Shoalhaven Starches Expansion Project Mod 26

Submission on Shoalhaven Starches Expansion Project – MOD 26
To: NSW Department of Planning, Housing and Infrastructure
I am a resident of the Shoalhaven and wish to make a submission on MOD 26 for the Shoalhaven Starches facility at Bomaderry.
My concerns are not about industrial activity in general or the importance of local employment. Rather, they relate to the cumulative impacts of ongoing expansion on the Bomaderry community, the Shoalhaven River environment, and surrounding areas including North Nowra, Terara, Numbaa and Shoalhaven Heads.
1. Cumulative impacts have not been adequately assessed
The Modification Report assesses the impacts of MOD 26 largely in isolation. However, the Shoalhaven Starches site has undergone numerous modifications over many years. The February 2026 Community Consultative Committee (CCC) minutes themselves list MOD 26 alongside several other current and proposed modifications, including MOD 31, MOD 33, MOD 34 and MOD 35.
The community experiences the combined impact of all developments, not each modification separately.
The key question for residents is not whether MOD 26 by itself is acceptable, but what the cumulative effect of ongoing expansion means for:
• noise;
• traffic;
• air quality;
• visual impacts;
• flood risk;
• wastewater management; and
• industrialisation of the Bomaderry entrance corridor.
The exhibition documents do not provide a clear assessment of the overall long-term impact of the site's continuing expansion.
2. Existing noise concerns should be resolved before further expansion
The Noise Assessment acknowledges that cumulative site noise exceeds Environment Protection Licence limits at sensitive receivers and that low-frequency noise is present.
While the assessment concludes that MOD 26 may individually comply with relevant criteria, residents are concerned about the practical reality that noise remains an ongoing issue.
The February 2026 CCC minutes recorded:
• five community complaints during the quarter, including noise complaints; and
• a NSW EPA Prevention Notice issued in relation to an ongoing noise complaint.
Given these existing concerns, the Department should carefully consider whether additional industrial infrastructure should be approved before existing community noise issues have been fully resolved.
3. Air quality and odour concerns remain unresolved
The Air Quality Impact Assessment identifies odour exceedances under certain operational scenarios and notes that investigations are ongoing.
Residents have already experienced odour issues over many years. The February 2026 CCC minutes confirm that odour complaints continue to be received.
MOD 26 includes substantial grain handling infrastructure, conveyors, unloading facilities, grain cleaning systems and silos. These activities have the potential to generate nuisance dust as well as additional operational impacts.
The assessment focuses heavily on compliance modelling. However, local residents are interested in what they may actually experience in day-to-day life, particularly during harvest periods and adverse weather conditions.
4. Floodplain and river corridor risks require greater scrutiny
The proposal includes significant infrastructure within a flood-prone area adjacent to the Shoalhaven River system.
The Wastewater Irrigation Feasibility Assessment acknowledges a range of site constraints including:
• flooding;
• shallow groundwater;
• salinity;
and
• drainage limitations.
The wastewater upgrade relies heavily on ongoing management and monitoring measures.
Residents are concerned that the assessment focuses on normal operating conditions rather than extreme events. Climate-related flood risks are increasing across the Shoalhaven. The potential consequences of infrastructure failure, wastewater incidents or erosion during major flooding should be examined more thoroughly.
Any impacts on waterways have consequences not only for Bomaderry but potentially for communities and environments downstream, including Shoalhaven Heads.
5. Riverbank stability and environmental impacts remain concerns
The exhibition material identifies a history of riverbank instability and the need for additional stabilisation works.
The proposal places new infrastructure close to the river corridor, including conveyor infrastructure associated with grain handling.
Government agencies, including Fisheries, raised concerns regarding riparian impacts and long-term riverbank stability during the assessment process.
Given the importance of the Shoalhaven River to the region, a precautionary approach is warranted.
6. Community consultation has been inadequate
Community consultation is a major concern.
There are only 2 committee minutes available for the public, buried on the Manildra website.
The February 2026 Shoalhaven Starches Community Consultative Committee minutes show that MOD 26 was discussed with the CCC.
The minutes also state that the next CCC meeting was scheduled for 19 May 2026 and that draft minutes would be circulated and final minutes issued after endorsement.
However, no May 2026 minutes appear to be publicly available.
This means the community cannot determine:
• what discussion took place regarding MOD 26 immediately before exhibition;
• whether concerns were raised;
• what responses were provided by the company; or
• whether the community's views influenced the project.
Although a CCC exists, the absence of publicly available records from the most relevant meeting creates the impression that meaningful community consultation is not occurring in a transparent manner.
A project of this scale should involve clear, publicly accessible and up-to-date consultation outcomes. We should not have to be trying to find information - it should be easily accessible to the community being impacted by this ongoing development.
7. Public benefit should be more clearly demonstrated
Manildra Group is a private company.
The application clearly explains the operational and logistical benefits of the proposal to the company. However, the public benefits are less clearly articulated.
The Department should require stronger evidence of how MOD 26 will benefit the broader community, particularly where residents may be expected to accept additional industrial infrastructure and associated environmental risks.
Conclusion
I request that the Department carefully consider:
1. The cumulative impacts of ongoing industrial expansion at the Shoalhaven Starches site.
2. Existing unresolved noise and odour concerns.
3. Floodplain and wastewater risks.
4. Riverbank stability and downstream environmental impacts.
5. The lack of transparent community consultation records relating to MOD 26.
6. The need for stronger demonstration of public benefit.
If the project is approved, conditions should include independent monitoring, public reporting of environmental performance, and stronger community engagement requirements to ensure local residents remain informed about impacts and compliance outcomes.
Thank you for considering this submission.

I realise I won't be writing this with any legal background or understanding of what truly is going on, but as a local resident, I'm very concerned about the impact the expanded site will have on local roads (already terrible), traffic, the train delaying residents despite it being a public road (already bad; I only wonder what it will truly be like after the site expands; hopefully better, but I doubt it), and especially, to risks pertaining to dust, odour and air emissions, wastewater, stormwater and contamination risks and especially, to fire, explosion and emergency risks.

The Manildra starches plant already has huge negative impacts on the Bomaderry community. This includes 24/7 noise, unreasonable lighting and visual (building height) impacts, encroachment onto nearby public roads, major heavy vehicle damage to roads, disruption of commuter rail and road functions, and congestion of roadside reserves with employee vehicles. There are major workplace safety incidents regularly at the site, and I have seen little evidence that the company intends to change their practices. They certainly arent a fit organisation to have such major expansion improved unless all of these issues can be significantly curbed. The presence of odours, spilled grain, dust and various other pollutants and rubbish that finds its way into every part of the surrounding area has been associated with dead birds, algal bloom, and physical and psychological harm to those who remember what Bomaderry was once like before this corporation got control of the town.
Expansion to the East will worsen all of these impacts tenfold, as Bolong road is an alternative entry road into the area for locals.
Manildra also do not seem to be a forward planning organisation in terms of their environmental impact, and all of their operations are heavily dependent on polluting fossil fuel and gas consumption. The plant itself produces vast amounts of CO2, recently added a major natural gas pipeline to power its equipment when it should have been forced to use more renewable energy where possible. The company transports in trainloads of food-grade grain from distant regions and uses it to produce ethanol from fermentation. This is a very wasteful process and the presence of volatile flour dust, electricity, heat and moisture, ethanol and now a huge gas plant in close proximity add up to a ticking time bomb for the Bomaderry community.
I do not believe any of the proposed expansions are appropriate for the location of the site.

As a resident of Shoalhaven heads and daily user of Bolong Rd for access to health services, groceries, schools, and work commuting, I’d recommend a major upgrade to the roads infrastructure and particularly the rail crossing and signalling at Manildra. There is no signage to alert drivers when the crossing is being used leading to lengthy delays with no way of turning around or diverting through Hannigans lane once you pass the old milk factory.

Further, the road is crumbling under the weight of existing truck traffic and requires a complete re surface.

As a resident of Shoalhaven Heads, we frequently smell the off-gassing of fermentation products from Manildra which is pretty gross. It would be great to get assurance that this wasn’t going to be worse (ideally it would be addressed as part of any planned work at the site).

I’d love to understand if there are more local jobs being created through this expansion. I’ve love to know that the train timetables aren’t going to be impacted. I’d love to know that appropriate green zones are being planted to support environmental carbon offset.

There’s also no walk way or bike path along the edge of the length of the facility meaning workers must drive to the site adding more traffic (24/7) to the road.

With all this additional building is there more checks and balances being made to ensure there isn’t any environmental damage (especially to the river) from the building site? The recently collapsed grain silos (which dumped tonnes of grain into the Shoalhaven river) are sitting in the middle of a paddock across the road- a complete eyesore.

Please make sure that the additional works don’t further impact and degrade the public access, environmental considerations and impacts to the site.

This submission does not oppose manufacturing or Manildra's contribution to regional employment. It asks whether, after more than 35 successive modifications over almost two decades, the planning system is still providing sufficient transparency and strategic oversight for one of the NSW South Coast's largest industrial developments.

The attached submission raises concerns regarding cumulative intensification, the absence of a contemporary whole-of-site Master Plan, strategic suitability as Bomaderry evolves, impacts on the shared public rail corridor, environmental and engineering governance following recent EPA and SafeWork action, the distinction between expansion and remediation works, and cumulative risks to the Shoalhaven River and surrounding community.

Rather than assessing Modification 26 in isolation, I respectfully request that the Department consider whether the cumulative evolution of this State Significant Development now warrants a broader strategic review, cumulative impact assessment and greater public transparency.

Please see the attached response from the local office.

I object to Mod 26 in its current form and seek further assessment before approval.