. This is not consistent with MIC claims that the majority of containers would be delivered within a radius of 20 km from the IMT; and
Response: Eastern Creek is in fact 27.2 kilometres which rejects MIC"s claims that the majority of Containers would be delivered within a radius of 20 km from the IMT; and
Page: 88 No other site has been identified that is practicably feasible in the timeframe required and able to deliver the same operational efficiency (including the efficiency benefit of competition between terminal users under the terminal open access arrangement). Therefore, only the Moorebank precinct creates an opportunity to increase Sydney metropolitan container movements by rail.
Response: The need in urgency to build Moorebank no longer exists. (1) The predicted annual increase in import containers of 7% has reduced to 4%, (2) The Chullora facility has recently advised that their container handling capacity has increased by 300,000 to 600,000 which has removed the urgency on Moorebank.
6.1.6 Page: 91
* The terminal will have some local impacts and, for this reason, some members of the local community oppose the Project. However, once the effect of mitigation measures is taken into account, the residual impact will be relatively minor and within established criteria and regulatory requirements. In addition, a package of local benefits will be progressed in consultation with the local community. On balance, therefore, the project is in the public interest.
Response: Let it be put on record that there are not some local members of the community in opposition to the proposed, but a great many local residents totally opposed to this inappropriate development. The proponents have shown no evidence as to what the noise and air quality levels will be when the terminal is operating at full capacity. I will continue to argue that this information must be provided, not in stage by stage, but at full operation. Furthermore, little mitigation has been advised and when I asked a senior MICL person how MICL would mitigate the two issues, the answer was that it would be up to the successful company (SIMTA I assume to address. (A no answer, answer)
6.2.1 Page: 92
One submission (208) raises concerns in relation to the staged approval process and argues that environmental impacts should be assessed upfront, with the design planned and modelled. Other concerns related to the fact that the Project is seeking full approval for Early Works, without having received an overall approval for the Project.
Response: I'm not concerned knowing what the stage 2 air quality or noise levels are at the completion of stage 2, what I want to know is what the air & noise levels will be at full operation. No point advising limits at the finish of each stage, then when the development is complete, say oops, the air quality is too high. I'm sure that if that was to occur, the proponents wouldn't cease operations, knock the facility down and start again. One of my greatest concerns is in respect to Noise & Air quality when the facility is operating at full capacity.
MIC acknowledges the comments provided in submission 208 in relation to the staged approval process and the suggestion that all environmental impacts should be assessed up front, with the design planned and modeled. While it is recognised this would provide greater certainly to the community if the design of the IMT was completed for the entire Project, in practice this approach is not appropriate given the complexity and detail of the work involved in completing the design (time, cost and resource) required to support a detailed assessment and approval process.
Response: It's interesting to note the reason why it's not appropriate to determine the end result PM2.5 level being, (Time, cost and resource) People are more important than time, money and resources are. This really illustrates the fact that the Government and proponents are totally focused on pushing the development through. They really need to take their blinkers off.
Furthermore, when the development is completed and up and running at full capacity, the people involved in the construction will be gone, together with the politicians involved. This issue is definitely a "Duty of care matter". There is absolutely no way that the proponents nor the Government can walk away from their legal obligations. It is on record that PM2.5 levels in the area are currently near to close to or over the required criteria, yet it's expected that there will be up to 10,000 extra trucks and 42 filthy old diesel locomotives coming into the area each day. It's unacceptable that people are expected to just cop it and spend the next 15 to 20 years of their life worrying about the pollution levels, particularly PM2.5, the nasty one.
Question, What action will the Government and or proponents take if eventually the PM2.5 levels exceed the safe standards and impact on the residents health, and what guarantee do the people have in respect of protecting their health. If the predicted air quality levels at the full operation aren't available, the development should not go ahead.
6.3.1 Page
The information sessions were held on different days, at different times and were scheduled to run between two and three hours, although all sessions ran significantly over time to allow plenty of opportunity for participants to have their questions answered. For example, the final session closed three hours after the scheduled finish time.
Response: The community consultation meetings deliberately started late afternoon which made it extremely difficult for those people who could make due to the time they finished work. Being a member of the community group opposing the development, I had many people complain that it was near impossible to attend. As I recall, there were no meetings held on weekends. In my opinion, the community consultation meetings were very lacking and as far as I'm concerned a waste of time because no action was ever take to address our concerns.
6.3.3 Page: 97
The Moorebank Intermodal Citizens' Jury was asked to develop a package of measures to benefit people living near the future Moorebank IMT. The proposed local benefits package recognises that the terminal will benefit the wider community through billions of dollars in productivity gains and lower traffic growth in parts of Sydney. The public benefits package is not intended to address the impact of the terminal, which will be addressed through mitigation measures (e.g. local intersection upgrades, noise walls and locomotive standards to reduce noise and diesel emissions). Appropriately, the value of these mitigation measures will go far beyond the funding that MIC allocates to local public benefit measures.
Response: I have seen no evidence of noise walls being built on the eastern side (Wattle Grove) the proposed site. Are these residents expected to be protected by some bush land, which if so is unacceptable. The residents of Casula have been asking for noise walls to be constructed along the rail line for many, many years without success, so I'm sure they don't have much confidence in this statement.
6.4.1 Page 100
The Moorebank site was selected due to its strategic positioning, with good access to existing major freight and rail corridors (SSFL, the M5 Motorway and near to the M7 Motorway and Hume Highway), and is centrally located relative to major freight markets in the west and south west of Sydney. The size of the site was also a significant factor in site selection, with the requirement to accommodate interstate trains which can be up to 1,800 m long and the need for the site to be large enough to handle the number of containers expected (a total throughput capacity of 1.55 million TEU a year including up to 1.05 million TEU a year of IMEX).
Response: The repeated statements that suggest Moorebank is the ideal location are annoying. Moorebank does not have good access to the M5/M7 due to the current road congestion. Has consideration been given to the fact that without the Intermodal, the local road network will exceed its capacity in 2030 by 21% and with the Intermodal it will exceed the same capacity by 53% by 2030. It also isn't centrally located relative to major markets in the western suburbs as previously stated in the reply.
6.4.3 Page: 105
No other known site in Sydney has the same unique characteristics to efficiently accommodate the type of activities being proposed. The availability of the site for development represents a once-in-a generation opportunity for a transformational freight infrastructure project. Given the clear suitability of the Project site for an IMT and the lack of economically efficient alternatives, it would be inappropriate and mostly inefficient to use the site for an alternative purpose (e.g. residential or commercial), as these land uses would have greater impacts on the local environment and community
Response: There are others site that have similar if not better characteristics than Moorebank, but the Government and proponent are only interested in Moorebank. I find it laughable using the wording, Clear suitability/efficient/efficiently. The proposed site is located on an island with only one access road available, which just happens to be connected to one of Sydney most congested road networks. The operation will also need to have a costly rail spur built across the Georges River. There will also be horrendous issues of weaving and blending at the Moorebank M5 interchange southbound. (It's noticed that the proponents make no mention of these issues)
6.4.4 Page 105
Submissions argue that the way the Project has been presented to the community has created confusion, particularly in regards to how the Projects would operate with the SIMTA project.
Response: Totally agree with this point. To have two separate EIS"s on the same development going at the one time is very confusing to the normal person who doesn't have a background in the topics. One could be forgiven for thinking that action is deliberate.
6.4.7 Page 106
Both studies are internal reports and are not publically available documents. ARTC is responsible for the planning, design and construction of these passing loops. Any work on these passing loops will require their own planning approvals.
Response: Why is the capacity of the Port Botany freight line such a big secret? Is it because the line doesn't have the projected capacity to provide the TEU numbers to the current operating terminals and Moorebank. Many attempts have been made by our community to determine the lines capacity without success. "Smells a bit fishy to me"
6.5.1 Page 107
The IMT is required to operate 24 hours a day, 7 days a week to meet the demands of the freight market. It is noted that heavy vehicles would only access the site for 16 hours a day, 5.5 days per week until the Project reaches Full Build, at which time trucks would also access the site 24 hours day, 7 days a week.
Response: This statement makes no sense at all. Yes there are great concerns of our community when you consider that people living within 3 kilometres of the Port Botany container terminal are suffering from sleep disturbance, yet the proponents expect us to believe that noise wont impact on people living as close as 400 metres for the proposed Moorebank site. I defy the proponents to provide evidence that we will not suffer what the people in Botany are going through. Again, another issue of "duty of care"
6.6.1 Page 110
The results of the modelling are provided in Table 11.16 of Chapter 11 - Traffic, transport and access of the EIS. MIC acknowledges that the traffic modelling shows road network upgrades would be required to maintain all intersections in the vicinity of the Project site to an acceptable level of service, except the Hume Highway and Reilly Street intersection and Moorebank Avenue and M5 Motorway interchange. These upgrades are required to accommodate future background traffic growth (without the Project); however, there are no significant changes to intersection performance between the `with and `without' Project scenarios as the network in 2030 is predicated to be congested based on background growth associated with urban and population growth in the region.
Response: Not sure of what is meant by the statement, but fact is that without upgrade before any operation commences, the Moorebank Ave and M5 southbound interchange entry will have massive issues with blending and weaving of traffic between Moorebank Ave and the off ramp at the Hume Hwy.
Many road upgrades need to be in place before any operations commence.
6.6.4 Page 113
Truck movements from the IMEX and interstate operations are not new trips. Without the Project, these movements would be associated with trips taken to and from Port Botany and, therefore, would already be on the highway network.
Response: Incorrect, many of the truck movements from Moorebank will be new movements, as not all current trucks travelling from Port Botany use the M5. There are many routes that trucks can take to reach their destination, including those that don't have a toll.
6.6.5 Page 114
In response to the `weaving' issue on the M5 Motorway, refer to MIC's response in section 6.6.2.
Response: Totally agree with concerns re accidents. Between 2009 and 2013, heavy vehicle accidents in the local area increased by 20%. This is without bringing up to 10,000 additional heavy vehicle movements onto the local road area, which includes the M5
6.6.6 Page 115
Section 11.4.3 of Chapter 11 - Traffic, transport and access of the EIS shows the results of the modeling of the Moorebank Avenue/M5 Motorway intersection. The intersection would operate at a LoS of B (good with acceptable delays and spare capacity) during the AM peak with or without the Project, and at a LoS of C (satisfactory) during PM peak with or without the Project. As such, no mitigation measures are considered necessary.
Responce: This would be by far the most important intersection requiring upgrade. Even with a 100 trucks using the intersection each day would result in problems regardless of what the study shows. Even this document showed the acceptance of the concerns for the weaving and blending between this intersection and the motorway.
6.6.8 Page 116
MIC acknowledges that increases in travel time as a result of traffic congestion can have negative social and economic impacts to individuals, the local community and businesses. However, as discussed in section 6.6.4 in this report, there are already congestion issues on both local and regional arterials in the vicinity of the Project site and these issues need to be addressed on a regional basis which is outside of the scope for the EIS. The Project is expected to reduce VKTs on the Sydney regional road networkwhich in turn will benefit traffic flow on major Sydney arterials.
Response: This statement suggests that because the congestion is already in place, that all is well and not the responsibility of the proponent.
6.7.1/ 6.7.2/6.7.3 Page 123 & 124
Response: Concerns are high as previously advised, that sleep disturbance will occur as is the case at Port Botany. The community needs to know if in fact the noise will impact on them in this manner. No guessing or maybe. It's too late to address the problem when the facility is in operation.
6.7.6 Page 126
In response to the comment stating noise measurements have been taken from background along train lines and major roads and are therefore not a good representative of sensitive receptors
Response: I can clearly recall looking at noise level studies carried out by the proponents that claimed at a certain area on the Southern Freight at Casula the noise level was 48dba, when a local resident living adjacent to the freight line had NSW government documents showing at their home which was close to the location of the proponents study, was in fact above 98dba. This somewhat questions the accuracy of the sample taken by the proponent. Outcomes of this nature doesn't give the resident much comfort.
6.7.7 Page 127
MIC recognises the importance of the proposed noise mitigation and the future operator of the IMT would be required to implement the measures as required by the Project approvals (Stage 1 and Stage 2 SSD approvals) and any conditions of approval.
Response: As was the case in respect of air quality, the noise levels at the full operation of the facility need to be determined upfront, to assure residents aren't exposed to sleep disturbance.
6.7.9 Page 129
MIC is not able to comment on management and mitigation of noise emissions from the Port Botany site. The operations at Port Botany are different to the operations proposed at Moorebank as such, a direct comparison between the two projects is not possible. The EIS has presented reasonable and feasible noise mitigation measures to control noise emissions from the Project. Once the detailed design is developed, the appropriateness of the noise mitigation measures will be further developed during the Stage 2 SSD applications.
Response: The operations of Port Botany and Moorebank are in fact similar. They both handle the same type of freight in the same manner, trucks coming and going 24/7 and they are loading the rail wagons that service the current operating terminals in the same manner. Geographically, Port Botany and Moorebank are different in respect that the port has Botany Bay (water) on one side which allows good noise disbursement of polutioin, unlike Moorebank which is surrounded by residential suburbs. Moorebank also has the elevated suburb of Casula on the western side which will act as noise reflector back towards the eastern boundary. I will say again, I defy the proponents to prove to me that the surrounding suburbs won't be exposed to excessive noise, because I can't see any way that the noise from the proposed facility can be suitably mitigated without gigantic noise walls being put in place. IE The site sits inside basin type of area.
6.11.2 Page 141
The following concerns were raised in relation to ambient air quality:
* Air quality is already an issue in the Liverpool area and the Project would exacerbate the impacts.
* Submission 81 argues that existing levels are exceeding World Health Organisation (WHO) recommendations.
Response: Air quality is most certainly an issue in the Liverpool area, that is why the PAC are on record as acknowledging that PM2.5 levels are close to or above the advisory criteria and more the reason that the PM2.5 predicted full operation levels are determined before further approvals are made.
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Karen,
The longer that I’m involved in the opposition to the above proposals, the more I think that the NSW Government departments are simply paying lip service to the many community concerns,
There is no way that the local road network could cope with even the SIMTA stage 1 volume of traffic.
There is no way that the PM2.5 levels will be at the acceptable (legal) levels at full operations.
There is no way that the noise levels at the residential properties that surround the proposed site will be under the acceptable level at full operation.
I made comment on the MICL EIS that the people living in a radius of 3 kilometres of the Port Botany container terminal are suffering sleep disturbance. Their reply was to say that Moorebank couldn’t be compared to Port Botany which in my opinion, would be considered by NSW Government departments to be a community concern that had been addressed, which it hasn’t. The EIS is then signed off and sent to PAC.
MICL’S response is absolute garbage, Why, because operations of both are the same, but Botany has the benefit of having Botany bay on the southern side of the facility, sea breeze and etc that acts as mitigation, with the majority of homes in that area constructed of double brick, unlike the homes that surround Moorebank, which are constructed of single brick. Furthermore, Moorebank is located in a basin, with the elevated suburb of Casula on the western side which suggests that its geographically worse than Botany.
What must now happen before any further approval is given is,
Now that both proposal are now one, the EIS process must commence again, with predictions based on the completed facility operating at full capaciy. My reasoning for this is based on the following,
We were originally talking of 2600 trucks, now tens of thousands,
We were talking about one rail line, we now have two.
We are now talking about 850,000 square metres of warehousing, which will massively increase the traffic.
Environmental studies on the noise, traffic & air quality predictions must cover the facility at full operation. From my point of view, I don’t need to know what these levels are at the completion of say, stage 1, what I do want to know, is the levels once this facility is at full operation.
What people involved in these proposals don’t appear to understand, is that they all have a duty of care to ensure that people aren't exposed health and wellbeing issues. Nobody has the right, morally or legally to deliberately expose another person to health risks, which to me appears to be what the proponents and Government are prepared to do in placing this inappropriate industry facility amongst residential housing.
In closing I would like to say exactly what I believe going on, but don’t really want to become involved in any legal issues.
Yours Sincerely,
Allan Corben
Alan Higgins
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Alan Higgins
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The M5,M2,M7, Newbridge Rd, Nuwarra Rd,Heathcote Rd Canterbury Rd. Parramatta Rd, Hume Highway and every other major arterial road in SW Sydney already struggles to handle the present traffic volumes. A simple thing like a minor accident or breakdown sends all the main and minor roads into gridlock.
All of the medical authorities tell us how the deisel fumes are so dangerous to our health and as so cause enormous cancer risks. Are our younger generations to be guinea pigs for such a stupid location of the Intermodal which will put many thousands of heavy vehicles each week on our local roads and driving through residential suburbs.
Our beautiful Georges River has finally been given a chance to get back to the wonderful asset that all of our communities can enjoy and be proud of for generations to come. The Intermodal will be bad for the rebirth of the river.
Please do not treat our families and communities with contempt by going ahead with the Intermodal Project.
The Intermodal needs to be relocated further west and incorporated with the new airport project.
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John Smith
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Brian Donaldson
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Brian Donaldson
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So why approve of a major potential polluter such as a MIT or possibly two of them on the immediate foreshores of the Georges River when there are other more suitable areas within the Liverpool Local Council area?
Whilst I am aware of the various engineering solutions to minimize possible pollution spills etc. never the less there is always exceptions / accidents that always happens on a regular basis that for some reason or another were not planned for.
Let me refer you to the following documents that I am sure you are familiar with:
1) Regional Environmental Plan
2) Southern Sydney Catchment Blueprint (2002)
3) Biodiversity of the Georges River Catchment.
4) Georges River Catchment Built Environment and Foreshores Access Study.
5) Georges River Catchment Better Practice Guidelines for Foreshore works.
Whilst SIMTA will claim compliance to all the above requirements it will be minimal or tokenism at best and only satisfy their legal obligations rather than their long term moral obligations.
This present area would be more suitable to a Hi-Tech Business Park or a University Campus so that the catchment area can be preserved for all use and appreciate - not a concrete / Blue gravel area with an eyesore of thousands of containers stacked everywhere with the associated truck & rail movements polluting the area both with noise and air pollution plus traffic congestion.
Keep our River foreshores pristine for future generations to enjoy.
The MIT is now not an urgent requirement due to the opening of the new Enfield MIT so replanning for a new location at an Industrial area at Badgerys Creek can be achieved under a more controlled manner and leave our Georges River for all to enjoy.