Moorebank Intermodal Precinct West - Concept & Stage 1

Wow! The Moorebank Intermodal AND the SIMTA Moorebank Intermodal. Two developments which I trust will be looked at as a collective, because this is how the operation of this facility will affect the environment.
If this development progresses, it will negatively impact residents and environment alike - as much as it is monitored and effects mitigated - this is a fact. The only question remains - how negatively will it impact?
Response to section 11 - traffic
Now forgive me but the EIS document is not downloading on my computer but I have a question which may be covered in the proponents' submission. I will mention my concern briefly then move on;
a) how can consistency of traffic flow be assured when, for one example, there exists traffic control signals at the intersection of Anzac Parade and Moorebank Avenue which operate independent of the facility? Whatever the figure of incoming vehicles - 8/minute or 13/minute or even 4/minute - consistency of flow, timeliness, and unhindered site entry would not be forthcoming now, let alone when construction and operation are in full swing.
b) what is the queueing theory?
c) what contingency is there regarding hazards, an incident, or breakdown affecting Moorebank Avenue access to site?
Response to section 12 - noise
a) Breaches of required guidelines will occur, and there needs to be suitable, tangible and timely responses to prevent further non-conformances/breaches. With that in mind, what is the operational Noise Management and Monitoring Plan? What mitigation strategies are proposed for a) noise (and light) emission, b) control of the transmission of noise (and light) in accordance with the recommended conditions of approval and what noise attenuated structures are engineered, and c) controlling noise at the receiver? This has been discussed for the site, but what of traffic to and from the site - that outside the confines of the development or inbound traffic?
b) Temperature inversions can bend sound waves over mitigation bund walls. Is two nights a week a reasonable estimation for these phenomena, mostly during colder months? The number of exceedances would certainly seem unacceptable, and that is not even considering being down wind of a noise source. Will mitigation measures be proximal to source AND proximal to receiver? From the table 51 (page reference 12-48) the mitigated modelling demonstrates that 90% of the noise sensors were within the required criteria under neutral conditions. In adverse conditions, this reduces to 65%. Is this acceptable? One cannot control the weather... So most definitely there is real potential for nuisance noise from the proposal under what is termed `adverse weather conditions' of which in the Liverpool basin there are frequent, seasonal and varietal.
c) All quoted figures are an indication of where the noise is projected to go and how intense the emissions are. It in no way reflects accurately the population density at monitoring sites or the number of residents it potentially affects.
d) Casula residents are assaulted by all rail line options at all times of the day under normal operating conditions (without mitigation) even before the full build, so they will have years of necessary mitigation required under normal meteorological conditions to keep within legislative guidelines. (table 12-16, 12-17 page reference 12-19, 12-20). Is this a reality? The conclusion of "During operation (modelled impacts with mitigated scenario)" (reference 12-54) tended to indicate that with the northern rail option under normal meteorological conditions that there will be no issue with exceedances. I am confused...
e) I am concerned of the truth of section 12.3.9 that road traffic noise (page 12-37) associated with the development will not increase existing road traffic noise by more than 2dB(A). The M5 and Moorebank Avenue deserve a mention which they get, and Anzac Parade? Forgive me but I thought that Anzac Parade was not to be utilised by intermodal traffic. Please excuse my ignorance.
f) Engines tend to make noise when under stress/load, and the stopping and starting of vehicles that visit the site will affect residents, particularly when this is a 24 hour a day operation. Just think of Port Botany and the news coverage it received earlier this year with flawed EPA data which suggested that the noise did not reach "sleep disturbance criteria" (Refer SMH article Aug 17, 2014). Noise complaints were reputedly made from kilometres away. This is unacceptable when the closer neighbours are within 300m of the access to the site. Has data been included for the omnipresent acceleration/deceleration of attending queueing heavy vehicles that have not entered the facility grounds?
g) Most importantly, let us not forget that the accuracy of the theoretical calculations that are made by an EIS should contain an error margin, which accounts for meteorological conditions encompassing wind speed, direction, temperature, humidity and vertical temperature gradient of +/_ 5dB(A) (Tonin, 1997)a. Whether a methodology was used other than that of the author of this paper, a margin of error/confidence interval/accuracy and precision guidelines are good practice. No error margin has been indicated by the documentation. With such borderline results in some areas of noise compliance, it would seem important that these are included in the document. Where are they?
Response to section 17 - air quality
a) A concern is not regulating existing locomotives to noise and air quality criteria as there is the clause "where reasonable and feasible", or "consider use of hybrid locomotives or cleaner fuels", or "consider electric powered locomotives (page 17-35 and 17-36) - not exactly concrete. There are references in this section regarding reducing heavy vehicle emissions through BATEA (best available technology economically achievable) noted, but nothing committed - the phrase "would be investigated". Not concrete either. The ideas are great - Euro V compliance, retrofitting older vehicles, hybrid utilisation, (a dabble in best management practice), and so on.
b) A question for the sewage treatment plant (reference 17-37) - where is the overflow to the structure in event of catastrophic failure? Surely this is detailed, and dare I mention that it will be the Georges River. There is no mention of detention times for this structure. Is it tertiary treating the waste water? Even with all of their infrastructure and budget Sydney Water was found negligent and fined by the EPA with a clean-up charge from a local council earlier this year for environmental discharge
c) I am concerned that without (or with limited) atmospheric dispersion, deposition of particles on site and in the near vicinity will affect the workers within the boundary of the facility, as they will be exposed to close to three times the NEPM advisory level at a conservative estimate, if not more.
I fear for the release by the operation of the terminal of toxic, carcinogenic, poisonous emissions. I see modellers addressing SOx, NOx , BTEX species, but what bothers me is this: from their research, I fear the 1) lack of tangible regulation of site inbound traffic (road and rail), 2) lack of appropriate scientific monitoring and analysis, and 3) procedures by the proponents to manage exceedances.
Two indices of interest are:
PM2.5
The annual average PM2.5 concentration recorded at the OEH Liverpool station between 2009 and 2013, incorporating natural particulate matter events (bushfires and dust storms), was 7.6 μg/m³.) NEPM advisory reporting goal of 8 μg/m³. Reference: Moorebank Intermodal Terminal project EIS (page 19 of 43 Chapter 17).
Given the Liverpool region struggles with particulate matter and teeters on the verge of established unacceptable air quality, what of the 21 plus kilograms of PM2.5 that this terminal will environmentally emit into the atmosphere daily at full build? This is the projected emissions for 2030. It is anticipated by project completion that national air quality indicator exposure limits will tighten, and together with an increase of background concentrations in the region due to community or local contribution. On the other hand, technological advances in Euro emissions standards for trucks may be introduced and uptake may be legislated, but collectively in accordance with the findings of Parsons Brickenhoff, the project will ubiquitously and consistently exceed air quality standards for this air quality indicator. (Graphical representation Figure 17.7, page 17-29 Chapter 17)
Polycyclic aromatic hydrocarbons
There are no current available monitoring data for PAHs in the Sydney area. These pollutants are anticipated to be present in trace concentrations within the local ambient environment.
Long-term studies of workers exposed to mixtures of PAHs and other workplace chemicals have shown an increased risk of skin, lung, bladder and gastrointestinal cancers. These studies have also reported asthma-like symptoms, lung function abnormalities, chronic bronchitis and decreased immune function. (Source:http://www.health.sa.gov.au/pehs/PDF-files/ph-factsheet-PAHs-health.pdf).This is well known science.
I am interested to learn that it is not recommended to continue PAH monitoring during the operation of the facility given the toxicity of the compounds and how little concentrations have large effects.
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 soil.
Where is the benzo(a)pyrene impact assessment criterion of 0.4 μg/m3 (reference 17-24 chapter 17) referenced from?
d) I am also concerned about table 17.7 "Derived short term concentrations for SO2 and CO - all scenarios" on page 17-23. It is impractical to tout the short term exposure limit for CO as 100ppm. It is interesting to note that workplace exposure standards for CO is 30ppm over an eight hour shift. Is 100ppm a realistic NSW EPA limit for the purposes of this exercise, or is this for illustrative purposes, or is there some value in mentioning a 15 minute exposure standard? Certainly it is not practical, and a safety approach by using 30ppm would be wiser.
e) According to the recommended conditions of approval, what are the key performance indicators for emission control, where are the on and off site monitoring points, what is the frequency of compliance reporting, what are the poor air quality response mechanisms?
f) It seems strange that we are almost blindly placing this in a residential area when the world awakens to the truth about diesel emissions - France plans on banning all diesel vehicles by 2020, Europe and the UK are banning diesel cars because of consistent failures of European air quality indicators, the United States Government within the last couple of weeks will impose a strict 230 mile (368km) buffer zone along the entire US coast from large SOx, NOx species and particulate generating ships. Canada is expected to follow this move. The world is awakening regarding diesel. What is Australia doing?
Response to section 29 - risk
a) I am mystified with the proponents continually stating that overall impact on M5 traffic would be positive (refer 29-7). What is their baseline? The assumption that they will have all freight and vehicle movements will be via the M5? I do not understand, because from a baseline modelling of future anticipated traffic, the volume of units travelling to Moorebank will in fact impact negatively on traffic, and that is without the effects of the intermodal traffic. And more nonsense such as "the project would reduce the vehicle kilometres travelled by trucks on Sydney roads" (refer 29-7). Given the majority of the freight is not locally utilised, does that not mean more kilometres? This not only impacts traffic congestion, but air quality, noise and quality of life to name a few.
b) The risk matrix for noise (ref 29-8) references the infrastructure but fails not mention all traffic to and from site which will potentially be a greater contributor to noise levels. This must be mentioned as it is part of the business of the freight hub, and has with it, inherent risk.
c) Ref 29-11 - in the impact/risk column is "adverse impact on local air quality during construction or operation", one of the descriptions of potential risk listed starts "excluding the contribution of existing ambient air quality..." Does this mean:-

Equation 1
atmospheric indicators within EPA/NEPM = permissible development emissions + background emissions

or
Equation 2
atmospheric indicators within EPA/NEPM = permissible development emissions - background emissions

I believe that they are trying to argue the second equation.
The above being the case, why is it acceptable that the rest of Sydney has EPA/NEPM air and workers of the development and proximal residents have less than this assurance/standard of clean air? The residents are already suffering. The reality should be clean air for all - ubiquitously.
d) The human health risks and impacts evaluation in this section of the EIS calculated increased lifetime risks (from the impacts of PM2.5 and PM10) and an increase in the number of cases for a range of key health effects. This is nothing new. Continuing, it noted that the NEPC advisory goals are based on the protection of population health (reference 25-19) - well, thank goodness for that!
e) Contrarily, on page 29-14 the risk/impact "risk to human health" discusses that "exposure-effect particulate matter are not measureable or statistically significant, and that the health risks or impacts are low and acceptable." Aside from contradicting the above paragraph, this scores a "major" consequence in the risk matrix. Flicking back a couple of pages to 29-4 the definitions of how the consequences of the risk matrix are scored, major risk rank is defined by:

"Impact likely to be medium- to long-term and potentially irreversible
Impact may be local or wider (most likely no greater than a regional spatial extent)
Impact likely to be of concern to key stakeholders"

Whereas critical is defined by:
"Impact likely to be long-term and irreversible
Impact may be local or wider (including up to a state-wide spatial extent)
Impact likely to be of a high level of concern amongst most stakeholders"

Is the insinuation from above that a major risk rank embodies potential reversibility of impacts? So, how does one reverse skin, lung, bladder and gastrointestinal cancers, asthma-like symptoms, lung function abnormalities, chronic bronchitis and decreased immune function?
I dare say that there are likely long term irreversible impacts from this development. I dare say that the impact will be local, and I dare say that there is a high level of concern amongst most stakeholders. This changes the unmitigated risk ranking of the activity with a likelihood of almost certain to a "major". Even if world class mitigation measures were in place, and if the likelihood changed to remote, the activity still obtains a score of "high" which means that it should not proceed without further controls. This is risk management.
f) The proposal is not built in a bubble, so whether the intent is to mitigate or not, whether it is to monitor or not, whether it is fraught with diligence or negligence, the activities that are proposed from this development will result in inevitable environmental discharge through multiple mediums. It is the nature of the development! Some chemicals known to be part of diesel emission do not need much airborne concentration to gain effect - they are extremely carcinogenic! A risk averse ethic is ultimately important.
g) What design features are planned to be instilled for air pollutant and noise emission control that are deemed best practice? There is a lot of talk about this and a few propositions put forward, but no firm accountable detail.
h) What is the assessment for retrofitting older locomotives and trucks in line with "reasonable mitigation and management measures? Once again, I note no definite details.
Conclusion
I know that collectively the modelling is trying to predict that the operation will sit comfortably within environmental guidelines, but it does not mean that:
a) the development will not create extra and at times nuisance noise in my quiet neighbourhood,
b) the proximal residents will not suffer a reduction in air quality,
c) the modelled traffic impacts will not be negative,
d) as part of the residual level of impact (section 8.2.1 of NSW Industrial Noise Policy) the dubious question over property value can only be positively affected, both directly and indirectly, and
e) the quality of life that my neighbours and I have will not be reduced.
f) the businesses in the near vicinity will not undergo a dynamic business shift to container handling/affiliated or freight businesses
The point f) above will negatively impact points a) to e) furthermore and negatively affect my community. I can see the need for a facility. I can see the employment benefits. I just cannot see the need for Moorebank being the target, nestled amongst the medium density population hub which is Casula, Glenfield North, Wattle Grove, and surrounds. There are many things right about the choice to use Moorebank as the intermodal site but proximity to residential areas the most unforgiveable. The decision seems terribly short sighted, and will affect a large number of people, all of which was avoidable if this development was in the right location. As it is approved in theory for Moorebank, it is a betrayal of the local community and electorate.
I fear that effective control measures will not be forthcoming and I, along with many residents, am going to be bullied into leaving our houses - our dreams. This is not just.
Reference a: Tonin, R; Australian Acoustics Journal, "Validation of Environmental Noise Model (ENM windows)" August 1997 Vol 25 number 2

I wish to object to the MIC proposal as detailed in the EIS.

The Liverpool area is a growing city, open for business, but more than anything a place people call home.

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

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

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

I cannot understand why SIMTA would put forward one development in one location, proposed to be developed at the same time, but submitted as two separate EISes - SIMTA and MIC. The planning process would be extremely flawed if this kind of gross subterfuge is allowed to pass. Since SIMTA is developing both sides of Moorebank Avenue simultaneously it is essential that the whole development be considered as one so that the need and the impacts can be considered holistically from the outset and residents rights can be properly protected. The developer is using this ruse of two separate EISes to pretend that the impact is half what it really is.

The TEU volumes proposed by the proponent are extremely high. In the SIMTA application, the PAC concluded that 250,000 TEUs are sufficient for the South West to meet the government's target for container movements by rail. Since SIMTA, who is also the company developing the MIC development, already has approval for all of the 250,000 TEUs that are needed in the South West, clearly no additional TEUs should be approved for the MIC component of the development.

The proponent is requesting approval to ship 1.5 million TEUs through just the MIC half of the development. This is equivalent to the size of Port Botany in 2006, wedged between three residential suburbs and next to a river. It is unthinkable that such intensive development could be compatible with such a location. Recent media report show that residents neighbouring Port Botany have been harmfully impacted by the noise of Port Botany and that the EPA was incapable of protecting them. There should never be a repeat of the disaster at Port Botany and the IMT that Sydney needs should be built in an industrial area, such as at Badgerys Creek under the flight path of the new Airport surrounded by new warehouses that can consume the 1.5 million TEU avalanche.

The statement "The site is adjacent to the SSFL, the East Hills Rail Line and the M5 Motorway." is inaccurate and misleading. The site is adjacent to the Georges River and the houses of thousands residents.

The southern rail connection provides no noise protection for residents in the southern part of Wattle Grove other than bushland, a fair proportion of which SIMTA seeks approval to put to the chainsaw.

The proponent's statement "The Project site was selected for ... its central location relative to major freight markets in the west and south west of Sydney" is misleading and deceptive. MIC modelling shows that these markets are centered on Eastern Creek, 20KM to the north. This is not a benefit at all, but a cause of major traffic disruption on critical Western Sydney arterial roads. This is in fact an argument for locating the IMT elsewhere, for example at Badgerys Creek where new infrastructure is already in the planning stages or at Eastern Creek where most of the containers need to be.

Where the proponent says "A number of submissions suggested the demand could be accommodated within Sydney's existing IMT facilities; however, IMTs serve a defined geographic catchment and there is clear demand for Moorebank from a catchment area that is different to that served by existing IMTs" this is also misleading. While they plan to service a different catchment to the other IMTs in the South West, their modelling shows the demand is nowhere near Moorebank which is at one extreme end of the supposed catchment.

While the proponent claims that visual impacts will be unavoidable, residents have a right to have their outlook (and therefore their property values) protected. The proponent should provide a guarantee that all residential properties will be shielded from any industrial development in their outlook.

The proponent claims "No other known site in Sydney has the same unique characteristics to efficiently accommodate the type of activities being proposed". Clearly they haven't been listening when the Liverpool Council proposed the IMT be located at Badgerys Creek. The supposed advantages of Moorebank are its size, its proximity to road and rail infrastructure. Each of these characteristics can be a feature of the Badgerys Creek location. Building an airport locks up a lot of land for industrial use because of the flight paths and the noise of the aircraft. This means there will be space for both long trains and lots and lots of TEUs. It also means that the warehouses that will be built there will be a popular destination for containers at Badgerys Creek minimising the need for additional infrastructure.

Badgerys Creek is already planned for major road and rail development. By considering a terminal there at this stage there will be no problems in building the infrastructure along with the IMT. Releasing the land at Moorebank for development as residential or commercial will raise sufficient funds to extend the freight line beyond the residential areas where it now runs, mainly due to previous planning failures. We should not allow the planning failures of the past to dictate new planning failures today and into the future. Why condemn thousands of residents to live next to a new Port Botany scale development just because the planners of the past didn't put industrial and freight rail together.

The proponent argues "The Moorebank precinct needs to be developed to a total intermodal capacity of 1.55 million TEU". If this is so, then it is an extremely strong argument to bite the bullet and spend the money on rail infrastructure now to locate the terminal away from residential areas that it is fundamentally incompatible with. Despite the argument that it is uneconomic to do this, the basic argument in favour of an IMT is that it is more cost effective to rail the containers than to build enough roads to freight them by road. With that in mind, surely the one primary economic concern should be where do they need to end up, not where does the freight rail go today. It must be cheaper to build a freight rail alongside the new passenger rail to Badgerys Creek than to upgrade every single arterial road between Moorebank and Eastern Creek and all of the other 20-30KM distant destinations that MIC identified in the original EIS. The proponent's concept of Economic Viability extends only to its own costs and profit, not to the true impact on the people of NSW and the infrastructure that must be paid for by their government to make their development economically viable.

The proponent argues "No other site has been identified that is practicably feasible in the timeframe required", but the time pressures have been eased significantly by a slowing in the rate of container movements and by new capacity being built by Asciano. This argument now favours good planning over the indecent haste proposed by the proponent.

The EIS response can be summarised as follows - the Moorebank option is cheaper than lower impact options. The Moorebank option mainly impacts local residents and the traffic congestion was going to be bad anyway. Previous poor planning means that all of the ingredients needed for the IMT happen to be in Moorebank, so the IMT should be in Moorebank regardless of the impacts. This kind of blame the victim approach is completely unacceptable. The quality of planning in Sydney is atrocious and it is due to this kind of band aid thinking. Nearly every unpleasant development is next to someone's house - airports, sea ports, IMTs, Rail, Motorways all cut through residential areas without thought for buffer zones or combining unpleasant, unhealthful or unattractive developments. What Sydney needs is to stop plonking the next dirty thing in the first available space and to start thinking strategically. Liverpool Council has shown more strategic thinking in proposing Badgerys Creek than has been seen in Sydney since Bradfield's day. The Badgerys Creek location is ideal. Yes, there is a need for infrastructure, but it can be built in a planned way in conjunction with other infrastructure that needs to be built.

Allowing the self interest of the developers to dictate the location, capitalising on previous planning mistakes would be extremely regrettable. If we want Sydney to be like Paris, we have to plan to make it like Paris. If we want Sydney to be like a miserable industrial wasteland of the industrial revolution, we need do nothing but approve developments like the MIC development next to as many residential areas as possible. Cities go down hill one development at a time. It has to stop here and now.

* Given the evidence that is already available on the affect of Diesel Particulate Matter 2.5 the approval of this project would be GOVERNMENT SANCTIONED MURDER! There is no difference between the approval of this project and the DEATH PENALTY. The individual State and Federal politicians and the corporate Individuals as well as there companies and shareholders are accountable and will be held to account in a legal proceedings for the Death and Destruction this project will inflict on the local residents should it go ahead. You have been warned.

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

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

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

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

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

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

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

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

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

See attachment

See attached.

See attached.

See attached.

See attached.

See attached

See attached.

See attached.

See attached.

See attached.

See attached.

See attached.

See attached.

See attached.